Citronen Base Metal Project

Licence 2007/02

Licensee Bedford (No. 3) Limited (a wholly owned subsidiary of Ironbark Zinc Limited)

SOCIAL IMPACT ASSESSMENT

June 2016 Rev 9

Social Impact Assessment Citronen Base Metal Project

Prepared by

Ironbark Zinc Limited Level 1 350 Hay Street Subiaco 6008 Western Australia Tel.: + 61 8 6461 6350

and

Grontmij A/S Granskoven 8 DK-2600 Glostrup Tel: + 45 4348 6060

REV. NO ISSUE DATE DESCRIPTION OF REVISION 01 May 2014 Draft report issued to MIMR for review (English). 02 June 2014 Draft report submitted to MLSA. Lodged as part of Licence application in English, Danish and 03 October 2014 Greenlandic. 04 February 2015 Resubmitted with MRA comments incorporated. 05 March 2015 Resubmitted with MRA comments incorporated. 06 April 2015 Resubmitted with MRA comments incorporated. 07 May 2015 Resubmitted with MILT comments incorporated. Submission for Public Comment with MILT comments 08 May 2015 incorporated. 09 June 2016 White paper updates

Social Impact Assessment Citronen Base Metal Project

Contents

1 NON-TECHNICAL EXECUTIVE SUMMARY 1-1

1.1 Summary of Benefits for 1-2

1.2 Objective of SIA 1-3

1.3 Approach and Method 1-3

1.4 Impact Analysis Method 1-3

1.5 Legislation 1-3

1.6 Description of the project 1-4 1.6.1 Secondary Processing 1-5

1.7 Study Area 1-5

1.8 Description of social baseline conditions 1-6 1.8.1 Demographic profile 1-6 1.8.2 Cultural Values and Natural Resources 1-6 1.8.3 Tourism 1-6 1.8.4 Socio-Economic Aspects 1-6 1.8.5 Education 1-7 1.8.6 Health care 1-7

1.9 Potential impacts 1-7 1.9.1 Employment 1-8 1.9.2 Industry and Commerce 1-9 1.9.3 Employee Transportation 1-10 1.9.4 Conflicts and synergies with other sectors 1-10 1.9.5 Salary boost 1-11 1.9.6 Taxes and revenues 1-11 1.9.7 Education and training 1-11 1.9.8 Existing infrastructure and Public Services 1-11 1.9.9 Demography and Population 1-12 1.9.10 Social conflicts 1-12 1.9.11 Vulnerable groups 1-13 1.9.12 Criminality 1-13 1.9.13 Occupational health and risk of accidents 1-13 1.9.14 Health - public health 1-13 1.9.15 Cultural and Natural Values 1-14 1.9.16 Cumulative impacts 1-14

1.10 Overview of impacts 1-14

1.11 Proposed mitigations 1-17

1.12 Public Participation 1-21

Social Impact Assessment Citronen Base Metal Project

2 INTRODUCTION 2-22

2.1 Objective of the SIA 2-22

2.2 Background 2-22

2.3 Study area and temporal boundaries 2-23

3 POLICY, LEGAL AND ADMININISTRATIVE FRAMEWORK 3-24

3.1 General political situation in Greenland 3-24

3.2 Legal Framework 3-24 3.2.1 Greenlandic legislation 3-24 3.2.2 Orders on Occupational Health and Safety relevant to the project 3-28 3.2.3 Bill to amend the Act on Income Tax 3-28 3.2.4 Taxes and Revenues 3-29 3.2.5 Royalty 3-29 3.2.6 Tax regulation 3-29 3.2.7 National guidelines relevant to the project 3-32

3.3 International Unions and Conventions 3-33 3.3.1 International Labour Organisation Conventions 3-35

3.4 National and International Guidelines on Social Impact Assessment 3-35

3.5 National Strategies 3-36 3.5.1 The Oil and Mineral Strategy for Greenland 2014 – 2018 3-36 3.5.2 The Employment Strategy 2015 – 2017 3-38

4 PROJECT DESCRIPTION 4-39

4.1 General area description 4-39

4.2 Mining and ore processing 4-39

4.3 Tailings waste 4-40

4.4 Waste rock 4-41

4.5 Port facility 4-41

4.6 Shipping 4-41

4.7 Site access 4-43

4.8 Supporting Infrastructure 4-44 4.8.1 Power and Fuel 4-44 4.8.2 Administration and mine buildings 4-45 4.8.3 Accommodation 4-45 4.8.4 Heating, ventilation and air conditioning system 4-45 4.8.5 Domestic and industrial waste management 4-45

Social Impact Assessment Citronen Base Metal Project

4.8.6 Health and safety management 4-46 4.8.7 Emergency Preparedness 4-46 4.8.8 Personnel 4-46

4.9 Construction 4-46

4.10 Description of the planned transportation routes (goods and staff) 4-46

4.11 Secondary processing evaluation 4-47 4.11.1 Zinc market and concentrate sale terms 4-48 4.11.2 Secondary processing on site 4-48 4.11.3 Selection of Processes 4-49 4.11.4 Process comparison 4-51 4.11.5 Capital cost estimate 4-51 4.11.6 Operating Costs 4-52 4.11.7 Risks 4-52 4.11.8 Conclusion 4-53

5 APPROACHES AND METHODOLOGIES 5-54

5.1 SIA team 5-54

5.2 Approach to SIA 5-54 5.2.1 General approach 5-54 5.2.2 Approach to the scoping phase 5-55

5.3 Study area and temporal boundaries 5-55

5.4 Baseline study 5-56

5.5 Data collection and research from secondary data 5-56

5.6 Data collection and research from primary sources 5-56 5.6.1 Qualitative methods 5-56 5.6.2 Quantitative methods 5-57

5.7 Impact analysis methodologies 5-57

5.8 Mitigation measures and measures to maximize the benefits 5-58

6 SOCIAL AND ECONOMIC BASELINE CONDITIONS 6-59

6.1 Introduction 6-59

6.2 Demographic profile 6-59 6.2.1 Population 6-60 6.2.2 Ethnic composition 6-62 6.2.3 Size of workforce 6-62 6.2.4 Migration 6-63 6.2.5 Intermunicipal migration and intramunicipal migration 6-64

6.3 Social and Cultural indicators of well being 6-65

Social Impact Assessment Citronen Base Metal Project

6.3.1 Household composition 6-65 6.3.2 Important goods and services 6-66 6.3.3 Important values 6-66 6.3.4 Language 6-67 6.3.5 Use of natural resources 6-68 6.3.6 Homelessness and crime 6-69

6.4 Socio-economic aspects 6-71 6.4.1 Personal income 6-71 6.4.2 Cost of living 6-73 6.4.3 Business structure in the public and private sector 6-74 6.4.4 Description of existing labour market structure 6-75 6.4.5 Level of education 6-78 6.4.6 Social structure 6-81 6.4.7 Public Authorities covering the 6-84 6.4.8 Transport facilities and infrastructures 6-86

6.5 Health 6-86 6.5.1 Public Health 6-86 6.5.2 Vulnerable groups 6-88 6.5.3 Health strategies 6-90

7 POTENTIAL IMPACTS AND MAXIMISATION OF DEVELOPMENT OF OPPORTUNITIES AND MITIGATING NEGATIVE IMPACTS 7-91

7.1 Summary of Benefits for Greenland 7-93

7.2 Economic environment 7-97 7.2.1 Employment 7-97 7.2.2 Business life 7-102 7.2.3 Provision of service of camps 7-105 7.2.4 Conflicts and Synergies with other sectors 7-108 7.2.5 Salary boost 7-109 7.2.6 Taxes and revenues 7-110

7.3 Education and training 7-113 7.3.1 ASSESSMENT 7-114

7.4 Public service and infrastructure 7-115 7.4.1 Existing infrastructure 7-115 7.4.2 ASSESSMENT 7-116 7.4.3 Public services 7-116 7.4.4 Tasks for the police 7-117 7.4.5 Working and resident permits 7-117 7.4.6 Health service 7-117 7.4.7 ASSESSMENT 7-118

7.5 Social aspects 7-118 7.5.1 Demography and population 7-119 7.5.2 ASSESSMENT 7-119 7.5.3 Social conflicts 7-119

Social Impact Assessment Citronen Base Metal Project

7.5.4 Vulnerable groups 7-121 7.5.5 Assessment of potential criminality at the mining site 7-121

7.6 Health 7-122 7.6.1 Occupational health and risk of accidents 7-122 7.6.2 Health of employees at the mine 7-125 7.6.3 Public health and quality of life 7-126

7.7 Cultural and natural values 7-126 7.7.1 Sites of monumental or cultural importance 7-126 7.7.2 Access to natural areas 7-127

7.8 Cumulative impacts 7-128

8 DRAFT MONITORING PLAN AND DRAFT EVALUATION PLAN 8-134

9 PUBLIC PARTICIPATION 9-139

9.1 Introduction 9-139

9.2 Overview of stakeholder involvement 2010 9-139

9.3 Overview of stakeholder involvement 2014 9-140

10 REFERENCES 10-144

Figures

Figure 1-1 risk assessment codes ...... 1-15 Figure 4-1 Basic Process Flow Diagram ...... 4-40 Figure 4-2 Shipping route Iceland to Greenland (MTHojgaard, June 2014)...... 4-42 Figure 4-3 Approximate shipping route north coast Greenland...... 4-43 Figure 4-4 Smelter Capacity. (Source: CRU Zinc Outlook October 2013) ...... 4-48 Figure 5-1 Risk assessment codes ...... 5-57 Figure 6-1 Map of Greenland showing municipalities and main towns ...... 6-59 Figure 6-2 Total population in Greenland, 2003-2013 ...... 6-60 Figure 6-3 Population distributed in municipalities in July 2013 ...... 6-61 Figure 6-4 Population trends and population projection from 1990 to 2040 ...... 6-61 Figure 6-5 Size of the workforce by gender and age in Greenland in 2013 ...... 6-63 Figure 6-6 Migration to and from Greenland between 2003 and 2012 ...... 6-64 Figure 6-7 Number of persons registered without an address ...... 6-69 Figure 6-8 Offences for breach of the criminal law ...... 6-70 Figure 6-9 Most frequent types of criminal acts in percent in 2012 ...... 6-71

Social Impact Assessment Citronen Base Metal Project

Figure 6-10 Average household income before taxes for Greenland and all municipalities ... 6-72 Figure 6-11 Average personal income distributed by percentage of the population in DKK, 2012 ...... 6-73 Figure 6-12 Turnover by business in Greenland in 2011 ...... 6-75 Figure 6-13 Educational profile by ISCED-2011 levels by gender between 2002-2012 ...... 6-80 Figure 6-14 Distribution of the public capital expenditure in Greenland from 2006 and 2015. 6-81 Figure 6-15 No. of reported TB cases in Greenland, 2008-2012 ...... 6-87 Figure 6-16 Suicides, divided by gender, 2002-2011 ...... 6-89

Tables

Table 1.1 Overview of the impact matrix ...... 1-16 Table 3.1 Main legislation for the Citronen Fjord Project ...... 3-25 Table 3.2 Orders on Occupational Health and Safety relevant to the project ...... 3-28 Table 3.3 Overview of income tax rates for the different municipalities ...... 3-31 Table 3.4 Greenlandic National Guidelines ...... 3-32 Table 3.5 Relevant International Unions and Conventions ...... 3-33 Table 4.1 Input and output comparison of secondary processing alternatives ...... 4-51 Table 4.2 Capital cost comparison of secondary processing alternatives ...... 4-51 Table 4.3 Operating cost comparison of secondary processing alternatives ...... 4-52 Table 6.1 Ethnic composition in municipalities by place of birth in July 2013 ...... 6-62 Table 6.2 Migration within municipalities in 2012 ...... 6-65 Table 6.3 Total households and occupants in Greenland Jan 2013 ...... 6-66 Table 6.4 Consumer Price Index (2008=100) by commodity and time ...... 6-73 Table 6.5 Average number of employment per month by main sector in Greenland in 2011 . 6-75 Table 6.6 Average unemployment of the labour force by gender and quarter in 2011 ...... 6-77 Table 6.7 Average number of unemployed per month by education and gender in 2008 ...... 6-77 Table 6.8 Persons having enrolled and completed education in 2005 and 2009 ...... 6-79 Table 6.9 Number of applicants at university in 2011 and 2013 ...... 6-79 Table 6.10 Number of reported cases of gonorrhoea and chlamydia in Greenland in 2012 ... 6-87 Table 6.11 Perception of social problems among adult Greenlanders...... 6-88 Table 6.12 Abortion rates in Greenland in 2012 ...... 6-89 Table 7.1 Risk assessment matrix ...... 7-91 Table 7.2 Overview of assessment ...... 7-94 Table 7.3 Project Job categories, functions, number required on site and total number...... 7-98 Table 7.4: Number of employees per year and the expected share of local employees ...... 7-99 Table 7.5 Assessment of the project’s impact on Greenlandic employment ...... 7-101 Table 7.6 Equipment and materials required for the Project ...... 7-104 Table 7.7 Assessment of the project’s impact on Greenlandic business life ...... 7-107 Table 7.8 Assessment of the project’s impact on conflicts and synergies with other sectors 7-109 Table 7.9 Assessment of the project’s influence on salaries...... 7-110 Table 7.10 Overview of expected income tax of personnel during construction phase ...... 7-110 Table 7.11 Overview of expected corporate tax and income tax of personnel during 14 years of operation ...... 7-110 Table 7.12 Estimated number of workers, expected wage expenditure and expected income taxes during the construction period ...... 7-111 Table 7.13 Estimated number of workers, expected wage expenditure and expected income taxes during the operation period ...... 7-111

Social Impact Assessment Citronen Base Metal Project

Table 7.14 Assessment of the project’s influence on Greenland’s tax and revenue income 7-112 Table 7.15: Number of persons with an education in selected fields, 2012 ...... 7-113 Table 7.16 Assessment of the projects impact on education and training...... 7-114 Table 7.17 Assessment of the projects impact on infrastructure ...... 7-116 Table 7.18 Assessment of the projects impact on public services ...... 7-118 Table 7.19 Assessment of the project’s impact on demography and population ...... 7-119 Table 7.20 Assessment of possible social conflicts ...... 7-120 Table 7.21 Assessment of the project’s impact on vulnerable groups ...... 7-121 Table 7.22 Assessment of potential criminality at the mining site ...... 7-121 Table 7.23 Assessment of occupational health and risk of accidents ...... 7-124 Table 7.24 Assessment of the projects impact on the health of employees ...... 7-125 Table 7.25 Assessment of the project’s impact on public health and quality of life ...... 7-126 Table 7.26 Assessment of the project’s impact on sites of monumental or cultural importance . 7- 127 Table 7.27 Assessment of the project’s impact on access to natural areas ...... 7-128 Table 7.28 Assessment of the project’s impact on cumulative impacts ...... 7-129 Table 7.29 Overview of impacts, proposed mitigations and impacts after mitigation (draft Benefit and Impact Plan) ...... 7-130 Table 9.1 Overview of the stakeholder engaged in October 2010 ...... 9-140 Table 9.2 Overview of the stakeholder engaged in 2014 ...... 9-142

Appendices

Appendix 1 Public participation summary from SIA (Draft) Feb 2011...... 10-147 Appendix 2 Invitation letter for stakeholder engagement in 2014...... 10-151 Appendix 3 Detailed responses from stakeholder involvement in 2014...... 10-153

Social Impact Assessment Citronen Base Metal Project

Definitions and abbreviations

Wording or abbreviation Explanation APP Local fishermen and hunting association AVATAQ Greenlandic nature and environment society The Baseline study describes the socio-economic and social conditions in the area(s) of the potentially affected Baseline Study by the project before the project is realised. The baseline is used to identify the expected impacts of the mining project. BAT Best Available Technique Benefit and Impact Plan - A plan of the proposed initiatives to realise and optimise the benefits of the project and to minimise or mitigate the negative impacts. BIP A draft Benefit and Impact Plan will be the starting point for negotiation of the Impact Benefit Agreement (IBA). A final Benefit and Impact Plan will be included in the IBA. DKK Danish Crowns Dead Weight Tonnage - Deadweight tonnage is a DWT measurement of the capacity in long tonnes of cargo, fuel, stores, passengers etc. of a vessel. EIA Environmental Impact Assessment FIFO Fly-In-Fly-Out basis GE Greenland Business Greenlandic workforce Worker who is also a resident of Greenland GWQG Greenland Water Quality Guidelines Human Immunodeficiency Virus/ Acquired Immune HIV/AIDS Deficiency Syndrome HMS Heavy Media Separator HR Human Resources HSEC Health Safety Environment and Community IBA Impact and Benefit Agreement ICC Inuit Circumpolar Council ICMM International Council on Mining and Metals IFC International Finance Corporation ILO International Labour Organization Inuit Aboriginal/local people of Greenland IUCN International Union for Convention of Nature KANUKOKA Association of Greenland Municipalities KNAPK National fishermen and hunters’ association LHD Load Haul Dump Local workforce Workforce from Greenland

Social Impact Assessment Citronen Base Metal Project

Marine Pollution – International Convention for the MARPOL Prevention of Pollution from Ships 1973/1978 MMR Ministry of Mineral Resources MILT Ministry of Industry, Labour and Trade MMU Mobile Mixing Unit NUSUKA Greenlandic Employer’s Union Greenland Government OHS Occupational Health and Safety PAARISA Centre of health prevention PFA Danish Pension Fund RAL A/S ROM Run of Mine SIA Social Impact Assessment Sulinermik Inuussutissarsiutteqartut Kattuffiat – SIK Employee’s Union of Greenland SISA Employee’s Pension Fund SLiCA Survey of Living Conditions in the Arctic SOLAS International Convention for the Safety of Life at Sea STD Sexual Transmitted Diseases SU Student Grant TB Tuberculosis TEU Twenty foot Equivalent Unit Terms of Reference - The document which describes the ToR expected focus and plan for the SIA process. TPA Tonnes per annum United Nations Educational, Scientific and Cultural UNESCO Organization VSB Assessment of Societal sustainability Q&A Questions and Answers

Social Impact Assessment Citronen Base Metal Project

1 NON-TECHNICAL EXECUTIVE SUMMARY

This is the non-technical executive summary of the Social Impact Assessment (SIA) for the Citronen Fjord Project, wholly owned by Ironbark Zinc Ltd. The Citronen Fjord Project is located in Peary Land within the North East Greenland National Park. Citronen Fjord is approximately 2,000km north-northeast from and 940km from Qaanaaq, the nearest Greenlandic settlement.

A separate Environmental Impact Assessment (EIA) has been prepared.

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Social Impact Assessment Citronen Base Metal Project

1.1 Summary of Benefits for Greenland

Value/ Benefit Item DKK (6.8 DKK : 1 USD)

Initial Capital Expenditure (CAPEX) 3.3 billion

Operating Expenditure 24 billion

Personal tax - construction 88 million

Personal tax - operation 1.9 billion

Corporate/Withholding tax – operation 2.0 – 2.7 billion

National Employment - construction 60 persons

National Employment - operation 235 persons by Year 5 423 persons by Year 7 Employment package Salary, location allowance, travel allowance (variable %- home to ), training.

Education and training Pre-employment and on-the-job training program for the required job categories during operation phase, in cooperation with local authorities, education institutions and construction contractor early in the detailed planning of the project. Underground mining training facilities established with education institutions. Apprenticeships. Business and enterprise Opportunity to bid for contract packages for supply of goods and services, including catering services, cleaning, laundry and similar tasks, provision of local food. Opportunity to bid for contract packages for transportation of goods and staff. Opportunities for contracts for local tradesmen such as carpenters, engineers, electricians etc Opportunities for contracts for IT and communication services. Potential opportunities for local fuel providers (as Polaroil). Special attention will be given to type of fuel and opportunities of transport of fuel to the location. Establishment of a forum with GA, Nusuka and the municipalities (business councils). This forum will be used before and during tendering process to provide information and clarification of the tenders.

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Social Impact Assessment Citronen Base Metal Project

1.2 Objective of SIA

The overall objective of the SIA was to identify and analyse the potential impacts of the proposed Project and to recommend initiatives to realise sustainable development opportunities as well as to mitigate the negative impacts. The SIA is based on a high degree of engagement of the stakeholders.

1.3 Approach and Method

The Bureau of Minerals and Petroleum (BMP) SIA Guidelines of November 2009 were used as the reference to establish a minimum level of information, content, and general structure of the SIA. The SIA was based on a participatory approach, involving the stakeholders during the development of the SIA. The SIA identified the potential impacts from the Project on the valued socio-economic components. All relevant potential impacts were identified, with priority given to those identified as the biggest concerns by stakeholders and authorities. For the potential impacts identified, the SIA includes the evaluation of the impact (significance) and propose possible mitigations. The net impact after the application of the mitigation measures is further evaluated. Potential benefits are identified and where possible measures to maximise them are included.

1.4 Impact Analysis Method

The impact assessment was based on an assessment of the positive and/or negative impacts from the project based on a set of social/socio-economic aspects with the use of an Impact Matrix. The impact on the social/socio-economic aspects (employment, business life, health, vulnerable groups, etc.) are assessed of the project (such as transport, provision of goods, operation of camp, mine site and processing plant etc).

For each combination of project activity and social/socio-economic aspect, both for the construction and the operation phases, the positive and negative impacts of the project have been predicted and its magnitude quantified as far as possible.

Mitigation measures have been identified for all negative impacts likely to occur, are adverse in nature and significant enough to require mitigation [medium and high-level (negative) impacts] in order to diminish or eliminate such impacts. Furthermore, mitigation measures that can lead to increased positive impacts have been identified.

1.5 Legislation

The main legislation for the Project is Act no. 7 of 7 December 2009 on Minerals and Resources (Act on Mineral Resources), which came into force on January 1, 2010.

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Social Impact Assessment Citronen Base Metal Project

1.6 Description of the project

The proposed Citronen Zinc project (the Project), includes the development, operation and ultimate reclamation of a zinc and lead mine at Citronen Fjord in Peary Land, Greenland. The Project will comprise mining three deposits (both open pit and underground) with an on-site processing facility to produce globally saleable mineral concentrates of zinc and lead. The concentrates will be shipped off-site to Iceland or another northern European port and subsequently to a third party smelter complex. As per the schedule, the project has two years of construction and an estimated mine life of at least 14 years. There is no existing infrastructure at the site and consequently all infrastructure and ancillary facilities need to be developed as part of the project.

A construction contractor will be used to provide construction services, equipment and personnel.

The proposed mining operation will occur at a rate of 3.3 million tonnes per annum at three deposits: initially two below surface and later an open pit. Approximately 40 million tonnes will be mined at an average grade of 5.4% zinc and lead.

The mined ore will be delivered by trucks to the processing plant. The ore will first pass through a two stage crushing process followed by Dense Media Separation (DMS), which acts as a pre-concentration step. The ore continues onward through a milling process before entering the flotation section of the plant, where the valuable zinc and lead concentrates are separated from the gangue (worthless) material. The flotation gangue is initially disposed of at the tailings storage facility (TSF), and later in the underground voids left by mining as backfill. After flotation the froth is cleaned and the concentrate dewatered through pressure filters to produce a concentrate cake. The globally saleable concentrate will be stored within a large concentrate dome before being shipped off site.

The project will consist of:

 Underground mine (room and pillar method)  Open pit (drill and blast, load and haul)  Processing plant (crushing and flotation)  Waste dump  Rejects dump  Tailings storage facility  Port site  Fuel storage  Concentrate storage  Airstrip  Accommodation camp  Infrastructure (roads, warehouses, administration buildings)  Power supply (heavy fuel power generators)

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Social Impact Assessment Citronen Base Metal Project

 Water supply (water will be supplied from Lake Platinova)  Sewage treatment (liquid waste generated at the camp will be treated and discharged into the Fjord)  Waste plant (solid waste generated will be treated in an incineration plant on site).

1.6.1 Secondary Processing

It is a requirement under the Act on Mineral Resources that the potential for downstream processing is evaluated prior to an exploitation licence being granted.

Batemans Engineering Pty Ltd was commissioned by Ironbark to produce a report which examines the traditional zinc smelting technologies, and provides operating and capital costs for each of these options to allow the evaluation of downstream processing to be undertaken.

Each of these processes will add significant capital cost to the project (doubling to tripling the capital cost of the project), and would duplicate capacity which is currently available worldwide, typically where power or transport synergies exist. These processes require large amounts of energy, either through electricity or coal, and specialised shipping would have to be constructed to bring these to Citronen.

Zinc concentrate prices are agreed, at arm’s length, annually in negotiations between smelters and miners. All of Ironbark offtake agreements are at arm’s length to ensure the highest prices possible will be obtained.

Given Citronen’s remote location, lack of significant power generation facilities and transparent nature of the zinc market, it is not feasible to construct a secondary processing facility on site.

1.7 Study Area

The SIA covers the area directly impacted by the mining operations and ancillary facilities (port, airport, camp etc.) where the impacts and benefits of employment, business opportunities and developments directly and indirectly created by the Project are expected to be more noticeable.

As the Project is located in a remote area outside the border of the four municipalities the project’s area of influence in terms of the SIA is Greenland as a whole. For the baseline study the information was processed and analysed at two levels: national and the four municipalities. All four municipalities were engaged on an equal basis.

The SIA covers the Project stages construction (two years), operations (14 years) and closure (post operation).

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Social Impact Assessment Citronen Base Metal Project

1.8 Description of social baseline conditions

1.8.1 Demographic profile

The total population of Greenland is 56,483 (July 2013). Greenland’s population primarily consists of Greenlanders, or Kalaallit, with roughly 11 percent comprised of Danes and other Europeans.

Greenland´s spatial distribution is unequally inhabited with the population concentrated in few areas, primarily divided between the four municipalities, Qaasuitsup Kommunia, Qeqqata Kommunia, Kommuneqarfik Sermersooq, and Kommune Kujalleq. The Project lies outside of these municipalities, in the north east of the national park. There are no towns or settlements in the region of the National park and apart from the personnel at meteorological stations and the Danish Armed Forces surveillance unit no people live in the area.

1.8.2 Cultural Values and Natural Resources

Generally in Greenland, traditional and cultural activities and customs are very important to the local communities, according to SLiCA, Survey of Living Conditions in the Arctic (Poppel, B. et al, 2004). Values include the preservation of traditional foods, hunting and fishing, the use of the , poetry and literature, or religious and spiritual beliefs. Greenlandic people are very involved in the use of natural resources, either commercially, for additional income or recreationally.

1.8.3 Tourism

The Greenlandic culture, amazing landscapes and wildlife are the main reasons for tourists to visit Greenland. In the national park, tourists only travel in the southern part of the park to discover landscapes and wildlife like walruses and polar bears. The region is also visited to investigate relics from former settlements along the coast (source:greenland.com).

1.8.4 Socio-Economic Aspects

Greenland’s economy is based on fishing and fish products. In addition, Greenland receives a block grant of some DKK 3.45 billion (2012) from Denmark, which is equivalent to approximately 40 percent of the public revenue.

The private sector in Greenland primarily consists of small enterprises such as retailers, builders, fishermen, hotel and catering, as well as repair services, apart from a few large national enterprises that are owned by the Self-Government. These national companies employ most of the workforce (Skatte- og velfærdskommission, 2010). The private sector has the highest revenue with retail trade, whole sale and repair work, counting for almost half of the total turnover in Greenland (47.7 percent). In 2014, the mining industry counts for 0.3 percent (DKK 55 million).

The number of unemployed was on average 3,960 persons per month, equivalent to 13.0 percent of the potential workforce in the first quarter of 2014. In 2006, this number was 5.6 percent.

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Social Impact Assessment Citronen Base Metal Project

1.8.5 Education

University education, vocational and commercial programs are free in Greenland (paid through the tax system). Students with a certain grade average from upper secondary school are admitted. Most students are eligible for financial support.

From 2006 to 2013, the number of graduates from formal post-primary education has increased by 64 percent. According to international standards Greenland has a high percentage of persons who have completed primary school and low percentage for secondary and tertiary education compared to other European countries.

1.8.6 Health care

All health care treatment in Greenland is free, including medication and dental treatment, being financed through the tax system (www.naalakkersuisut.gl or www.aka.gl).

Greenlanders are increasingly abandoning the traditional Greenlandic lifestyle and foods and choosing to adopt a Western lifestyle, resulting in an increase in welfare based diseases such as diabetes, heart diseases, cardiovascular diseases and obesity since 1993. (Bjerregaard, P. and Aidt, E.C., 2010).

Tuberculosis (TB) has been recognised as a prevalent disease in Greenland. On average, 88 persons have contracted TB each year for the past five years. The majority of the cases have been reported in municipality of Sermersooq, especially Tasilliaq have had many cases since 2010 (Landslægeembedets årsberetning, 2011 & 2012).

1.9 Potential impacts

The potential impacts of the Citronen Fjord Project during both the construction and operation phases, as well as for the closure of the project are assessed.

The assessment is based on the valued social and socio-economic components:

 economic aspects (employment, tax and revenues and business opportunities)  education and training  public service and plans  social aspects  health  culture and natural values  cumulative effects

This non-technical summary includes only the description of the medium and high level impacts.

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Social Impact Assessment Citronen Base Metal Project

1.9.1 Employment

The project is divided into the construction and the operation phases. The construction phase will require approximately 300 workers, both local and foreign, over a period of two years. Once construction is completed and operations have commenced, the number of employees per year will increase to approximately 470 per year for the first ten years of operation and thereafter the number of employees will decrease until the end of the Project. Approximately 290 people are expected to be on site at any time. The rosters are of two types - three week on/three week off rotation and six week on/three week off rotation.

The following types of jobs will be required for the Project:

 General and administrative - IT technical staff, Occupational health advisor, Safety advisor, Environment and community advisor, and Medical, Security/Emergency response.  Maintenance - Process and Mining - Maintenance manager, Electrical engineer, Mechanical engineer, Boiler maker, and Process plant operations.  Stores and Logistics - Warehouse and stores personnel, and Port personnel.  Camp - Camp manager, Cooks, Kitchen hands, Cleaners, and Maintenance.  Off-site Management and Personnel - Operations manager, Finance manager, Business analyst/accounts, HSEC manager, Occupational health coordinator, Safety coordinator, Environmental and communication coordinator, Human resources manager, Recruitment advisor, HR advisor, Payroll, and Travel and accommodation staff.  Process Management and Operations - Process manager, Plant metallurgust, Chemist/Environment monitor, Loader operator, Crushing operator, HMS and Grinding operator, Floatation and Filter plant operator, Plant sampling and laboratory assistant.  Mine Management - Mining manager, Senior mining engineer, Mine planning, mining engineer, Senior geotechnical engineer, Geotechnical engineer, Geology manager, Geologist, and Surveyor.  Underground and Open Pit Labour - Mining foreman, Shift boss, Jumbo operator, Long-hole operator, Boltec operator, LHD operator, Truck driver, Shotfirer, Service crew, Backfill operator, Explosives Facility/Magazine keeper, Grader operator (UG), Driller, Excavator operator, Dozer operator, Shotfirer and MMU operator.

The aim of the Project is to operate with a maximum of local workforce in all job categories. The share of the local workforce is aimed to reach a level of 20 percent during the construction phase if personnel with appropriate qualifications and experience can be recruited on competitive terms. This goal of local employment will increase to 50 percent by year 3 of the operation phase, and increase further to 90 percent by year 7 of operation.

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Social Impact Assessment Citronen Base Metal Project

A construction contractor will be chosen to complete the plant construction and hence foreign workers will account for the majority of workers in the initial construction phase. Foreign operators will be progressively replaced by local workers during the construction phase with support and guidance from Greenland government agencies. The licensee’s early planning and training will be essential in order to achieve the local employment targets and attract the best candidates.

It has been recognised that barriers may exist in achieving the expected high share of local workforce. Some identified barriers are:

 The remote location of the project will make the location less attractive compared to other mining projects in Greenland;  Lack of minimum qualifications/experience for the required positions;  Competition with other mining and oil projects for qualified workers;  Lack of access to communication (such as telephone and IT) to keep in touch with home, as Greenlanders have a very strong relationships with their family;  Language barrier: it is expected that a basic level of English will be required (primarily for safety procedure communication). Potentially, unemployed workers can benefit from the job opportunities created by the Citronen Fjord Project during the construction and operation phase. However, the most likely scenario is that the project will attract mainly workers already employed in other sectors and new graduates. Indirectly, this will create new opportunities for the unemployed workers throughout Greenland.

The impact of the direct employment during the operation phase is characterised as positive minor to major, and for construction phase negligible to minor. The Citronen Fjord Project does not require the employees to move close to the mine, and therefore the positive effects of local employment will not be geographically concentrated, but distributed around Greenland.

While the duration of the employment will cease with the completion of project, benefits related to employment, such as enhancement of qualifications and experience, pension and savings, etc. will last beyond the employment time.

1.9.2 Industry and Commerce

The remote location of the Project is the most important factor when considering using local businesses and the provision of goods. The majority of equipment and supplies will require to be shipped to site. It is imperative that materials and equipment transported during the shipping window arrive at the site according to the planned window sequences to enable all work to be completed on schedule.

The Project will require one main marshalling point close to the site to take advantage of the limited shipping window. This will be a location suited to the transfer of equipment and materials from normal ocean-going ships onto ice-classed vessels. This is most likely to be Akureyri in Iceland, or a similar location.

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Social Impact Assessment Citronen Base Metal Project

The majority of the process plant equipment and steelwork will come from overseas. Equipment for the mining activities such as dump trucks, excavators etc. are expected to be purchased directly from outside Greenland.

Other consumables to be purchased during the operation phase of the project are light vehicles and vehicles supplies, furniture and equipment for the camp, stationery, clothes and safety shoes, protective gear and equipment. Most of these articles are likely to be purchased from outside Greenland. Unfortunately, Greenland does not yet have the large scale fabrication yards and employment pool with appropriate skills in sufficient quantities to enable Citronen to be exclusively using local resources.

Ironbark will outsource activities related to transportation of goods and staff as well as servicing of the camp, including catering and cleaning. Where possible and competitive, local businesses will provide these services.

1.9.3 Employee Transportation and Other Opportunities for Greenlandic Businesses

The planned transportation route for local employees will be from Kangerlussuaq directly to the Project. This flight will be paid for and organised by Ironbark. Ironbark will also provide a travel allowance that will notionally cover the cost of flights from the capitals cities of each municipality to Kangerlussuaq.

Employment package agreements (Employment terms and conditions, salary) will include this travel allowance (on top of their agreed salary).

Employees living outside Kangerlussuaq or a municipal capital city will be required to organise and pay for their own transport to these cities. Foreign employees will fly to site via Longyearbyen in Svalbard.

Local transportation companies as Air Greenland and other companies who operate in Greenland such as Air Iceland and Nordand air could provide the transport of staff.

There are opportunities related to the Project with regards to local provision of goods and services. However, it will be difficult (primarily due to transport issues to the remote location) and initiatives such as planning and corporation with local suppliers need to be in place. Based on the opportunities that exist, these are assessed to be positive negligible during construction and negligible to minor during operation.

1.9.4 Conflicts and synergies with other sectors

Potential conflicts and synergies with other sectors such as oil, minerals and construction have been identified especially with the completion of human resources. This impact is considered to be negative negligible during construction and minor during operation.

When Greenland has several mining projects in operation it is foreseen that synergies could occur within the mining sector, for example common education and training activities across the sector.

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Social Impact Assessment Citronen Base Metal Project

1.9.5 Salary boost

It is expected that there will be an increase in the economic activity due to the Project. This is as a result of salary increase for the local workers which will boost the economic activities through an increased demand for services and goods. As there is no local community near the Project, the impact of the salary boost will be spread all over Greenland and thus it will be difficult to accumulate and stimulate the local economic environment within a small community.

A salary boost and the opportunity for economic development is assessed to be positive negligible for both construction and operation phase.

1.9.6 Taxes and revenues

The main direct economic benefits from the Ironbark Citronen Zinc Project arrive from corporate taxes and income taxes from local and international employees whom will be liable to pay tax in Greenland according to the Greenland tax regulation (Act on income Taxes no. 12 of 2 November 2006).

As the Project generates income and corporate taxes this is assessed to have a positive major impact during the construction phase and a significant impact during operation.

The current exploration licence (2007/02) for the Citronen Fjord Project (Ironbark) does not include any royalties and thus royalties have not been included in the SIA.

1.9.7 Education and training

In Greenland, there is a general need and wish to improve and further develop the skills and competences of labour, in order to be prepared for potential future activities such as in the extraction industry.

Working on a mine site and a processing plant requires certain skills and education which are currently not 100 percent available in Greenland. It is anticipated that initially 80 percent of the workforce will be held by foreign employees. However once construction is finished and as the project progresses (training and education programs are completed), Ironbark aims to increase the local percentage of employment to 50 percent by year 3 and 90 percent by year 7.

It is considered that projects such as Citronen project will contribute to the general development of skills in Greenland. The impact from training and education is positive and has been assessed during construction as positive negligible to minor. During the operation phase the impact is assessed to be positive minor to major.

1.9.8 Existing infrastructure and Public Services

No infrastructure exists at the Project site, other than a temporary camp and a gravel airstrip. All required infrastructure will have to be established by Ironbark.

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Social Impact Assessment Citronen Base Metal Project

The planned air transportation route for local employees will be from Kangerlussuaq directly to Citronen. Transport of equipment and materials will primarily be on ships originating from outside Greenland. Greenlandic shipping company Royal Arctic Line was consulted regarding shipping options for the project. Although they do not have suitable ships for this type of transport they would be available for consultation and provide advice on shipping and routes for the project.

As the international workforce will be transported directly to the site from an airport outside Greenland, and as Ironbark will organise chartered transport from Kangerlussuaq to the site for local workforce, the pressure on the existing infrastructure and services are considered to be negative negligible.

Increases in some public services are expected due to the Project during the construction phase and operation phase. These are customs control (police), immigration authorities and health services. Emergency management at site will also require assistance from the police.

As there is a need for further consultation with police and other authorities, the pressure on the public services are considered to be negative major prior to mitigation measures.

The increased pressure on the health system is expected to be negative major for both construction and operation. There is the possibility that medical assistance may be required outside the expertise provided by site. The Greenland health service is already under pressure due to cost of infrastructure, the lack of sufficient personnel resources and a small Government budget. These concerns were raised by the health authorities during the stakeholder consultation.

1.9.9 Demography and Population

The Citronen Fjord Project is expected to employ up to 470 employees per year. During construction and the first years of the operation, the majority of the employees will be foreigners. During the operation phase an increasing number of local employees are expected.

A possible positive impact of the Citronen Fjord Project is an expected reduction in the negative net migration rates of Greenlanders, as a result of increased job and business opportunities. This positive impact will be obtained both if more people choose to stay in Greenland, and if Greenlanders who have earlier moved away from Greenland choose to return.

The impact on demography is assessed to be insignificant during the construction phase and positive negligible during the operation phase.

1.9.10 Social conflicts

The assessment of impacts of social conflict is based on experiences from other mining projects around the world. Identified risks are conflict between local and international employees and increased marginalisation of persons without skills to work in the mining sector.

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Social Impact Assessment Citronen Base Metal Project

The risk of social conflicts during construction is assessed to be negative minor to negligible. The risk of social conflicts during operation is assessed to be negative major to negligible as there is a risk of both social exclusion and conflict between local and international employees at site.

1.9.11 Vulnerable groups

No direct impact on any vulnerable groups is expected. However, indirect negative impacts may occur with regards to children in vulnerable families, should the most functional adult in the household be employed at the Project.

1.9.12 Criminality

During the hearing process of other proposed mining projects in Greenland, police have raised potential crime at the mining site as a concern, particularly violence and theft. The risk of criminality at the mining site is assessed to be negative major to minor during both the construction and operation phases.

1.9.13 Occupational health and risk of accidents

There is a potential risk of accidents during the construction, operation and closure of the mine, mainly related to the operation of heavy machinery, explosives, and processing. Adverse weather conditions can also lead to accidents during transportation of goods, staff and concentrate. Furthermore, the long distance to health facilities outside Project area is also a risk factor.

Even though the likelihood of accidents is low, the repercussions are very serious if anything is to happen to workers and transporters. Due to the number of workers involved and type of potential accidents involving explosives and heavy machinery the risks are significant.

Based on an overall assessment risks of accidents during construction and operation are therefore considered negative major to minor (after mitigation).

Working at a mine can have adverse effects on personal health, including illness from dust exposure, hearing issues, respiratory disease and mental health issues (due to the remote location of the Project).

Communicable diseases are also a risk due to many employees living in a small community.

1.9.14 Health - public health

A mining project’s operations will have an impact on the health and quality of life of the employees and the public in general. These negative impacts are often related to interactions between the local community and the influx of staff.

Due to the remote location of the Project, where foreign employees are expected to fly to the site from outside Greenland, there will be no influence of foreign workers on towns and settlements.

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Social Impact Assessment Citronen Base Metal Project

With many employees from different countries and cultures living full time at the mine site for several weeks, the largest risk for impacts of the public health derives from infections received at the mine site and brought back to the home communities. A health screening for STD and HIV/AIDS will be required before employment. This impact is assessed to be negative negligible.

1.9.15 Cultural and Natural Values

An archaeological survey of the Project area (July 1994) noted a site with potential pre- historical significance. This site comprises three stones arranged in a row, and may have been placed by members of the Thule culture to support an “umiak” – an 8-10 metre-long open boat used in summer to move people and possessions to seasonal hunting grounds (EIA 2014). Greenland’s National Museum recommends that these finds be registered and dated before any activity is undertaken in the area. The stones may also be a natural occurrence as the area is almost exclusively populated with stones as a result of recent glacial activity.

Based on the previous surveys the impacts of the project on ‘Sites of monumental or cultural importance’ during the construction phase are assessed to be negative major before mitigation as the registration is needed. After this registration the impact will be negligible. During operation the impact is assessed to be negligible.

Peary Land, including Citronen Fjord, is not used for fishing, hunting or other human activities by the Greenlandic population or people from other nations. This is due to the remoteness and the fact that sea ice covers the ocean around North Greenland most of the year. Furthermore, as the licence area is located in the National Park, hunting and fishing activities are not allowed unless you have obtained a permit (Order no. 7 of 17th June 1992).Accordingly, it was decided that a local use study was not necessary due to the remote nature of the project and Peary Land has been un-inhabited for the last 600 years. Based on this the impact of the access to natural areas are considered to be not significant.

1.9.16 Cumulative impacts

The cumulative impacts recruitment of local staff for the Citronen Fjord project is assessed to be negative negligible as increased competition of local workers as other mining projects are established will lead to increased competition for local workers. This may result in more international workers and could lead to an increased number of negative social conflicts.

1.10 Overview of impacts

For each social and socio-economic component the impact has been assessed before and after mitigation for the construction phase, the operation phase, and where relevant the closing phase.

The result of the assessment is presented using the following colour codes indicating whether the impact is non-significant, negligible, minor, major or significant (Figure 1-1). The assessment is based on an evaluation of the likelihood of the impact taking place and the magnitude of the impact should it take place.

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Social Impact Assessment Citronen Base Metal Project

Positive Impact/ Magnitude Adverse Impact Benefit Very High High Moderate Low Low Moderate High Very High Highly likely

Probable Significant Major Minor Negligible Negligible Minor Major High Likelihood

Unlikely Not significant Not

Very unlikely Figure 1-1 risk assessment codes

An overview of the impact matrix, identifying areas with high, medium and low impacts before the mitigation measures are applied is presented in Table 1.1.

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Social Impact Assessment Citronen Base Metal Project

Table 1.1 Overview of the impact matrix Issue Construction phase Operation phase Before mitigation After mitigation Before mitigation After mitigation Economic impacts Employment Negligible Minor Minor Major Business life Negligible Negligible Negligible Minor Conflict with other sectors: Negligible No mitigation Major Minor Mineral sector required Conflict with other sectors: Negligible No mitigation Major Minor Building and construction sector required Conflict with other sectors: Not significant No mitigation Not significant No mitigation Fishing and hunting activities required required Salary boost Negligible No mitigation Negligible No mitigation required required Taxes and revenue Major No mitigation Significant No mitigation required required Education and training Education and training Negligible Minor Minor Major Public service and plans Existing Infrastructure Negligible No mitigation Negligible No mitigation required required Public services Major Minor Major Minor Social aspects Demography and population Not significant No mitigation Minor No mitigation required required Social conflicts Minor Negligible Major Negligible Vulnerable groups Negligible No mitigation Negligible No mitigation required required Potential criminality at the Major Minor Major Minor mining site Health aspects Occupational Health and risk of Major Minor Major Minor accidents Health of employees at the mine Minor Negligible Minor Negligible Public health and quality of life Negligible No mitigation Negligible No mitigation required required Cultural and natural values Sites of monumental or cultural Major Negligible Negligible No mitigation importance required Access to natural areas Not significant No mitigation Not significant No mitigation required required Cumulative impacts

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Social Impact Assessment Citronen Base Metal Project

Issue Construction phase Operation phase Before mitigation After mitigation Before mitigation After mitigation Cumulative impacts Negligible No mitigation Negligible No mitigation required required

1.11 Proposed mitigations

For all negative impacts that are major or significant in nature, mitigation measures have been identified. For positive impacts measures to optimise the benefits are proposed.

The proposed mitigation measures are presented in the following table.

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Social Impact Assessment Citronen Base Metal Project

Overview of proposed measures (mitigation or enhancement)

Issue Proposed measures (mitigation or enhancement)

Economic Impacts 1 Employment a) Prepare a description of the requirements for the different work and job categories for the construction and operation phase. b) Assistance in understanding requirements of the future workplace, such as health and safety issues etc., in cooperation with the local authorities. c) Develop a plan for recruitment of local employees. This plan should be developed together with the municipalities (Labour Market Offices) and should be developed before concluding the IBA d) Ironbark to be physically present in Greenland including a Greenlandic speaking human resources person to support the development and implementation of recruitment plans. e) Develop a program to stimulate representation of local employees to be represented in all positions, including employment packages to make Citronen Fjord Project an attractive workplace for local workers. f) Undertake a gender sensitive workforce assessment, in order to ensure that both women and men will apply for the jobs during the operation phase. g) For retention of local workforce, the camp area should offer communication services in order for the local employees to have reliable communication with family. Communication services will be determined by what is technically possible in such a remote location. In addition, there should be Greenlandic food served at the camp. h) A travel allowance in Employment packages to provide assistance to travel from home to Kangerlussuaq and on to site. i) Consider transportation of staff via Iceland in order for potential workforce from the south east Greenland to be employed at the site as there are regular flights to Iceland from east Greenland and south Greenland. j) Clearly communicate a zero-tolerance towards alcohol and drugs for all potential employees. k) As education and training measures are key to ensure local employment this has been assessed separately in section 6.2 of this table l) On site education should be of international standards and if possible certified so that employees can use their skills on other mining projects. 2 Business life a) Procurement and contract packages for goods and services will be prepared and issued to the pre-qualified and approved bidders in Greenland as well as overseas. b) Outsourcing of activities related to transportation of goods and staff. Where possible and competitive, local businesses will provide these services. c) Servicing of the camp will be tendered. Such services include catering services, cleaning, laundry and similar tasks. Arrangements can be done by the catering company with local fishers and hunters for the provision of fish and meat for traditional food. Moreover, there will be a number of services provided for the mine when contracting

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Social Impact Assessment Citronen Base Metal Project

local tradesmen (carpenters, engineers, electricians etc.). Also, IT services could be requested during the operation and provided locally. d) Close dialogue with local transportation providers will be established to discuss local opportunities and challenges (Air Greenland, Royal Arctic Line). e) Close dialogue with local fuel providers (as Polaroil) will be established to discuss local opportunities and challenges. Special attention will be given to type of fuel and opportunities of transport of fuel to the location. f) Close dialogue with local communication service providers will be established to clarify if the need of Ironbark in connection with what Greenlandic telephone companies can provide. g) Close dialogue with KNAPK in order to organise provision of local food to the camp. h) Establishment of a forum with GA, Nusuka and the municipalities (business councils). This forum will be used before and during tending process to provide information and clarification of the tenders. Education and training 3 Skill upgrading a) Undertake an assessment of training needs in cooperation with local authorities in Greenland b) Develop a pre-employment and on-the-job training program for the required job categories during operation phase, in cooperation with local authorities, education institutions and construction contractor early in the detailed planning of the project. c) Discuss with educational institutions how to set-up training facilities for underground mining. d) Development of a dedicated training program for staff on specific duties, safety, etc. e) General training programs and on-the-job training for staff will be part of all employees’ work profile. f) Cooperation with other mining companies in terms of offering training and apprentices. g) Focus on continuously up-grading of employees at all levels. h) Offer apprenticeships within different fields of work. Public Service and Plans 4 Public services a) Develop a plan and an approach together with the Police covering aspects of customs and the role of the Police on site. b) Develop a Health and Safety Management Plan in close cooperation with the authorities, including procedure for use of external public health care services. c) Establish contact with local health service and work out cooperation between both parties. d) Pre-employment health screening and an annual check. The parameters to be included in the health check should be agreed with the health authorities. e) Establish contact with local health service and work out cooperation between both parties and other major local work places.

Social Aspects

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Social Impact Assessment Citronen Base Metal Project

5 Social conflicts a) Establish introductory sessions for all workers on intercultural understanding and provide an overview on Greenlandic culture for international workers as part of their introduction process. b) Set up a program for intercultural understanding, to be provided to all of the workforce and contractors. c) It should be ensured that the camp accommodates the cultural needs of the different nationalities living at the camp. 6 Potential criminality at a) Development of rules of behaviour and code of conduct/ethics, and include these in the introduction sessions for the mining site new employees. b) Ironbark should cooperate with the police of Greenland in the planning of the project. c) Having a zero-tolerance policy with regard to possession and use of alcohols, drugs and use of firearms. Health Aspects 7 Occupational Health a) Develop and implement health and safety management plan for staff in the mine site. and risk of accidents b) Establish health and safety committee with joint participation of workers that help to monitor and advice health and safety programs on mine site. c) Training of all staff on safety and emergency response on the mine site. d) Contractual requirements to providers of transportation services (Air Greenland, charter boats for staff, etc.) regarding safety measures, response time, etc. in order to minimise risk of accidents, appropriate and timely response in case of accidents, emergency evacuation from mine site, etc. e) Pre-notification of operations and traffic of vessels to authorities. f) Develop emergency and contingency plans in coordination with Greenland Contingency Committee and other major local workplaces. 8 Health of employees at a) Dust and noise controls on machinery eg water sprays, noise inhibitors. Provision of personal dust and noise the mine protective equipment eg ear plugs, dust masks. b) Health screening prior to employment to ensure that the workers do not have any Sexually Transmitted Disease (STD) or Tuberculosis (TB). Cultural and natural values 9 Sites of monumental or a) Contact the Greenlandic National Museum and Archive for them to further study and register the affected cultural importance archaeological features.

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Social Impact Assessment Citronen Base Metal Project

1.12 Public Participation

In 2014, the Greenland parliament, , amended the Mineral Resource Act, which meant that new rules concerning public consultation came into force in July 2014. This means that mining companies, which start the SIA process after July 2014 will have to submit a project description for drafting the SIA report. The Project description will be subject to a public review, which will last for at least 35 days – a so called “Pre-hearing” of the project. However, due to Ironbark commencing the SIA process before July 2014 the Citronen Base Metal Project has not been subject to the aforementioned “Pre-hearing” (see Section 5 and 9).

Based on the Guidelines from the BMP (2009) and local knowledge relevant stakeholders have been identified for the Citronen Zinc Project. Stakeholders were initially engaged in October 2010. Meetings between the stakeholders and Ironbark representatives were organised by Greenland Venture and held in person in Greenland and by phone. The objective of the stakeholder engagement was to identify parties with interests in the establishment of a mine at Citronen Fjord, and invite the stakeholders for their views on the mine. The four municipalities and KANUKOKA agreed that during the scoping phase there was no basis for holding public meetings because the mine is not located in a municipality.

The key issues raised during the stakeholder engagement in 2010 were possibilities for local employment, requests from stakeholders to be informed on the different kind of jobs and required qualifications, transportation opportunities, local business opportunities and a request for collaboration with education institutions.

Follow-up stakeholder engagement activities occurred between December 2013 and March 2014. The objectives of the stakeholder engagement activities were to update the stakeholders on the status of the project and to share the findings from the consultation with stakeholders in 2010. Additionally, the stakeholders were invited to propose initiatives which could increase the local involvement in the project (employment and business opportunities) in the light of the remote location of the project.

Before the phone interviews occurred, a detailed description of the project was distributed along with an invitation letter which clarified the objective of the interview and stated the questions to be answered during the call. The interviews were held either in Greenlandic or Danish (by preference of the stakeholders).

The key issues raised during the stakeholder engagement in 2014 were health issues, the requirement for a Greenlandic transportation hub, an increased share of local involvement in the construction phase, importance of providing Greenlandic food at the site, additional meetings with infrastructure authorities are needed, engagement with education institutions, more cooperation with the local stakeholders (municipalities, local representatives from GA, SIK etc), and a requirement for increased stakeholder engagement due to increased interest in activities.

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2 INTRODUCTION

This report is the Social Impact Assessment for the Citronen Fjord Project, which has been prepared by Grontmij A/S, an independent consulting group, on behalf of Ironbark Zinc Limited (Ironbark). The Project lies at the head of Citronen Fjord in Peary Land, North Greenland.

Ironbark, based in Western Australia, is planning to develop the Citronen Fjord Project. The Project includes the development, operation and ultimate reclamation of a zinc and lead mine (both underground mine and open pit).

When mining companies apply for an exploitation licence in Greenland, the Greenland Government requires an environmental and a social impact assessment. This Social Impact Assessment (SIA) is based on the Guidelines for Social Impact Assessments for mining projects in Greenland (BMP, 2009).

Ironbark has prepared an Environmental Impact Assessment (EIA) in parallel to this SIA.

2.1 Objective of the SIA

The overall objective of the SIA is to identify and analyse the potential socio-economic impacts of the proposed mining activity and to recommend initiatives, realise sustainable development opportunities as well as to mitigate any negative impacts. The SIA is based on engagement with relevant stakeholders and current Greenland social baseline information.

The main objectives of a SIA process for a mineral project in Greenland are (BMP, 2009):

 to engage all relevant stakeholders in consultations and public hearings;  to provide a detailed description and analysis of the social pre-project baseline situation as a basis for development, mitigation and future monitoring;  to provide an assessment based on collected baseline data to identify both positive and negative social impacts at both local and national level;  to optimize positive impacts and mitigate negative impacts from the mining activities throughout the project lifetime;  to develop a Benefit and Impact Plan (BIP) for implementation of the Impact Benefit Agreement (IBA).

2.2 Background

In 2010 Ironbark commenced the SIA process with assistance from Greenland Venture. The SIA process was placed on hold during 2011. In 2013 Ironbark commissioned Grontmij A/S to review, manage and finalise the SIA for the Project.

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Social Impact Assessment Citronen Base Metal Project

2.3 Study area and temporal boundaries

The study covers the area directly impacted by the mining operations and ancillary facilities including (port, airport, camp) where the impacts and benefits of employment, business opportunities and developments directly and indirectly created by the Project are expected to be more noticeable.

As the Project is located in a remote area outside the border of the four municipalities the area of influence for the SIA is Greenland as a whole.

For the baseline study the information has been processed and analysed at two levels: National and the municipal level. With regards to the municipal level, information has been processed and analysed at a general level for each of the four municipalities.

All four municipalities have been engaged on an equal basis.

The SIA will cover the following stages in the project:

 construction phase (two years)  operation phase (14 years)  closure (after 16 years).

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Social Impact Assessment Citronen Base Metal Project

3 POLICY, LEGAL AND ADMININISTRATIVE FRAMEWORK

3.1 General political situation in Greenland

Greenland has had home rule from Denmark since 1979. On June 21, 2009, a new constitution was introduced after the referendum for the Government of Greenland in November 2008, and country status then changed to “self-rule”. Greenlandic is now the only official language in Greenland. Under the Government of Greenland, Greenland will become a subject under international law in matters that are within its jurisdiction. Greenland can then enter into agreements and establish bilateral and multilateral relationships with other states.

Greenlandic citizens, being Danish nationals, will have exactly the same rights as any other person born in the Kingdom of Denmark (The Unity of the Realm). Two Greenlandic- elected representatives are elected to the Danish national parliament.

Greenland is member of the Nordic Council and Nordic Council of Ministries. This membership with other Nordic Countries and autonomous regions facilitates parliamentary cooperation among the members, particularly in relation to nature and environmental issues.

Greenland is also member of the Arctic Council since 1996. The Inuit Circumpolar Council, (ICC) is present in Greenland.

3.2 Legal Framework

This section lists and describes the regulations and guidelines relevant to the project, particularly for the issues and areas of interest for the Social Impact Assessment of the Citronen Fjord Project (Table 3.1, Table 3.2 & Table 3.4). Greenlandic law will be applied for all aspects of the project, including health and safety, environment, safety and criminal regulation.

3.2.1 Greenlandic legislation

The main legislation governing the Ironbark Project is the Act no. 7 of 7 December 2009 on Minerals and Resources (the Mineral Resources Act), which came into force on January 1, 2010 (including amendments No. 26 as of 18 December 2012 and No. 6 as of 10 June 2014).

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Social Impact Assessment Citronen Base Metal Project

Table 3.1 Main legislation for the Citronen Fjord Project

Title Summary & Relevance Year Greenland Parliament Act No. 7 This Greenland Parliamentary Act aims to ensure appropriate exploitation of mineral 2009 of 7 December 2009 on mineral resources, use of the subsoil, regulation of matters of importance to mineral resource and resources and mineral activities and subsoil activities. activities (the Mineral Resources Furthermore it aims at ensuring that activities under the Act are performed in a sound Act) with Amendments of Act No. manner as regards to safety, health, the environment, resource exploitation and social 26 as of 18 December 2012 and sustainability, and appropriately and according to acknowledged best international practices No. 6 as of 10 June 2014. under similar conditions. Act no. 7 was created on December 7, 2009 and came into force on January 1, 2010.

Act No. 1048 of 26 October 2005 The Act aims to ensure a safe and healthy working environment which shall at any time be 2005 on Occupational Health and in accordance with the technical and social development of the Greenland society, and the Safety (the Greenland Working basis on which the enterprises themselves will be able to solve questions relating to safety Environment) and amendment in and health under the guidance of the employers' and workers' organisations, and under the Act no. 1382 of 23 December. guidance and supervision of the Working Environment Authority. See also additional Orders listed below in section 2.2.2. Danish regulation No. 150 Foreign worker policy. Although foreign workers rules differ slightly between Denmark and 2001 “§9 (2) (3) of Decree No 150 of Greenland, they need to be issued work and residence permits in Greenland from the February 23, 2001 on request Danish immigration authorities. relating to the entry into force of A special procedure has been established for the rapid and flexible management of work the law on non-nationals into and residence permits for personnel involved in oil extraction or other jobs in the extractive Greenland” industries. Request for work and residence permits of this type are sent to the Greenland Home Rule Government for final decision.

Act No. 882 of 25 August 2008 on Rules the implementation under Greenland law of the International Convention on safety at 2008 Maritime Safety (Safety at Sea) Sea (SOLAS, 1974), the international convention for the prevention of pollution from ships, 1973 and the modified protocol (MARPOL), 1978. BL 5-24 - Operational regulations This BL lays down the operational regulations for all internal flights in Greenland, including 2008 for internal flights in Greenland all transit flights within Sondrestrom FIR, by Danish or foreign registered aircrafts. and for transit flights in Sondrestrom Flight Information Region (FIR) (Edition 2, 26 June 2008)

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Social Impact Assessment Citronen Base Metal Project

Aeronautical Information Additional regulation on airports in Greenland 2014 Publication (AIP) Greenland, latest edition (6 February 2014) Greenland Parliament Act No. 14 The act regulates the emergency management, where special attention should be given to of 26 May 2010 on emergency paragraph 13 which states that in case of an emergency situation this has to be coordinated services in Greenland and fire by the Policy in Greenland. and explosion prevention (Emergency Management Act) Act no. 306 of 30th April 2008, The act describes the criminal code for Greenland, including the sentences for criminal 2008 Criminal law offences. The Greenlandic judiciary system is regulated by Danish legislation and is administered by the Danish authorities.

Greenland Parliament Act No. 11 The Act serves to protect the ancient relics, finds, monuments and buildings. 2010 of 19 May 2010 on conservation and other heritage protection of cultural relics Order no. 7 of 17 June 1992 on The purpose of the order is to protect and conserve the natural state of the national park 1992 the National Park in North- and area, and at the same time ensure the opportunity for research and public access. To the East Greenland widest extend possible the landscape, vegetation, wildlife ancient monuments and similar And must be protected.

Order no. 16 of 5 October 1999 According to the order approval for feasibility studies, exploration, and exploitation of updating order. No. 7 of 17 June minerals in the National Park follows the regulation in Greenland Parliament Act no. 7 of 7 1992 December 2009 on Minerals and Resources

Greenland Parliament Act no 29 The Act serves to protect the nature of Greenland 2003 of 18 December 2003 on Nature protection Section 25 of Greenland The Act serves to protect the nature of National Park in North and East Greenland. 1999 Parliament act No. 16 of 5 October 1999 on National Park in North and East Greenland.

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Social Impact Assessment Citronen Base Metal Project

Act No. 12 of 2 November 2006 The Acts regulated the taxes in Greenland 2006, on income tax and amendments 2009, of act no 3 of 30 November 2009 2010 and Act no. 20 of 18 November 2010

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Social Impact Assessment Citronen Base Metal Project

3.2.2 Orders on Occupational Health and Safety relevant to the project

Table 3.2 Orders on Occupational Health and Safety relevant to the project

Orders on Occupational Health and Safety relevant to the project Year

Order no. 32 of 23 January 2006, Rest periods and off-time in Greenland 2006 Order no. 151 of 18 April 1972, Installation and use of mechanically operated 1972 cranes, hoists and similar Order no. 155 of 18 April 1972, Pressure contained on land 1972 Order no. 133 of 5 February 2010, Asbestos 2010 Order no. 363 of 6 April, Education on Occupational Health and Safety 2010 Order no. 395 of 24 June 1986, Order on the performance of work 1986 Order no. 396 of 24 June 1986, Work with substances and materials (chemicals) 1986 Order no. 398 of 24 June 1986, Technical equipment 1986 Order no. 399 of 24 June 1986, Arrangement of workplaces 1986 Order no. 401 of 24 June 1986, Reporting of work related injuries 1986 Order no. 1168 of October 2007, work place Assessment in Greenland 2007 Order no. 1344 of 15 December 2005, Order on the construction owner’s 2005 obligations and responsibility Order no. 1347 of 15 December 2005, Work for young people 2005 Order no. 1346 of 15 December 2005, Order on the Occupational Health and Safety Work in Greenland and amendment in 2005, 2010 Order no 364 of 6 April 2010 Order no. 1348 of 15 December 2005, Order on the arrangement of construction 2005 sites and similar work places in Greenland

3.2.3 Bill to amend the Act on Income Tax

On 9 December 2013, a Bill to amend the Act on Income Tax was sent out for public consultation. The Greenland Government tabled the final Bill in the Parliament during the spring session in 2014. The Bill contains initiatives to prepare the tax legislation for developments within the mineral resource sector in particular.

One of the key issues of interest will be on the full or partial tax exemption. The Bill proposes an alternative to the current exemption provision that when issuing an exploitation licence, the Government should be authorised to grant the licensee a right to deduct any royalty against the licensee's corporate tax.

The decision allowing the licensee to deduct the royalty against the tax must be made in connection with the grant of the exploitation licence. According to the Bill it will not be possible to grant such a deduction after the exploitation licence is issued.

Furthermore, the Bill also aims at simplifying the treatment of persons subject to the so called gross taxation scheme. The aim is to simplify the tax administration in relation to certain types of man power.

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3.2.4 Taxes and Revenues

This section describes the Greenland legal framework and regulations on taxes and revenues applicable to the project. The impact analysis regarding taxes and revenues to be generated by the project is based on the legal framework described in this section. The estimation and results of the Taxes and Revenues analysis in terms of benefits to Greenland are presented in Section 6.

The information presented in this Section is based on the Act on Minerals and Resources (Inatsisartut law no. 7, dated December 7, 2009) which came into force January 1, 2010, and the Tax Law including available information regarding the latest amendment to the income tax from November 9, 2010. The section is divided into concession fees and tax base and taxation.

3.2.5 Royalty

The Mineral Resource Act §17 states:

“The consideration to be paid by the licensee to the Greenland Self-Government is laid down in a licence under section 16 above. The licence may include a provision to the effect that an annual fee is payable, calculated on the basis of the size of the area covered by the licence (area fee). Terms may also be laid down on the payment of a fee calculated on the basis of the mineral resources extracted, etc. (royalty) or terms on payment to the Greenland Self-Government of a share of the profits from the activities under the licence (profits fee).”

The current exploration licence for Citronen Fjord Project (Ironbark) does not include royalty and thus any royalty has not been included in the SIA.

Tax on profits to be generated by the exploitation will however be applied by the Greenland Government.

3.2.6 Tax regulation

This section contains an account of the corporate taxation in Greenland related to mining activities, as well as an income tax estimate related to employees. The different types of taxes that will be relevant to a limited company domiciled in Greenland are listed below and are supplied by Deloitte and Naalakkersuisut March 2012:

3.2.6.1 Corporate Taxation

Capital contribution There is no capital contribution tax.

3.2.6.2 Dividend tax

Greenlandic companies are to withhold a dividend tax corresponding to the personal tax in the municipality of registration. For companies with permits under the Mineral Resources Act, the present dividend tax rate is 37 percent.

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3.2.6.3 Tax losses

Companies with exploration or exploitation/mining permits under the Mineral Resources Act are entitled to carry forward tax losses without timing limitations.

3.2.6.4 Corporate tax

In general the corporate tax is levied at a flat rate of 31.8 percent and the rate applies to a resident company as well as a registered branch office of a foreign company. The taxable income is determined on the basis of the profit shown in the statutory annual report, adjusted to comply with the prevailing tax provisions. Corporate tax for companies with a licence under the Mineral Act is 30 percent.

Tax depreciation and amortization can be allocated as follows:

 Buildings and related installations are depreciable in a straight line by a maximum 5 percent per year  Aircraft and vessels by maximum 10 percent per year  All other items like machinery, equipment etc. by max 30 percent  All assets costing less than DKK 100,000 are depreciable / amortizable in the year of acquisition.

Companies with exploitation/mining permits under the Mineral Resources Act may, when computing their taxable income, deduct immediately the cost of the accounting provision for closure.

3.2.6.5 Licence amortization

An amendment to the income tax law passed by the Parliament of Greenland in November 2010, and effective from January 1, 2011 changed the amortization of licences. For mineral licences the amortization is now “pegged” and fixed at the same amount over a period of four years.

3.2.6.6 Transfer prices

The tax law now includes specific provisions on documentation of trade between related companies. Agreements between related companies/parties must be documented, including written documentation as to how prices and term are determined for the intercompany transactions.

3.2.6.7 Thin capitalisation rules

The tax rules include specific rules on thin capitalisation. Basically it is important to note that lending between related companies/parties is to observe the arm’s length principle.

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3.2.6.8 Personnel taxation

The amendment to the income Tax Law in November 2010 introduced a 35 percent flat rate tax for foreigners working in the mineral resource industry outside towns and settlements on salary originating from their income in Greenland. Only individuals who have not been liable to tax in a Greenland municipality during the previous six months will be covered by the flat tax scheme.

There are tax agreements between Greenland, Denmark, Iceland, Norway and the . Otherwise the income tax system is structured according to the Danish model with taxation at source.

The income tax rate for 2014 is illustrated in Table 3.3. Personal allowance (tax-free threshold) for 2014 is DKK 58,000.

Table 3.3 Overview of income tax rates for the different municipalities Source: Greenland Tax Authority.

Qaasuitsup Kommunia 44% Qeqqata Kommunia 42% Kommuneqarfik Sermersooq 42% Kommune Kujalleq 44%

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3.2.7 National guidelines relevant to the project

Table 3.4 Greenlandic National Guidelines

Title Summary & Relevance Year Guidelines for Social Impact Assessments Guidelines prepared to assist mining companies and their consultants in Nov 2009 for mining projects in Greenland preparing Social Impact Assessments (SIA), describe the role of the BMP, the SIA process and content of the SIA document. BMP Guidelines for preparing an Guidelines for EIA that apply to mining companies. The report must cover the Jan 2011 Environmental Impact Assessment (EIA) entire exploitation period from mine development prior to mine start until Report for Mineral Exploitation in closure and subsequent monitoring period. The guidelines include Greenland requirements on baseline and project specific environmental studies 2-3 years in advance of EIA report preparation. Rules for field work and reporting The rules apply to licensees' field activities regarding mineral resources 2000 regarding mineral resources (excluding (excluding hydrocarbons) hydrocarbons) in Greenland and to reporting to the Greenland Home Rule in Greenland Government's Bureau of Minerals and Petroleum (BMP) on the activities and their results. The Danish Maritime Authority’s guidelines The guidelines ensure that the concession holder – prior to starting the 2010 of 2010 on investigation of navigational exploitation activities – must have carried out a navigational safety safety issues investigation of the conditions in the operational phase in connection with calls at ports, facilities, anchorages, etc. in the concession area. The purpose of the investigation is to illustrate that navigation can be carried out in a safe manner. Standard Terms for prospecting Licences Serves under the Mineral Resources Law. Guidelines from BMP describing 2010 for Minerals (excluding hydrocarbons) in application for prospecting licences, rights and rules for prospecting of Greenland minerals in Greenland. Standard Terms for Exploration Licences Serves under the Mineral Resources Law. Guidelines from BMP describing 2010 for Minerals (excluding hydrocarbons) in application for exploration licences, rights and rules for exploration of Greenland minerals in Greenland.

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3.3 International Unions and Conventions

The following unions and conventions presented in Table 3.5 are relevant to Greenland.

Table 3.5 Relevant International Unions and Conventions

Title Summary & Relevance Year UN Declaration on The UN Declaration on indigenous peoples rights sets 2006 indigenous peoples rights out the individual and collective rights of indigenous peoples, as well as their rights to culture, identity, language, employment, health, education and other issues. The declaration also "emphasizes the rights of indigenous peoples to maintain and strengthen their own institutions, cultures and traditions, and to pursue their development in keeping with their own needs and aspirations". UN convention against The United Nations Convention against Corruption 2005 corruption (UNCAC) is a multilateral convention and the first global legally binding international anti-corruption instrument. UNCAC requires that States Parties implement several anti-corruption measures which may affect their laws, institutions and practices. These measures aim at preventing corruption, including domestic and foreign bribery, embezzlement, trading in influence and money laundering. Extractive Industries The Extractive Industries Transparency Initiative 2002 Transparency Initiative (EITI) is a global Standard to promote open and (EITI) accountable management of natural resources. Countries implementing the EITI disclose information on tax payments, licences, contracts, production and other key elements around resource extraction.

Greenland has officially stated that it supports the EITI principles, but Greenland / Denmark are not yet candidate countries to EITI. ILO declaration on the Declaration commits Member States to respect 1998 fundamental principles and and promote principles and rights in four categories, Rights at Work whether or not they have ratified the relevant Conventions.

These categories are: freedom of association and the effective recognition of the right to collective bargaining, the elimination of forced or compulsory labour, the abolition of child labour and the elimination of discrimination in respect of employment and occupation. United Nations Framework The convention aims at protecting, preventing and 1997 Convention on Climate reducing global warming by reducing the emissions of Change greenhouse gases. The convention enforces the Kyoto Protocol which came into force in 2005. The Kyoto Protocol is a legally binding agreement to reduce greenhouse gas emissions. Convention on Biological The Convention on Biological Diversity has 3 main 1993 diversity objectives: The conservation of biological diversity,

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The sustainable use of the components of biological diversity, and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources. OSPAR convention (The OSPAR is the mechanism by which 15 Governments 1992 Convention for the & the EU cooperate to protect the marine environment Protection of the Marine of the North-East Atlantic. Overall, the work of the Environment of the North- OSPAR Commission is guided by the ecosystem East Atlantic approach to an integrated management of human activities in the marine environment.

The Convention has been signed and ratified by Denmark ILO convention 169 - The ILO convention 169 is a binding international 1991 Indigenous and Tribal convention concerning indigenous peoples. It Peoples Convention recognises and respects the cultures and ways of life of indigenous peoples, rights to land and natural resources, and rights to determine priorities for development. it does not simply state rights, but goes beyond by providing technical guidance on how to implement those rights, and which measures, precautions, or safeguards to take in order to ensure full enjoyment of those rights.

Ratified by Denmark (including Greenland and Faroe islands) on 22 February 1996 OECD guidelines for The OECD Guide for Multinational Enterprises are the 1976 multinational enterprises most comprehensive set of government-backed recommendations on responsible business conduct in existence today. The governments adhering to the Guidelines aim to encourage and maximise the positive impact MNEs can make to sustainable development and enduring social progress. UN convention on civil and The International Covenant on Civil and Political 1976 political rights Rights (ICCPR) is a multilateral treaty that commits its parties to respect the civil and political rights of individuals, including the right to life, freedom of religion, freedom of speech, freedom of assembly, electoral rights and rights to due process and a fair trial International Covenant on It commits its parties to work toward the granting of 1976 Economic, Social and economic, social, and cultural rights (ESCR) to the Cultural Rights Non-Self-Governing and Trust Territories and individuals, including labour rights and the right to health, the right to education, and the right to an adequate standard of living. Convention for the Aims to conserve and protect cultural heritages from 1972 Protection of the World destruction by traditional decay and by changing Cultural and National social and economic conditions. Because Heritage (UNESCO / World deterioration or disappearance of any item of cultural Heritage Convention) or natural heritage constitutes a harmful

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impoverishment of the heritage of all the nations of the world. Ramsar convention The Ramsar is an intergovernmental treaty that 1971 provides the framework for national action and international cooperation for the conservation and wise use of wetlands and their resources.

Denmark signed the treaty in 1978 and two Ramsar sites are placed in the Greenland National Park – Kilen and Hochstetter Forland. International Convention on The Convention on the Elimination of All Forms of 1965 the Elimination of All Forms Racial Discrimination 1966 (CERD) was one of the of Racial Discrimination first human rights treaties to be adopted by the United Nations. European Convention on The Convention for the Protection of Human Rights 1953 Human Rights and Fundamental Freedoms, better known as the European Convention on Human Rights, was the first instrument to give effect to certain of the rights stated in the Universal Declaration of Human Rights and make them binding.

Implemented in Danish legislation in Act no 285 of 29 April 1992 International Union for the IUCN helps the world find pragmatic solutions to the 1948 Conservation of Nature most pressing environment and development (IUCN) challenges ILO convention 87 and 98 The ILO convention 87 ensures the Freedom of 1948 Association and Protection of the Right to Organize / 51 and the ILO convention 98 concerns the the Right to Organise and to Bargain Collectively

3.3.1 International Labour Organisation Conventions

Some of the International Labour Organisations Conventions have been incorporated in the Greenlandic legislation for working conditions.

3.4 National and International Guidelines on Social Impact Assessment

The Social Impact Assessment is based on the Guidelines for Social Impact Assessments for mining projects in Greenland, November 2009, prepared by the Bureau of Minerals and Petroleum, now known as the MLSA. The Social Impact Assessment is a matter for the Ministry of Industry, Labour and Trade (MILT). Furthermore, the guidelines from IFC and Mackenzie Valley (USA) have been used:

 International Finance Corporation (IFC), Addressing the Social Dimension of Private Projects – Good practice Note, 2003  International Council on Minerals and Metals framework and guidance notes.  Community Development Toolkit, produced by World Bank, International Council on Minerals and Metals, and the Energy Sector Management Assistance Program

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 Mackenzie Valley, Socio-Economic Impact Assessment Guidelines, Mackenzie Valley Environmental Impact Review Board, 2007.

3.5 National Strategies

This section presents some of the recent strategies developed by the Self-Government which is of relevance to the Project.

3.5.1 The Oil and Mineral Strategy for Greenland 2014 – 2018

On 8 February the Self Government published its strategy for Oil and Minerals for 2014 – 2018. The strategy contains a number of new initiatives in the following areas: oil/gas, minerals, taxation, geosurvey and sustainable development. Below is a summary of the strategy with focus on the areas of interest for the Project.

3.5.1.1 Minerals

The mineral components of the strategy which will be in focus are: iron, copper and zinc; rare earth minerals; gold and gemstones. It is emphasized in the strategy that Greenland Government will analyse the metals' distribution, potential for new reserves and size especially regarding the zinc potential in North Greenland.

3.5.1.2 Taxation model for raw materials

The Self-Government recommends a taxation model for all metals and minerals other than uranium, rare earth and gemstones, with a royalty of 2.5 percent, where corporate tax/ dividend tax are deducted from the calculated royalty.

3.5.1.3 GeoSurvey Greenland

The Self-Government will set-up a GeoSurvey (hereinafter called GSG) in Nuuk for mineral exploration and mine development. After the election in November 2014 it was announced that this will not be launched in the near future.

3.5.1.4 Sustainable development

The Government recommends that the mining sector will be developed in a sustainable manner. Areas to be covered are infrastructure, labour and employment, education, environment and health sectors.

3.5.1.5 Environmental protection

The Environment Agency for Mineral Resources Activities (EAMRA) is responsible for environmental protection in the area of mineral resources activities. The EAMRA works closely with the Danish Centre for Environment and Energy (DCE) under the Aarhus University and the Greenland Institute of Natural Resources (GINR) to provide scientific advice concerning environmental protection in the area of mineral resources activities.

The strategy will focus on developing rules applying to environmental protection and differentiating between the environment authority and licensing authority.

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3.5.1.6 Does the infrastructural framework fit the needs of the mining industry?

Within the infrastructural framework, there are a number of challenges which need to be addressed. These challenges are:

 Financing of infrastructural facilities  Energy supply to the locations where mining companies will operate  Air transport to and from the mining projects  Demand to existing ports  Majority of all goods in Greenland transported by ship  Need for telecommunications at mining projects.

3.5.1.7 Labour and Employment

The current situation of high unemployment must be tackled with initiatives on development of competences to be targeted in the mining sector. It is expected that there will be a need for unskilled and skilled workers who have undergone targeted mining courses. There is also a need for upgrading of skills of workers in safety, which is part of the international requirements to work in the mining sector.

3.5.1.8 Education

The Self-Government recommends that the educational and training initiatives must be directed to the minerals sector and supporting industries, not least education in the building and construction sector. There is also a need for more apprenticeships and closer co-operation between the municipal labour offices.

3.5.1.9 Health and social care

The health care system is not established to meet the needs of mining activity. Therefore, there is a task to ensure that the health care system during the strategy period will be able to handle the challenge. In addition there is also a need for clarification of the economic challenges that the integration of a new industry in the existing structures will provide.

3.5.1.10 Citizens, communities and stakeholders

In 2014, the Greenland parliament, Inatsisartut, amended the Mineral Resource Act, which meant that new rules concerning public consultation came into force in July 2014. This means that mining companies, which start the SIA process after July 2014 will have to submit a project description for drafting the SIA report. The Project description will be subject to a public review, which will last for at least 35 days – a so called “Pre-hearing” of the project. However, due to Ironbark commenced the SIA process before July 2014 the Citronen Base Metal Project has not been subject to the aforementioned “Pre-hearing” (see Section 5 and 9).

This means, among other things, that citizens and stakeholders will be involved earlier in the process, and that there should be a formal consultation period of eight weeks.

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3.5.2 The Employment Strategy 2015 – 2017

An Employment strategy has been prepared by the Ministry of Industry, Labour and Trade. This Strategy contains the following ten initiatives.

1. Establishment of a national public job portal 2. Government pool to be increased and adjusted to support mobility of workforce 3. Efficient administration of international workforce 4. Resources on the Labour Market offices 5. Assessment of competencies for un-skilled workers 6. Young people under 29 years in education 7. Special initiatives for so-called Match group 3 8. Increased use of rehabilitation initiatives (Match Group 2) 9. Senior initiatives 10. Courses to qualify un-skilled workers.

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4 PROJECT DESCRIPTION

Ironbark’s Citronen Zinc Project (the Project), includes the development, operation and ultimate reclamation of a zinc and lead mine at Citronen Fjord in North Greenland. The Project will comprise mining three deposits (both underground and open pit) with an on- site processing facility to produce globally saleable mineral concentrates of zinc and lead. The concentrates will be shipped off-site to Iceland or another northern European port and subsequently to a third party smelter complex. The anticipated mine life is currently at least 14 years. There is no existing infrastructure at the site and consequently all infrastructure and ancillary facilities need to be developed as part of the project.

A construction contractor will be used to provide construction services, equipment and personnel.

4.1 General area description

Citronen Fjord is situated in Peary Land, North Greenland. Citronen Fjord is a small branch of the Frederick E. Hyde Fjord (83°05’N, 28°16’W). The nearest settlement is Qaanaaq, in north-west Greenland almost 1,000km away. The Station Nord military base has a gravel airstrip and is located 240km south-east of Citronen Fjord.

The Project lies at the head of Citronen Fjord on the eastern shore, in the junction of two glacial valleys through which the Esrum and Eastern Rivers run, and is surrounded by mountains up to 1,000m high.

The area is in the High Arctic Region with long, cold winters and short, cool summers with permafrost. Mean daily temperatures above freezing occur from June until September. Precipitation is very low (in the order of 200mm per year) and mainly falls as snow. Frederick E. Hyde and Citronen Fjords are iced over for much of the year.

The low temperatures during the short summer season combined with very low precipitation results in a sparse and discontinuous vegetative cover. The number of animals is also very low. For further details on flora and fauna refer to Section 5.8 of the Environmental Impact Assessment.

Lake Platinova is the only lake in the immediate vicinity of the Project. The Eastern River runs through the Project area before entering Citronen Fjord. The Esrum River lies just west of the Project.

4.2 Mining and ore processing

The proposed mining operation will occur at a rate of 3.3 million tonnes per annum at three deposits: initially two below surface and later an open pit. As per the schedules, the project has two years of construction and an overall mine life in the order of 14 years.

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The mined ore will be delivered by trucks to the processing plant. The ore will first pass through a two stage crushing process followed by Dense Media Separation (DMS), which acts as a pre-concentration step. The ore continues onward through a milling process before entering the flotation section of the plant, where the valuable zinc and lead concentrates are separated from the gangue (worthless) material. The flotation gangue is initially disposed of at the tailings storage facility (TSF), and later in the underground voids left by mining as backfill. After flotation the froth is cleaned and the concentrate dewatered through pressure filters to produce a concentrate cake. The concentrate will be stored within a large concentrate dome before being shipped off site (Figure 4-1).

Figure 4-1 Basic Process Flow Diagram 4.3 Tailings waste

A 3.6 million cubic metre tailings storage facility will be constructed to contain the processing waste. The tailings storage facility will be operational for the life of the mine, but primarily used for disposal of tailings in the first year. As deposition and freezing takes place, the excess water from the tailings will be pumped from the mine back to the plant. Once sufficient space is available, tailings will be disposed within the underground mine and will naturally freeze due to the permafrost conditions.

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4.4 Waste rock

Mining waste rock from Citronen will be deposited at the Waste Rock Dump and DMS Rejects Dump. The waste rock will be used throughout operations as a construction material where required.

4.5 Port facility

The marine facilities will be located in the south-eastern corner of Citronen Fjord, behind the small cape where adequate land areas for container and winter storage yards are available.

The shipping window for access to the Citronen Fjord is approximately mid-July to mid- September each year. During this period, loading of concentrate and unloading of supplies will take place on a 24 hour per day basis.

The proposed port facilities are of a simple design to enable them to be established swiftly with a reduced amount of site work.

The port facilities will comprise:

 pier head  two berthing/mooring dolphins  longitudinal moorings  access dike  land areas.

4.6 Shipping

Due to the remote nature of Citronen Fjord, which is accessible only via air or sea, the saleable end product (concentrate) and required volumes of supplies, consumables, and heavy items will be shipped to and from Citronen.

Shipping will occur July through to September, subject to prevailing conditions. As the ice cover varies from year to year there is no specific shipping route from the open waters of the Greenland Sea to Citronen Fjord. The sailing route will depend on the lead in the ice developing in the shear zone between the shore fast ice and the drift ice. Consequently the final sailing route cannot be determined until closer to each shipping period and will have to be adjusted for each trip. Figure 4-2 and Figure 4-3 show the approximate shipping route to Citronen Fjord.

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Figure 4-2 Shipping route Iceland to Greenland (MTHojgaard, June 2014). Green line – ice covered water, Red line - open water.

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Figure 4-3 Approximate shipping route north coast Greenland.

Due to the short time with which shipping can occur, it is expected that approximately three trips of two ice class ships in convoy will be completed each year. Shipping and the route is outlined in greater detail within the Navigational Safety Investigation report (MTHojgaard June 2014).

Currently bulk shipping in ice class vessels is not an area of expertise in Greenland, therefore impacts from a social perspective are anticipated to be minimal.

The annual amount of the cargo to and from Citronen Fjord during operation of the mine is planned as:

 approximately 360,000 t of concentrate out of Citronen Fjord on average  approximately 75,000 m3 arctic diesel fuel to Citronen Fjord  approximately 1,000 to 1,100 TEUs of supply to Citronen Fjord including spares and consumables. 4.7 Site access

Access to Citronen is currently achieved via airplane from Oslo to Longyearbyen on Svalbard, then by charter from Svalbard to Citronen stopping at Station Nord for refuelling. Ocean access is only possible during the summer months via Frederick E. Hyde Fjord.

There is an existing airstrip at the Project. The airstrip will be used for transportation of staff to and from site and for supplies that are required to be flown in (e.g. fresh groceries and spare parts required at short notice). The airstrip will be progressively upgraded during the early years of the project.

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During the project operations phase air traffic is expected to be for personnel (50 people in and out) as well as supply of fresh groceries. This can be maintained by two aircraft flights per week on average plus one cargo aircraft for delivery of spares and replacement parts when needed.

The airport facilities will be constructed in two stages. Aircraft which could potentially use the airstrip during each stage include:

 Stage one: DHC-6 Twin Otter, DHC-7 and Hercules C-130H  Stage two: Hercules C-130H and Fokker 50 In Stage one, a temporary airstrip will include lighting and navigation systems to enable operation on a 24 hour basis. It will have a 900m runway for the operation of passenger/freight aircraft similar in size to the Twin Otter or DHC-7.

In Stage two, the temporary facilities will be upgraded to a permanent airstrip with a 1,500 metre runway to handle larger aircraft such as a Fokker 50.

An alternative route to Citronen Fjord is by airplane from Akureyri, Iceland to Citronen directly or via Station Nord to Citronen. This route is approximately 2,030km. The airport in Akureyri has a runway 1,900 m long. The runway at Station Nord is 1740m and it is able to handle bigger aircraft such as Hercules C130 and Fokker 50.

4.8 Supporting Infrastructure

4.8.1 Power and Fuel

The required power consumption of approximately 23 MW will be met by a total of six generator units, with four in operation and two on stand-by duty/ maintenance. Other large installations will be the fuel storage area for power and equipment/vehicles.

The fuel storage area consists of:

 two tanks each for arctic diesel  two tanks each for jet fuel  hose station and lines  pipelines for both arctic diesel and jet fuel  fuel station for arctic diesel. Fresh water will be sourced directly from Lake Platinova.

The use of hydropower for the project was an alternative source of power considered by Ironbark. A site study was conducted at the Project in July 2010 to investigate this option (MTH and Landsvirkjun 2010). Four potential sites were visited. Three sites were deemed not suitable due to the glacial ice dams within the reservoir area and a potential risk of large glacial floods. The fourth site only has a 1.5MW power potential which is not large enough to make it economically feasible for the mining project.

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4.8.2 Administration and mine buildings

The buildings will be constructed from pre-fabricated modules. They will be elevated from the ground, integrated with the main warehouse and will be part of the walkway system between the camp and the process plant.

4.8.3 Accommodation

The camp is designed to accommodate approximately 290 people based on an 8+1 concept and comprises eight accommodation blocks spread around a central reception block. This layout was selected to enable camp residents to access central facilities through small connection corridors without having to go outdoors.

All buildings, ancillary facilities and electrics will be designed and constructed according to the Greenlandic Building Regulations, adhering to requirements including those for heating insulation and fire safety. The camp will be divided into several fire sections to mitigate the risk of fire spreading.

It is planned to erect the camp as early as possible so that it can be utilised for the construction workers and subsequently refurbished for use by operations personnel.

The buildings will be delivered as fully fitted-out prefabricated modules equipped with on- site works being foundations, connection of services reticulation systems, fitting-up and furnishing. The foundations will comprise of prefabricated components and will consist of steel frames fixed to buried concrete slabs. The buildings will be placed with the floor level raised one metre above the ground to preserve the permafrost.

4.8.4 Heating, ventilation and air conditioning system

Due to the on-site climate conditions, it is necessary to provide heating to the plant site buildings to enable regular maintenance and operations to be carried out. The heating, ventilation and air conditioning (HVAC) system will utilise waste heat recovered from the power plant.

4.8.5 Domestic and industrial waste management

Domestic and industrial waste (combustible) will be disposed of through the use of an incinerator. The incinerator will be capable of dealing with combustible waste, lubricants, fuel and oil and will be installed in the main warehouse. The incinerator plant will be installed as an early priority at the beginning of the construction phase and will have sufficient capacity to handle combustible waste generated during the construction period. It will continue during the operation phase. Incinerator ash will be disposed of to a site landfill. All non-combustible waste will be either buried within the site landfill or removed from site according to the Environmental Management Plan. The incinerator cannot be used for burning larger metal parts, batteries or chemical waste. These types of waste will be collected and stored for later disposal off site.

Sewage and waste water from buildings at the plant site will be sent to the sewage treatment plant (on-site). Effluent from the camp site will be carried to the sewage treatment plant through pipelines running below the arctic corridors to the main warehouse. Effluent from waste water will go into the process plant.

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4.8.6 Health and safety management

Health and safety will be managed by the Health and Safety Management System in accordance with international standards and recognised best practice. Health and safety personnel will be employed on site.

4.8.7 Emergency Preparedness

Ironbark will develop Emergency Preparedness Plans as part of its Health and Safety Management System. The plans will use a risk analysis approach and incorporate procedures and guidelines to be followed. The basic premise is that emergencies, whilst not expected, will be planned for.

4.8.8 Personnel

During the two years of construction, the expected use of manpower will be equal to approximately 300 full time employees (local and foreign). Once construction is complete and operations have commenced, this number will increase to approximately 470 per year with 290 people on site at any one time.

Personnel will work on a fly-in/ fly-out rotation of three weeks on/three weeks off or six weeks on/three weeks off depending on the job level and position. One working shift is 12 hours (11 working hours) and one working week is six days.

Working on a mine site and a processing plant requires certain skills and education that are currently not fully available in Greenland. It is anticipated that initially 80 percent of the workforce will consist of foreign employees. However once construction is finished and as the project progresses (training and education programs are completed), Ironbark aims to increase the local percentage of employment to 50 percent by year three and 90 percent by year seven.

4.9 Construction

A construction contractor will be the primary supplier of equipment required for the construction of the processing plant, which will take approximately two years. The majority of the project facilities will be constructed utilising contract construction companies supplemented with specialists where required.

The construction work will consist of two phases. During the first phase the construction camp, fuel storage facility and communications will need to be established prior to mobilisation of the initial construction workers. Construction equipment and materials will be brought to site during the first shipping window. The port area will be completed.

The second phase comprises the remaining construction works. This includes the construction of the haul roads and access roads building of the processing plant, and construction of the tailings storage facility and pipeline.

4.10 Description of the planned transportation routes (goods and staff)

The planned transportation route for local employees will be from Kangerlussuaq directly to the Project. This flight will be paid for and organised by Ironbark. Ironbark will also provide a travel allowance that will notionally cover the cost of flights from the capitals cities of each municipality to Kangerlussuaq.

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Employment package agreements (Employment terms and conditions, salary) will include this travel allowance (on top of their agreed salary).

Employees living outside Kangerlussuaq or a municipal capital city will be required to organise and pay for their own transport to these cities.

Flights from Akureyri to Citronen may also be possible should the number of employees be economic. Employees could fly to Akureyri from the east coast of Greenland (using existing flights) to transfer to the Citronen flight.

Foreign employees will fly to site via Longyearbyen in Svalbard.

The differences in the cost between getting local and foreign employees to site will be considered in the employment packages and travel allowances (eg local employees would receive more if the costs of getting to site are more expensive than a foreign employee).

Framework related to employment package agreements, including travel allowances will be determined in the IBA.

Transport of equipment and materials will primarily be on ships originating from Akureyri or from a designated northern European (for example Narvik, Norway) port depending on which method of shipping is decided. Some materials and equipment may be transported via aircraft from Nuuk.

4.11 Secondary processing evaluation

It is a requirement under the Mining Act that the potential for downstream processing is evaluated prior to an exploitation licence being granted.

This section examines the potential for treating the concentrate on site to produce zinc and lead metal, rather than the sale of separate zinc and lead concentrates as per the current mine design.

It should be recognised that concentrate sales from mine site to third party smelters is standard practice within the zinc industry, as smelting facilities tend to be located in areas with existing substantial infrastructure services, including low cost and stable power, acid availability and access to multiple sources of concentrate. There is currently a surplus zinc smelting capacity globally, see Figure 4-4, therefore it is unlikely that any new smelting facilities will be constructed in the near future.

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Figure 4-4 Smelter Capacity. (Source: CRU Zinc Outlook October 2013) The pricing mechanism for the sale of zinc and lead concentrate is also discussed, as the terms under which lead and zinc concentrate are sold according to accepted worldwide practices, where each party is independent of each other and on an equal footing, that are negotiated annually by the world’s leading base metal miners and smelters.

4.11.1 Zinc market and concentrate sale terms

Zinc and lead concentrate are the final product produced from most zinc and lead mines. The concentrates are globally traded and sold on global markets according to annually negotiated benchmark pricing between smelters and miners, as well as on the spot metal markets. The most accepted pricing mechanism is the London Metals Exchange (LME) which sets live prices on its global platform.

Most mines are funded using the concentrate production offtake agreements. Ironbark has committed 70 percent of the lead and zinc offtake to Nystar and Glencore, major international smelter operators and metal traders, on commercial terms under the offtake agreements.

4.11.2 Secondary processing on site

Bateman Engineering Pty Ltd was commissioned by Ironbark to produce a report which examines the traditional zinc smelting technologies, and provides operating and capital costs for each of these options to allow the evaluation of downstream processing to be undertaken.

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Please refer to the entire report for assumptions, exclusions and accuracy of the estimates. The report can be found in the reference section of this document /and is made available from the Ironbark website. Alternatively a copy may be obtained by contacting Ironbark Zinc Limited.

It should be noted that this report was prepared based on the early projected process rate feasibility study prior to the resources and mining upgrade, and optimisation of the process plant. These changes result in more concentrate being produced and would increase the capital costs, power requirements and acid consumptions above the figures shown here, but would not materially change the conclusions.

Each of these processes treats lead by different means, but in each case an intermediary product will be produced which would require additional treatment which has not been included in the analysis.

4.11.3 Selection of Processes

The study evaluated all possible refining technologies available to convert Citronen concentrate and determined that four processes were suitable for further analysis. These processes are:

 Imperial smelting process (ISP)  Roast leach electrowinning  Pressure leaching based on a two stage counter current leach  Atmospheric leaching based on Outotec Direct leaching technology. 4.11.3.1 Imperial smelting process

Currently about 8 -10 percent of the world's primary zinc is produced with ISP technology. The process co-produces lead bullion in addition to zinc metal using a mix of lead and zinc concentrates or complex lead-zinc concentrates as raw material.

The ISP is an energy-intensive process and thus became very expensive following the rise of energy prices in recent years. This and the lower production of bulk concentrates containing significant amounts of lead resulted in to abandoning of the ISP. Today, Imperial Smelting Furnaces (ISF) are only in operation in China, India, Japan and Poland at nine operations.

ISP starts with sintering, where bulk concentrates (a mixture of lead and zinc concentrates) are blended with oxidic secondaries and fluxes. The mixture is passed through the sinter plant to remove sulphur. Gas generated from the sintering process is cleaned before sulphuric acid production.

4.11.3.2 Roast leach electrowin process

The electrolytic zinc smelting process uses a mix of zinc-containing concentrates or secondary zinc material such as zinc oxides or scrap as feed to the roasting plant. Most zinc smelters use several sources of concentrates. These different materials are blended to obtain an optimal mix of feedstock for the roasting process.

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Approximately 90 percent of zinc in concentrates is oxidized to zinc oxide. At roasting temperatures of around 950°C approximately 10 percent of the zinc reacts with iron impurities within the zinc concentrates to form zinc ferrite or spinel (depending on the iron concentration in the feed).

The by-product of roasting sulphur dioxide, is captured and further processed into sulphuric acid of between 92 and 98 percent strength through the double contact and adsorption process and sold as a by-product.

Zinc metal is extracted from the purified solution by means of electrolysis. An electric current is passed through the solution and the zinc is deposited on aluminium cathodes.

The dissolved iron is removed from the zinc sulphate solution as goethite, jarosite or hematite which is usually stored in ponds.

Ever increasing environmental pressure is moving technology towards the production of an inert residue.

The electrolysis phase uses ~ 3200 kWh/tonne zinc produced and the electrical energy contributes ~ 80 percent of the overall energy-cost in the smelting process. Typically about one third of total plant cash costs are for electricity. Hence, cell house productivity (and electrical current and energy efficiency in particular) is a crucial driver in overall plant efficiency.

4.11.3.3 Pressure leaching (Sherritt zinc pressure leach process)

Today there are five zinc refineries using the pressure leaching approach. The pressure leaching process was primarily developed to address the environmental problems associated with roasting of sulphide ore and the disposal of sulphuric acid. Generally the pressure leaching plants have a somewhat lower capital cost than conventional roast/leach plants, higher extraction efficiencies, produce a more acceptable residue as well as elemental sulphur which may have a potential commercial value.

Zinc concentrate or bulk concentrate are leached in spent electrolyte under oxygen pressure to produce a zinc sulphate solution. Surface active agents, such as calcium ligno-sulphonate and quebracho, are added to inhibit coating of the un-reacted zinc sulphide particles formed during discharge and cooling of the slurry.

Slurry is discharged from the autoclave under controlled conditions, to produce a residue. The oxidic flotation tailings are either treated directly in a lead smelter or further upgraded to a product which can be treated in a lead smelter. The sulphidic concentrate is washed to remove salts, melted and filtered under pressure to recover an elemental sulphur by-product. The filter cake, containing un-reacted sulphides and entrained elemental sulphur, may be impounded or treated further for recovery of the contained metals, including precious metals, and sulphur.

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4.11.3.4 Direct leaching – atmospheric leaching

Zinc concentrate or bulk concentrate are leached in the presence of ferric sulphate at atmospheric pressure to produce a zinc sulphate solution. The concentrate may be reground to improve both the rate of reaction and the overall zinc extraction. As the leaching temperatures are under the melting point of sulphur there is no need for the use of surface active agents, such as ligno-sulphonates as required in the pressure leaching process.

Zinc concentrate is fed into various stages compiling of low acid leaching and hot acid leaching. Leaching is typically conducted at 90°C.

A key benefit of the direct leaching processes is that the production of sulphur dioxide and other harmful gaseous compounds is reduced, especially in comparison to the conventional pyrometallurgical methods. On the other hand, elemental sulphur, which requires a special storage area, is formed.

4.11.4 Process comparison

Table 4.1 Input and output comparison of secondary processing alternatives Units Imperial Roast Pressure Direct smelting leach leaching leaching electrowin Concentrate treated tpa 223,090 223,090 223,090 223,090 Concentrate grade % Zn % 55 55 55 55 % Pb % 1.75 1.75 1.75 1.75 Zinc metal produced tpa 120,000 120,000 120,000 120,000 Estimated power MWh/a 451,765 532,530 514,000 468,000 Labour requirements Persons 285 285 350 330 Sulphuric acid produced tpa 175,000 185,000 NA 50,000 Lime consumption tpa NA NA NA 16,000 Coal consumption tpa 112,000 NA NA NA

4.11.5 Capital cost estimate

The study found the following costs, presented in Table 4.2, were applicable for secondary processing on site:

Table 4.2 Capital cost comparison of secondary processing alternatives Imperial Roast leach Pressure Direct smelting electrowin leaching leaching Capital Cost* (AUD $ Million) 861 508.5 435 491

*These figures do not include price escalation from fourth quarter, 2010, when the report was prepared.

These costs did not include:

 power plant and reticulation facilities  water supply costs  fuel transportation cost

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 personnel transportation cost  shipping of metal product to market  access roads and other infrastructure outside plant boundaries  changes to port to accommodate loading of ingots rather than concentrate  costs of remote construction in cold climates, productivity factors, white out days.  costs of mobilising equipment to site  cost of mobilising additional employees to site during construction.

4.11.6 Operating Costs

The study found the following costs, presented in Table 4.3, were applicable for secondary processing on site:

Table 4.3 Operating cost comparison of secondary processing alternatives Imperial Roast Leach Pressure Direct Smelting Electrowin Leaching Leaching

Operating Cost* A$/lb Zn produced 0.748 0.464 0.485 0.462

*These figures do not include price escalation from fourth quarter, 2010, when the report was prepared.

These costs did not include:

 administration costs  environmental services  waste disposal services  transportation costs for acid and/or sulphur products  credit for acid and or sulphur products  residual treatment costs for processing lead concentrates and/or residues  fuel requirements for light vehicles and plant machinery.

Each of these technologies will require a significant additional of people to operate, which will necessitate a larger accommodation village and associated services.

4.11.7 Risks

A Processing plant would mean increased environmental risks (emissions, containment, more land disturbance), increased safety risks (due to a more complex plant operation), increased health risks (increased zinc and lead dust emissions), an increased number of employees (accommodation, flights, emergency backup etc), and more complex logistics for day-to-day running of the mine site (shipping, fuel supply, reagent consumables).

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4.11.8 Conclusion

Zinc and lead concentrate are widely traded commodities with price transparency, and globally agreed pricing mechanisms. There is a significant overcapacity of zinc smelters throughout the world, and there is significant demand for zinc concentrate. This will ensure that fair market values for zinc contained in the concentrate will be obtained, and that there will be a wide market for the product.

Zinc concentrate prices are agreed, at arm’s length, annually in negotiations between smelters and miners. All of Ironbark offtake agreements are at arm’s length to ensure the highest prices possible will be obtained.

Ironbark has investigated the most common zinc smelting technologies under the requirements meeting secondary processing obligations. Each of these processes will add significant capital cost to the project (doubling to tripling the capital cost of the project), and would duplicate capacity which is currently available worldwide, typically where power or transport synergies exist. These processes require large amounts of energy, either through electricity or coal, and specialised shipping would have to be constructed to bring these to Citronen.

Mining companies do not generally build or operate smelters. Smelting concentrate to produce metal is a complex process, often outside the expertise of most mining companies. Smelters are sources of pollution, have huge demands on power, coal and acid as well as a range of environmental issues regarding waste disposal and carbon emissions. It is common practice for mining companies around the world to process their product to a concentrate product and then have the concentrate treaded by a suitable established trader or smelting group.

Given Citronen’s remote location, lack of significant power generation facilities and transparent nature of the zinc market, it is not feasible to construct a secondary processing facility on site.

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5 APPROACHES AND METHODOLOGIES

5.1 SIA team

In 2010 Ironbark started the SIA process with assistance from consulting company Greenland Venture. In 2013 Ironbark commissioned Grontmij A/S to finalise the SIA for the project in conjunction with Ironbark representatives. The core project team of Grontmij consists of experts with knowledge on social impact assessments of mining activities, detailed knowledge on Greenland (language and culture), communication and facilitation of processes. The project manager of the development of the SIA is Rikke Carlsen, and the core team consisted furthermore of Mia Lynge and Camilla Christensen. When needed specialized experts on specific topics have been consulted, and the impacts and suggested mitigation measures are to a large extend build on input from the consulted stakeholders.

Grontmij A/S has acted as an independent consultant to conduct the SIA and facilitate stakeholder involvement in the SIA process.

5.2 Approach to SIA

The BMP SIA Guidelines of November 2009 is the basic reference to establish the minimum level of information, content, and general structure of the SIA.

During the planning and development of the SIA process, other references have been used as best practices for SIA for the mining industry (International Council on Minerals and Metals, International Reporting Initiative for Extractive Industries) as well as knowledge and experience developed in Greenland when evaluating and assessing the social conditions and impacts.

The SIA is based on engagement of stakeholders as much and effectively as possible.

The selection of socio-economic parameters for the baseline study has been based on the BMP Guidelines and characteristics of the arctic living conditions.

For the stakeholder engagement; collection of information has been based on developed interview guides specific to this project.

5.2.1 General approach

The general approach to the SIA is to focus on identifying potential relationships between the proposed potential impacts from the project and valued socio-economic components.

The identification of potential relationships (negative impacts, benefits, indirect effects, etc.) is based on the baseline study, the analysis of the project and its components and a checklist of critical questions addressing the key social issues.

All relevant potential impacts have been identified and priorities have been given to the ones which are identified as the biggest concerns by stakeholders and authorities.

For the potential impacts identified, the SIA includes the evaluation of the impact (significance) and propose a possible mitigation. The net impact after the mitigation measure is applied is then further described.

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For the potential benefits identified, the SIA includes the evaluation of such benefits and propose measures to maximise it.

5.2.2 Approach to the scoping phase

In 2010 Ironbark started the SIA process where the first stakeholder engagement meetings took place in the autumn of 2010.

The key aspects raised during this stakeholder engagement were:

 what were the possibilities for local employment  a request from the stakeholder to be informed on the different kind of jobs and required qualifications  transportation opportunities are important for local involvement  what were the opportunities for local business  a request for collaboration with education institutions. These key aspects were the basis for the scoping of the SIA. Based on this scoping a draft SIA was prepared and submitted to the BMP in 2011. In 2012, Ironbark revised the SIA.

In 2014 additional stakeholder engagement activities took place (both with the same stakeholders as in 2010 and with additional stakeholders). One of the objectives of this engagement activity was to discuss if the key aspects identified in 2010 were still considered to be to be key aspects. The conclusion from the 2014 stakeholder engagement was that the key aspects identified in 2010 are still valid for the SIA.

5.3 Study area and temporal boundaries

The study covers the area directly impacted by the mining operations and ancillary facilities (port, airport, camp etc.) where the impacts and benefits of employment, business opportunities and developments directly and indirectly created by the project are expected to be more noticeable.

The Citronen Fjord Project is located in a remote area outside the border of the four municipalities the area of influence for the SIA is Greenland in general.

For the baseline study the information have been processed and analysed at two levels: national and the four municipalities.

All four municipalities have been engaged on an equal basis.

The SIA will cover the following stages in the project:

 construction phase (two years)  operation phase (14 years)  closure (after 16 years)

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5.4 Baseline study

The baseline study provides information on demographic, economic conditions and trends, political structures, local organisations, cultural traits, and other factors that can influence the way in which affected communities will respond to anticipated changes brought about by the Project. The baseline also helps to predict in which way the Project will be affected by these factors. The development of the baseline and the identification of the impacts are an interrelated and parallel process.

The baseline study has been based on review of secondary resources and information obtained through qualitative and quantitative methods.

The scope of the baseline study is based on identification of a number of themes which are considered important. Identification of these themes are based on the BMP Guidelines, SLiCA study (2007) and the note from IFC addressing the social dimension of private projects (IFC, 2003). For each theme and sub-theme the SIA team has considered how the information is organised and analysed.

5.5 Data collection and research from secondary data

First step in the baseline study was to review the information available from secondary sources. The secondary sources are official data about Greenland, the four municipalities and the mine area of Citronen Fjord Project. Furthermore, research reports and other relevant reports and studies have supported the creation of the starting point of the baseline study.

5.6 Data collection and research from primary sources

The data collection and research from primary sources contain both qualitative and quantitative methods.

The SIA team have elaborated specific interview questionnaires and tools for qualitative methods which have been based on international standards, local experience and specific objectives and scope of the SIA for the Citronen Fjord Project.

International experts have ensured scientifically sound and robust methodologies and tools. A Greenlandic expert has ensured local sensitivity and adequacy. All tools have been tested before undertaking the overall survey activities.

5.6.1 Qualitative methods

Qualitative methods involve people’s perceptions, how they view themselves and the world around them.

Group interviews have been used for smaller groups which represent a larger group.

Individual interviews with knowledgeable key informants have been used to collect information and get a better understanding on complex issues and past events. Participatory techniques have been used for the collection of information, opinion and perceptions.

Interview guides have been prepared for both group and individual interviews.

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5.6.2 Quantitative methods

The quantitative methods have been used to generate data, mostly at household level and for selected arctic living conditions indicators.

Existing high quality, recent research studies like the SLiCA study (Survey of Living Conditions in the Arctic, 2007) the Mobility Study in Greenland (2010), have been used as main references.

5.7 Impact analysis methodologies

The impact assessment is based on an assessment of the positive and/or negative impact from the project based on a set of social/socio-economic categories with the use of an Impact Matrix (Leopold, 1971).

The key categories which are expected to be affected by the mining project are:

 Economic environment (employment, business life, conflicts and synergies with other sectors, salary boost, taxes and revenues)  Education and training  Public service and development plans  Social aspects  Health  Culture and natural values  Cumulative effects. For each category positive and negative impacts have been identified and qualified as far as possible. The qualification takes into consideration the likelihood of the impact (very unlikely, unlikely, probable and highly likely) and the magnitude of the impact if it occurs (low, moderate, high or very high).

The result of the assessment for each impact is presented using the following colour codes indicating whether the impact is significant, major, minor, negligible (positive or negative) or not significant (Figure 5-1). The result is found by combining the likelihood and the magnitude of the impact.

Positive Impact/ Benefit Magnitude Adverse Impact

Very High High Moderate Low Low Moderate High Very High

Highly likely

Probable Significant Major Minor Negligible Negligible Minor Major High Likelihood

Unlikely Not significant

Very unlikely

Figure 5-1 Risk assessment codes

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Different methodologies have been used to characterise, assess significance and evaluate the impacts for different impact categories. All the tools and methodologies for impact characterization and prediction are known and accepted by other international SIA guidelines such as the Mackenzie Valley Environmental Review Board, IFC and ICMM.

Public concern has also been considered when assessing the significance of the impacts.

The criterion used for determination of likelihood is:

Highly likely: Consequence very likely to occur, already planned Probably: Expected but not planned; has occurred on numerous similar projects; is a common consequence of such a project Unlikely: Not expected, uncommon consequence of such projects Very unlikely: Steps taken to avoid this consequence; very uncommon consequence of such projects.

Criteria for determination of the magnitude of the impact are following factors:

Extent of the Geographical range of the impacts, number and situation impacts: (vulnerability, resilience to change, etc.) of the receptors/beneficiaries Duration and Temporary occurrence of the impacts (short lasting or frequency of permanent), wide fluctuations that could disrupt the community impacts: over time (boom-and bust periods) Period of The impacts could be noticed immediately or over time by the Manifestation: community Public concerns: Potentially affected/beneficiary groups in the community, authorities, stakeholders and general public.

5.8 Mitigation measures and measures to maximize the benefits

Mitigation measures are identified and proposed for impacts likely to occur which are adverse in nature and significant enough to require mitigation, that is, negative impacts which are major or significant in nature. For the areas where positive impacts have been identified measures to optimise the benefits are proposed. Table 7.29 is an overview of the impacts, proposed mitigations and impacts after mitigation.

The measures presented in the SIA have been proposed by:

 stakeholders and authorities during consultations  SIA consultants based on international experience, best practices and their own understanding of the local context and opportunities. Anticipated social impacts are summarised in a table at the beginning of chapter 6, with colours indicating the significance both before and after applying measures.

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6 SOCIAL AND ECONOMIC BASELINE CONDITIONS

6.1 Introduction

This chapter describes the existing social and socio-economic environment of Greenland. With the Ironbark project being outside municipal borders, in the Northeast Greenland National Park, the baseline does not focus on a specific location but provides a national overview, including specific conditions in all four municipalities of Kujalleq, Sermersooq, Qeqqata and Qaasuitsup. All information is based on the most recent data on statistical studies and available documents, reports or relevant articles until February 3rd, 2014. The scope and content of the following baseline fulfils the requirement of the Guidelines for SIA for mining projects in Greenland (BMP, 2009).

6.2 Demographic profile

Today, Greenland’s population consists of Greenlanders, or Kalaallit, along with about 11 percent Danes and other Europeans.

According to (2014) 48,151 persons live in towns and 7,775 persons in settlements and a small minority of the population live in stations or farms. More than one quarter of the entire population live in Nuuk (16,454 people).

Figure 6-1 shows the four municipalities and towns in Greenland as well as the location of Citronen Fjord.

Citronen Fjord Station Nord

Figure 6-1 Map of Greenland showing municipalities and main towns Source: NunaGIS, Oqaasileriffik, The Danish Geodata Agency

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The map also gives an overview of the size of the National Park (Nationalparken), being the largest in the word with a surface of 972,000km2 and the location of the military and scientific station Station Nord.

6.2.1 Population

In July 2013, the total population of Greenland was 56,483. Figure 6-2 illustrates variations in Greenland’s population from 2003 to 2013. Over the past ten years the number of inhabitants has varied by approximately 800 persons. In the period between 2006 and 2009 the total population was decreasing partly due to the fact that emigration surpassed immigration (Figure 6-6).

Population in Greenland 57000

56900 56800 56700 56600 56500 56400 56300 56200

Number ofinhabitants 56100

56000

2004 2010 2003 2005 2006 2007 2008 2009 2011 2012 2013

Figure 6-2 Total population in Greenland, 2003-2013 Source: Statistics Greenland, BEESTM21,2014

Figure 6-3 illustrates the fact that Greenland´s is unequally inhabited spacially; the population is concentrated in few areas. In July 2013, 70 percent of the total population lived in the two municipalities of Sermersooq and Qaasuitsup. Only 13 percent of Greenlanders lived in the southern municipality, Kujalleq, where 17 percent lived in Qeqqata municipality. There are no towns or settlements in the region of the national park. Indeed, apart from the personnel at meteorological stations and the Danish Armed Forces surveillance unit, the elite Sirius Patrol (which patrols only), no people live in the area.

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Population distributed in municipalities

0%

13% Kujalleq 31% Sermersooq Qeqqata Qaasuitsup 39% Outside municipalities 17%

Figure 6-3 Population distributed in municipalities in July 2013 Source: Statistics Greenland, BEESTM2, 2014

The population forecast, illustrated by Figure 6-4, shows an expected diminution of the total population in the coming years. By 2040, the population is expected to have decreased by 5 percent compared to 2005, the year with the highest population. According to Statistics Greenland, this prediction is the result of calculations following the recent development of births, deaths and migration during the past years.

Population trends and projection 57500 57000 56500 56000 55500 55000 54500 54000 53500

Number ofinhabitants 53000

2035 2040 1990 1995 2000 2005 2010 2015 2020 2025 2030

Figure 6-4 Population trends and population projection from 1990 to 2040 Source: Statistics Greenland, BEEP2013, 2014

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6.2.2 Ethnic composition

To a large extent, Greenland is inhabited by Inuit and Danes. There is also a small population of foreigners from, amongst other countries, Iceland and Sweden.

There are different ways of looking at ethnic composition according to Statistics Greenland. One way of categorising the different groups in Greenland is by looking at a person´s birthplace. Today, nearly 89 percent (or 50,101) of Greenland´s population are born in Greenland and are thus categorised as Greenlanders and 11 percent of the population are born outside Greenland (Statistics Greenland, 2013). The number of residents not born in Greenland peaked twice during the 1970s and 1980s, first in relation to new construction that led to the immigration of many foreign male workers, and secondly in connection to the transfer of administrative functions from Denmark to the Self Government (Hamilton and Rasmussen, 2010). Table 6.1 illustrates the ethnic composition in the four municipalities as well as areas outside municipalities.

Table 6.1 Ethnic composition in municipalities by place of birth in July 2013 Source: Statistics Greenland, BEESTM2, 2014

Born in Born outside Total Greenland Greenland In Greenland 89 % 11 % 100 % Kujalleq 11.8 % 0.9 % 12.7 % Sermersooq 32 % 6.9 % 38.9 % Qeqqata 15.5 % 1.4 % 16.9 % Qaasuitsup 29.6 % 1.5 % 31.1 % Outside 0.1 % 0.3 % 0.4 % Municipalities

6.2.3 Size of workforce

In July 2013, the size of the workforce (persons aged 18-64) in the country was 26,791 on average per month. It means that on average per month, 47.5 percent of the total population is either engaged in or available for work.

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Workforce pyramid by age and gender in Greenland, 2013

60-64 55-59 50-54 45-49

40-44 Men

Age 35-39 Women 30-34 25-29 20-24 18-19

3000 2000 1000 0 1000 2000 3000 Number of inhabitants

Figure 6-5 Size of the workforce by gender and age in Greenland in 2013 Source: Statistics Greenland, BEESTM2, 2014

Figure 6-5 Size of the workforce by gender and age in Greenland in 2013 illustrates the age distribution among the Greenlandic workforce (people aged 18 to 64 years old) by gender. It shows that the male workforce is, at every age scale, slightly larger than the female workforce. In general, Greenland´s population is also composed of more men due to the immigration of male guest workers from other countries, along with more women than men going abroad for studying and not returning to Greenland (OECD, 2011) once studies have been completed. The size of the workforce is quantitatively bigger for both men and women between 45 and 49 years old due to the birth boom in the 1960s which was caused by improved living conditions and industrialisation process (commercial fishing) (Bjerregaard P, 2004).The distinction between employed and unemployed is presented in section 5.4.4.

6.2.4 Migration

According to Figure 6-6, the emigration rate exceeded the immigration rate in the past years. By deduction, the net migration rate has a negative value, illustrating the fact that more people are leaving the country than coming from abroad to settle in Greenland. Emigration is strongly linked to the history of Greenland as an autonomous territory of Denmark. Denmark is an easy destination for Greenlanders because of networks and administrative facilities. In 2012, the total emigration was 2,744 persons of which 2,677 persons moved to Denmark (Nordic Year Book, 2013).

It is interesting here to make a distinction concerning the place of birth. It is only the net migration rate of persons born outside the country that has a positive value. Again, the migration of foreign workers explains this trend. After the completion of their work, they return to their home country.

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Total migration

3.500 Total

3.000 emigrations

2.500 Total 2.000 immigration

1.500 Net migration in 1.000 Greenland

500 Net migration of persons born in Number iofinhabitants - Greenland -500 Net migration of persons born -1.000 outside

Greenland

2009 2003 2004 2005 2006 2007 2008 2010 2011 2012

Figure 6-6 Migration to and from Greenland between 2003 and 2012 Source: Statistics Greenland, BEEBBIU2, 2014

6.2.5 Intermunicipal migration and intramunicipal migration

21,698 domestic movements were recorded in 2012, however a majority of these where within the same municipality. Around 40 percent of Greenlanders expect to move from their current dwellings within a timeframe of five years (Mobility Study, 2010). This means that Greenlanders are very mobile and willing to move especially within the same locality. Most municipal migration is registered within the municipalities of Sermersooq and Qaasuitsup. These two municipalities attract the majority of migration movements, as shown in Table 6.2.

According to the OECD Territorial Reviews, internal migration is linked to economic opportunities. Job seekers are now moving to area where jobs are available and by the same time, new job creation is encouraged by the growing concentration of people within the same area (OECD, 2011). The willingness to move is often associated with the level of education as highly educated people are more willing to move than those with little or no education (Mobility Study, 2010). Younger people and especially women are also more likely to move permanently than older people or men that move temporarily but return to where they come from. If there is a job opportunity in another region, data shows that Greenlanders will not have difficulties to settle in different regions for the working period.

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Table 6.2 Migration within municipalities in 2012 Source: Statistics Greenland, BEEBBIU5, 2014

to Kujalleq Sermersooq Qeqqata Qaasuitsup Outside municipalities From

Kujalleq 2,401 285 130 120 1

Sermersooq 350 6,631 396 568 3

Qeqqata 164 351 3,178 332 0

Qaasuitsup 123 410 287 5,952 3

Outside 2 4 5 2 0 municipalities

Total 3040 7681 3996 6974 7

6.3 Social and Cultural indicators of well being

6.3.1 Household composition

A household is defined as a group of persons living under the same roof regarded as a unit sharing meals or living accommodations. Statistics Greenland defines it as all persons registered with an identical address.

Through the 1960s there has been a trend where the population grew rapidly in towns. This trend continued over the last 30 years as the population in towns continues to increase while it declines in the settlements (Statistics Greenland, 2014).

Table 6.3 highlights this trend as most households (87.4 percent) live in towns in 2013 where a smaller percentage of the population choose to live in settlements and to a certain extent farms or stations. Larger towns also offer “economies of scale, including better services, infrastructure and connection” (OECD, 2011). On the other hand there is a limited availability of services in the settlements, including easy access to education. The average number of persons per household in settlements is always higher than in towns for every municipality.

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Table 6.3 Total households and occupants in Greenland Jan 2013 Source: Statistic Greenland, BEEHUS2, 2014

Number of Number of Others Total Average of persons Households Households (farms, per households in towns in stations) Towns Settl. Total Settlements 2,5 Greenland 19,495 2,724 76 22,305 2,5 2,9

Kujalleq 2,554 413 51 3,018 2,4 2,2 2,4 Sermersooq 8,540 459 21 9,020 2,4 3 2,4 Qeqqata 3,268 549 0 3,817 1,6 2,5 2,5 Qaasuitsup 5,133 1,303 0 6,436 2,6 3,2 2,7 Outside 0 0 14 14 - - - municipalities

6.3.2 Important goods and services

According to different sources, the majority of Greenlanders are well equipped with goods and services considered as important. In 2012, there were 65 Internet users per 100 persons and 105 telephone subscribers per 100 people (www.data.un.org, 2014).

According to the SliCA1(Poppel et al., 2007), Greenlanders frequently used electronic equipment such as DVDs, mobile phones and PCs. Some 45 percent of the interviewees have in the past 12 months used VHF radios and GPS devices. More than half of the households own freezers, camping tents, rifles and boats.

6.3.3 Important values

This section focuses on the most important values in the Greenlandic society such as social cohesion, tradition and cultural heritage.

6.3.3.1 Social ties

Solidarity and interdependence are some key elements explaining the strong social ties that remain in Greenlandic society, where the family plays an important role. Greenlanders have very strong social ties with a large degree of interdependence, especially in small communities. These social ties bring a great synergy among Greenlandic families that consists of not only the immediate nuclear family, but also extended family members such as half siblings, grandparents, cousins, foster children etc.

6.3.3.2 Tradition and cultural heritage

For almost all Greenlanders interviewed in the SliCA, it is important or very important to maintain Greenlandic identity and values such as the preservation of traditional foods, hunting and fishing, the use of the Greenlandic language, poetry and literature, or religious and spiritual beliefs among others (Poppel et al., 2007). There is a high

1 The Survey of Arctic Living Conditions (SliCA) was initiated in 1997 to understand the well-being of Indigenous people in the Arctic Region such as living conditions and quality of life.

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consideration toward traditional Greenlandic food as the share of traditional food counts for 70 percent in households. Greenland has also a very rich cultural life where music, art and storytelling, among others, are very important. Traditional activities illustrate the rich cultural background of Greenland.

Finally, the hunting and fishing culture has been omnipresent for thousands of years. Traditional tools and methods are taught from parents to children and the first catch by the children is always a big event and an occasion to invite guests to the traditional coffee and cake, Kaffemik.

Many cultural sites from both the Norse and the Thule culture are found in Greenland such as Norse ruins and archaeological finds.

In regards of North Eastern Greenland, many come to explore the many traces of ancient Inuit settlements (www.greenland.com) However, no ancient Inuit settlements are within the project area but are located more on the east coast from Danmarkshavn to (NANOK report, 2013).

An archaeological survey from July 1994 was conducted in the Citronen Fjord area and the only sign of potential pre-historical activities was a site on the eastern shore of Citronen Fjord, marked as “A2” in Kapel (1994). This site comprises three stones arranged in a row, and may have been placed by members of the Thule culture to support an “umiak” – an 8-10 metre long open boat used in summer to move people and possessions to seasonal hunting grounds (Orbicon, EIA study, 2014).

6.3.4 Language

Greenlandic is the official language in Greenland. Greenlandic is a dialect of the Inuit language which is spoken in the Arctic regions of Canada, Greenland, Alaska and a small area in Siberia. Dialectal differences occur from settlement to settlement and from town to town (Rischel, J., 2007). The majority of people in Greenland speak and understand Greenlandic well. Since the early 20th century, Greenlandic has been taught in schools, and subjects have been taught in Greenlandic (Poppel et al., 2007). Some 98 percent of all adults declare that they have been taught indigenous language in elementary or high school (Poppel et al., 2007).

According to the same survey, 60 percent of the people living in towns and 75 percent living in settlements consider that they understand and speak Greenlandic very well. Only a small percentage of the Danes living in Greenland consider that they speak Greenlandic very well (2 percent) or well (12 percent) (Poppel et al, 2007).

Greenlandic and Danish is used in public administration and in business. In the towns, it is common to be bilingual in Greenlandic and Danish whereas in the settlements people tend to only speak Greenlandic. Another minority is also monolingual, speaking only Danish as a first language but with a very strong attachment to Greenland’s cultural and social life. These people consider themselves to be Greenlandic (Lund and Nathanielsen, 2007).

English is taught in all schools but is rarely spoken by the population, apart from young people who use English more frequently.

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6.3.5 Use of natural resources

Three major groups are using Greenland’s natural resources:

 commercial fishermen and hunters who have fishing and hunting as their main source of income.  fishermen and hunters who supplement their income from regular or seasonal work with fishing and hunting.  recreational group (usually an entire family and /or friends), who use natural resources exclusively on a recreational basis on weekend trips by boat or during summer cruises in the fjords. This group also use the natural resources as provisions during sailing trips but not necessarily as a supplement to their income. They often both hunt and fish for their own consumption in the area in their leisure time, particularly during the summer. It is very common among fishermen and hunters to help each other. However, it is difficult for many fishermen/hunters to fully support their family economically, and thus these families are often heavily depending on their wives income from paid work. The traditional Greenlandic diet is very important to the local inhabitants and is therefore also dependent on natural products. The fishermen and hunter’s use of the natural resources vary greatly according to the season and occurrence of their catches, and consequently earnings also vary from year to year.

6.3.5.1 Hunting

In 2011, the hunting of land mammals like reindeer, musk ox or polar bear represented 13,976 animals in all Greenland. This number has been decreasing the past years. The marine mammal species that can be found around the project area are polar bear, walrus, hooded seal, harp seal, bearded seal, bowhead whale and narwhal (EIA, 2014).

Approximately 121,000 birds were hunted in Greenland in 2011 where the most common species are Guillemot, Little auk, Eider, Theist or Grouse (Statistics Greenland, 2013b). Hunting will be forbidden on the project area in the national park.

Bird species living near the project area are the common eider, ivory gull, thick-billed murre, little auk, ross’s gull and fulmar (cf. EIA).

6.3.5.2 Fishing

Fishing is the primary industry of the country. In 2011, the total landing of fish was 47,000 tonnes and 57,000 tonnes of shellfish. Also there are regulations of quotas and licence for prawns and Greenland halibut (Statistic Greenland, 2013b). In 2013, Greenland exported for DKK 784 million of fish, crustaceans and molluscs which represented 80 percent of Greenland´s total export.

According to the Greenland Institute of Natural Resources, more than 250 different fish species live in Greenlandic waters such as Greenland halibut, Atlantic cod or lumpfish.

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6.3.5.3 Tourism

The Inuit culture, amazing landscapes and wildlife are the main reasons for tourists to visit Greenland. In 2012, 210,398 hotel stays were spent in Greenland. In addition to tourists, the overnight statistics also include business travellers and short-term workers hired by foreign companies. The number of tourists in Greenland has increased since 2002. In 2013, Greenland´s peak tourist season was from July to August, with June and September as the second most popular months. The number of cruise passengers has decreased from 30,300 in 2010 to 23,399 in 2012, (Statistics Greenland, TUEKRP, 2014).

In north-eastern part of Greenland, tourists travel in the southern part of the national park to discover landscapes and exciting wildlife like walruses and polar bears. Besides the wildlife, the region is also visited to investigate relics from former settlements along the coast (greenland.com).

6.3.6 Homelessness and crime

6.3.6.1 Homelessness

The following sections are from the Greenland Homeless Survey conducted by the Danish Building Research Institute in 2013 (Hansen and Andreasen, 2013).

In 2012, a total of 850 persons were estimated to be homeless. The majority (600 people) of these are persons were registered without an address, Figure 6-7. Additionally, approximately 250 persons lived in government housing. Together this means that 1.5 percent of the total population are homeless.

Figure 6-7 Number of persons registered without an address Source: Hansen and Andreasen, 2013

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For some persons being homeless is a long-term situation but for many, and expectedly most, the timeframe is shorter. This means that if the number of persons who experience homelessness over a period of several years will be significantly higher than the number at a certain point in time.

6.3.6.2 Criminal Justice System and Crimes

The judicial system in Greenland (police, courts and the prison service) has not transferred to the self-government. The legislation still belongs to the Ministry of Justice in Denmark.

The crime in Greenland is characterised by a relatively high gross of acts of violence, including sexual offences, homicide and attempted homicide compared to other countries. Furthermore, there is a relatively high degree of drug offences, mostly marijuana, and various forms of financial crime.

The police of Greenland publish annual statistics, the latest of which covers 2014. From 2013 to 2014 the number of offences for breach of the criminal law decreased by 8 percent from 4,713 notifications to 338 notifications. The number of offences was the lowest since 2006. The majority of offences (2,174) are within property crimes (including theft) followed by violence (702) offences.

Offences for breach of the criminal law 3000

2500 Offences against the person 2000 Sexsual offences 1500 Theft, burglary and 1000

robbery Nomberoffences of 500 Vandalism

0 2010 2011 2012 2013 2014

Figure 6-8 Offences for breach of the criminal law Source: Annual Statistics, 2014, Greenland Police

As seen in Figure 6-8 there is a trend towards fewer crimes since 20010. However, the number of offences are still relatively high per inhabitant compared to Denmark. Most significant this is seen for sexual offences, where the number of offences per capita is more than 13 times higher than in Denmark.

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In 2014 theft was the most frequently committed criminal offence as shown in Figure 6-9 below.

Most frequent types of criminal acts in 2014 16,5 16 15,5 15 14,5 14 % of total criminal 13,5 offences 13 12,5 12 Violence Shoplifting Burglary Theft Vandalism

Figure 6-9 Most frequent types of criminal acts in percent in 2014 Annual Statistics, Greenland police, 2014.

Violence and sexual abuse is frequent in Greenland, with 59 percent of the persons interviewed in a population survey having experienced different types of violence or threats during their adult life (Bjerregaard, P. and Aidt E.C., 2010).

6.4 Socio-economic aspects

The GDP of Greenland in current prices represented DKK 13.8 billion in 2012 with an annual real growth of 1.3 percent. Part of Greenland revenues is made of an annual block grant from the Danish government. This annual subsidy is DKK 3.4 billion, but is adjusted annually in accordance with the increase in the general price and wage index. However, the adjustment is according with price and wages development in Denmark.

6.4.1 Personal income

This section has been composed by data from Statistics Greenland unless indicated.

Figure 6-10 shows that the gross average household income in Greenland has increased approximately DKK 100,000 in the past ten years. The municipality of Sermersooq has the highest average income, with a household having revenue (coming from all kind of sources) of approximately DKK 500,000 a year and the municipality of Kujalleq has the lowest income in 2012 with DKK 325,000.

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Figure 6-10 illustrates the inequality of personnel income distribution in Greenland in 2012. More than 50 percent of the total population earned less than DKK 150,000 and around 3 percent of the Greenlanders earned more than DKK 700,000 in 2012. There is no official poverty limit in Greenland, but a relative limit is set by the European commission where there is a risk-of-poverty threshold when income s are under 60 percent of national median equalized disposable incomes (http://epp.eurostat.ec.europa.eu).

Gross average household income in municipalities

600000

500000

400000

in in DKK

300000 Amount 200000

100000

0 2002 2007 2012 Total Greenland Kujalleq Sermersooq Qeqqata Qaasuistup

Figure 6-10 Average household income before taxes for Greenland and all municipalities Source: Statistics Greenland, INEH1, 2014

In 2012, 15.7 percent of the population had an income 60 percent below the median income, which represents people earning less than DKK 50,000 a year, as seen in Figure 6-11 (Statistics Greenland, 2014).

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Personal income (DKK) distributed by percentage of the population 1,000,001 and above 900,001 - 1,000,000 800,001 - 900,000 700,001 - 800,000 600,001 - 700,000 500,001 - 600,000 400,001 - 500,000 350,001 - 400,000 300,001 - 350,000 250,001 - 300,000 200,001 - 250,000 150,001 - 200,000 100,001 - 150,000 50,001 - 100,000 Maximum 50,000 0 5 10 15 20 25 Percentage of population

Figure 6-11 Average personal income distributed by percentage of the population in DKK, 2012 Source: Statistics Greenland, ww.stat.gl, INEP6 and own calculations, 2014

There are differences in wages depending on birth place, type of dwelling and gender.

There is a marked difference in the average taxable personal income before taxes in 2012 for people born in Greenland (DKK 186,000) and people born outside Greenland (DKK 430,000).

In general, incomes in settlements are lower than in towns.

Male-female income disparity in Greenland has been increasing slightly every year since 2008. At that time, men earned DKK 61,200 more than women whereas today, men earn DKK 63,000 more than women. The gender pay gap has thus been wider the last years.

An important addition when discussing yearly income is that Greenlandic household incomes often are supplemented with traditional activities such as consumption and/or exchange of products from hunting, fishing or handicraft – a so called mixed cash and harvest based economy (Poppel et al, 2007).

6.4.2 Cost of living

Table 6.4 illustrates the evolution of prices of all goods and services in Greenland based on January 2008.

Table 6.4 Consumer Price Index (2008=100) by commodity and time Source: Statistics Greenland, PREPRISV, 2014

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Jan Jan 2009 Jan 2010 Jan Jan Jan 2008 2011 2012 2013

All Goods and services 100.0 103.5 105 106.8 112 113,8 Food etc. 100.0 106 111 113.4 119.7 121.5 Alcohol and tobacco 100.0 104.2 105.6 106.1 108.5 109.8 Clothing and footwear 100.0 103.1 101.8 99.9 99.9 100.3 Housing 100.0 104.9 105.9 109.4 124.4 127.6 Furnishing and household 100.0 102.1 111.5 110.6 113.9 116 services Medicine, pharmaceutical 100.0 102 116.2 115.3 121.5 121.8 articles Transportation 100.0 103.7 104.9 105.4 109.7 112.7 Telephone and postage 100.0 94.8 95 95.1 95.2 95.5 Leisure and culture 100.0 101.5 99.3 98.2 95.2 95.3 Restaurants and hotels 100.0 100.5 101.1 108.9 110.2 112.6 Other goods and services 100.0 105 98.4 99.7 103.3 106.1

The consumer price index or inflation rate for Greenland was 113.8 in January 1, 2013, comparing to January 1, 2008 and has increased every year since. The increase in the index is notably caused by rising housing prices (+27.6), medicine and pharmaceutical articles prices (+21.8) and food prices (+21.5). At the same time, the price of goods and services related to telephone, leisure and cultural and clothing/footwear has diminished since 2008.

Greenland’s consumer price index was 126 in 2008, meaning that prices increased by about 26 percent since 2000. In comparison the consumer price index of Denmark was 118 and 155 in Iceland for 2000 (www.data.un.org, 2014).

The construction price index is currently 124.1 as of January 1, 2006 (Statistics Greenland, PREBYG1, 2014). Its index has risen by 0.7 percent in the period from July 2011 to January 2012. Construction costs have thus risen by 24 percent per cent in the last seven years. The constructions costs that have increased the most are mainly plumbing (+36 percent) and electrical installations (+31 percent) compared to construction site preparation and foundation (+20 percent) or concrete work (+10 percent). The index follows the Danish index closely as almost all building materials are imported from Denmark.

6.4.3 Business structure in the public and private sector

At the most recent study, 3,785 businesses were counted in Greenland (Statistics Greenland, 2014). Since 2006, The Greenlandic Business Register (GER) keeps track of all companies and self-employed personnel that have to register in Greenland in accordance to the Trade Act (www.ger.gl).

The public sector is relatively large in Greenland with a substantial share of public welfare tasks such as health, social security, education etc. The public sector employed more than 40 percent of the population (Table 6.5).

In recent years some tasks have been outsourced to the private market but Greenland’s Self Government is still the main or sole shareholder of Greenland’s largest companies.

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The private sector in Greenland mostly consists of small enterprises often local as land- based businesses (fishing, hunting, raw materials, tourism), retail trade such as Ltd, transport, construction, financial advice, hotel and catering as well as repair services (Skatte- og velfærdskommission (Tax and Welfare Commission), 2010b).

Turnover by business in Greenland in 2011

Retail trade, whole sale and repair work 47,7% Fishing Real estate and 6,2% business services 6,1% Mining 0,3% Industry 4,1% Finance and Insurance 2,2% Construction 11,5% Transport 19,9% Hotels and restaurants 2,0%

Figure 6-12 Turnover by business in Greenland in 2011 Statistics Greenland, ESERES, 2014

Figure 6-12 shows that in 2011 the private sector having the highest turnover (or revenue) was retail trade, whole sale and repair work, counting for almost half of the total turnover in Greenland (47.7 percent). This data does not include the public sector. In 2014, the mining industry counts for 0.3 percent (DKK 55 million) of all Greenlandic turnover whereas it reached DKK 353 million in 2008.

6.4.4 Description of existing labour market structure

This section has been composed by data from Statistics Greenland unless indicated.

6.4.4.1 Distribution of employees in sectors

Table 6.5 shows the total employment in Greenland by sector in 2011. The sectors with most employees are marked in bold.

Table 6.5 Average number of employment per month by main sector in Greenland in 2011 Source: Statistics Greenland, AREBFB3, 2014

Per cent of all Evolution since Industries Total industries 2007 Total 24,320 100% Agriculture, fishing, hunting, etc. 10 0.0% Fishing (inshore and offshore) 1,111 4.6% Extraction of raw materials 67 0.3%

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Industry2 794 3.3% Supply of electricity and water 408 1.7% Construction 1,805 7.4% Retail trade, whole sale and repair 4,563 18.8% work Hotels and restaurants 815 3.4% Transportation 2,077 8.5% Post and telecommunications 491 2% Finance and insurance 127 0.5% Real estate and business services 1,209 5% Public administration 10,054 41.3% Education 81 0.2% Social institutions and health care 132 0.5% Refuse, association, culture, other 522 2.1% Unknown3 54 0.2%

The major employment sector is by far public administration (41 percent). As mentioned earlier, the public sector dominates Greenland’s business life and economy.

The public sector consists of public service, administration and corporate sectors (see section 6.4.3 on the corporate sector). The public administration can be divided into three segments or level of competences: the municipalities, the Government of Greenland and the Danish State. The municipalities are in charge of the administration in general, such as primary and lower secondary schools, renovation, home help. The Government of Greenland has full competencies regarding health care, business development, national library and so on. Finally, the Danish state is still responsible for defence, police, judicial system and work environment supervisory authority, including defence and the judicial system, which are under the Danish state. All of them are large employment sectors.

The second industry is retail trade, whole sale and repair work (18.8 percent) followed by transportation (8.5 percent). The four other sectors with most activity are typically private companies including industries as for example food and beverage industry, wood and paper, construction, real estate and business services. The extraction of raw materials employed 67 persons in 2011.

The economy in Greenland is reliant on natural resources and especially the fishing industry. But because of climate change raising serious challenges for the fishing industry in the future, there are big expectations toward the mining industry (OECD, 2011). The mining sector is thus a current expending sector to reduce dependency on fisheries. Even if it is currently employing a small share of the population, it is becoming a strong player with a large public support and an increase of number of licences issued.

2 Industry refers to the industries of food, beverage and tobacco products, textile and clothing, wood and paper, stone and clay and others. 3 This category includes a number of persons for whom it has not be possible to identify the business sector.

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The number of employed women and men is also very different depending on the sector of activities (Statistics Greenland, AREBFB7, 2014). It is clearly shown that the largest employment sector for women is public administration and service which count for 59 percent and have been dominating in these areas since the late 1970’s. Men dominate in the traditional sectors such as fishing, trade and repair, construction and transportation.

6.4.4.2 Unemployment

In December 2013, 3,960 persons were registered as unemployed equivalent to 13 percent of the potential workforce (Statistics Greenland, ARELED4, 2014).

Table 6.6 Average unemployment of the labour force by gender and quarter in 2011 Source: Greenland Statistics, ARELED4, 2014

1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total

Total 11.4 8.6 7.7 9.9 9.4 Men 11.8 8.3 6.9 9.8 9.2 Women 10.9 9.0 8.8 10 9.7

As Table 6.6 shows, in 2011 women had a higher unemployment rate (9.7 percent) compared to men (9.2 percent). There are relatively high seasonal variations in the unemployment rate, with the lowest percentage of unemployment in the third quarter of the year, July, August and September. It is during the first three months of the year that the percentage of unemployment is the highest.

Table 6.7 shows the average number of unemployed per month by education and gender. For both gender, being unskilled increases the probability of being unemployed. There are more unemployed people educated in trade and office but these positions also represent the largest employment sector.

Table 6.7 Average number of unemployed per month by education and gender in 2008 Source: Statistics Greenland, 2009)

Education or training Total Female Male Total 1,132 468 665 Education undeclared 20 6 13 Iron and metal 22 1 21 Building and construction 21 1 20 Trade and office 46 26 19 Food industry 22 12 10 Shipping, navigation, and 31 3 28 fishing Fishing industry 5 1 3 Educational and social 16 15 2 subjects Graphical 1 0 1 Service trade 3 2 1 Medium length education 23 7 16

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Further and higher education 1 1 Miscellaneous education 1 0 1 Unskilled 922 393 529

The government’s aim is also to develop competitiveness of local companies by offering courses to improve local competence in extractive industries and fight against structural unemployment and dependency toward the fishing industry. In 2013, 14 such courses took place around Greenland. Also the international mining companies are expected to participate in government’s efforts by offering internships and apprentices (www.noraregiontrends.org).

6.4.4.3 Unions and workers’ rights

Wage earners are, to a large extent, organised and represented through SIK (Sulinermik Inuussutissarsiutillit Kattuffiat or Greenland Workers Union). Moreover, there are a number of unions organised by professions including nursery and kindergarten teachers, journalists, doctors, dentists and teachers.

Private employers are organised and represented by GE (Greenlandic Business association) which have around 400 member enterprises and NUSUKA.

The Association of Fishermen and Hunters in Greenland (KNAPK) organise the fishermen and hunters.

Public employees are represented by four main organisations: the Teacher´s Union (IMAK), the Union of Public Servant (AK), the Association of Academics in Greenland (ASG) and the Cartel of Health Workers in Greenland (PPK).

Since 1991, there has been equality between native and expatriate wage earners with the same education and position. Working hours are 40 hours per week with five weeks of holiday per year for full-time employees. Employers pay a 12 % holiday allowance.

There are currently two pension funds in Greenland; SISA (Wage Earners’ Pension Fund) as well as PFA Soraarneq, a pension scheme under the Danish pension fund PFA (Statistics Greenland, 2014). At the same time, the Gender Equality Council (Grønlands Ligestillingsråd) promotes gender equality at work (see www.nali.gl).

6.4.5 Level of education

Improving education and vocational training is high on the political agenda. Among all Nordic countries, it is the Greenlandic government that has the highest public expenditure on education, around 14 percent in 2011 (Norden, 2013).

From 2006 to 2013, the first phase of the Greenland Education Programme has been the central focal point of the education policy. In total, the number of graduates from formal post-primary education has increased by 64 percent. In addition, an increase of 44 percent of students has attended formal post-primary education during the same period.

Table 6.8 illustrates the increase of people enrolled and completed an education before the Greenland Education Programme in 2005 and later on in 2011.

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Table 6.8 Persons having enrolled and completed education in 2005 and 2009 Source: Statistics Greenland, UDEEUDD, 2014 Commenced Completed Commenced Completed education in education education in education 2005 in 2005 2011 in 2011 Total 995 365 1,474 585 Vocational education 611 232 953 406 Iron and metal 110 28 189 69 Construction 86 23 105 37 Commercial and office 148 36 241 82 Food sector 82 14 100 34 Maritime and fisheries 44 31 81 53 Agriculture 3 1 8 6 Social and health 122 106 231 112 Graphic sector 3 3 7 2 Service 14 4 10 11 Middle-range training 232 95 334 133 Higher education 150 38 187 46

In 2011, 1,474 students began education while 585 completed an education the same year. This is an increase of 48 percent for commenced education and 60 percent for completed education compared to the figures in 2005. For vocational training there has been an increase of 56 percent for commenced education and 75 percent for completed education. There are vocational schools in every big city across the country including Qaqortoq, Narsaq, Paamiut, Nuuk, Maniitsoq, Sisimiut, and Ilulissat and several regional schools on the west coast.

Most of the vocational training focuses on alternation between practical experiences in a firm and theoretical learning at the school. Some 23 percent of students have graduated from middle range training and 7 percent from higher education. There are no records as to the percentage of persons who both enrol and complete their studies.

Table 6.9 shows in detail the number of applicants at university in 2011 and 2013. The number of applicants is currently rising and thus in every fields expected teacher training.

Table 6.9 Number of applicants at university in 2011 and 2013 Source: EU Commission, 2013

2011 2013 Total 361 428 Journalism 21 31 Cultural and Social history 28 32 Social sciences 31 40 Social work 22 55 Languages, literature and media 43 46 Theology 6 8 Translation, commercial - 32 Teacher training etc. 169 140

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Nursing and health science 41 44

Another way of differentiating education is by looking at the UNESCO´s International Standard Classification of Education (ISCED) which applied in statistics worldwide with the purpose of comparing and analysing data worldwide.

Educational profile

75 70 65 60 55 50 Men 45 40 Percentag 35 Women 30 25 20 15 10 5 0

Figure 6-13 Educational profile by ISCED-2011 levels by gender between 2002-2012 ISCED 0: Pre-primary education or less; ISCED 10: Primary education; ISCED 2+3: Secondary education; ISCED 5-8: Tertiary education Source: Statistics Greenland, UDEISCPROA, 2014 and own calculation

Figure 6-13 shows the highest finalised education of the Greenlandic population. In 2012, the highest finalised education by 52 percent of all men and 49 percent of all women have been to secondary education commonly known as elementary education or high school (UNESCO, 2012). More women have graduated from tertiary education such as a bachelor, master or doctoral degree. According to international standards Greenland has a high percentage of persons who have completed public school and low percentage for ISCED 3 and 5-6 when compared to other European countries.

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6.4.6 Social structure

6.4.6.1 Political structure

Greenland is a democratic country with universal suffrage for all citizens above 18 years of age. Greenland is an autonomous country within the Danish Kingdom and is a member of the Danish Commonwealth, which also includes the Faroe Islands. Two Greenlandic elected representatives are elected to the Danish Parliament. Since 21 June 2009 Greenland has had a Self-Government, introduced with the Act on Greenland Self- Government. With the act Greenland repatriated legislative, judicial and executive power (ex: Administration of justice, criminal law), revenue of mineral resource activities and so on (Statsministeriet, 2009)

Naalaakersuitsut, Greenland Self Government, presently consists of eight members elected by popular vote from the parties

The four municipalities are responsible for education (including primary and lower secondary school) and culture, social security services, economy and municipality taxes, planning, housing and environment.

6.4.6.2 Development plans

According to Figure 6-14 from the latest Debt and Investment Strategy from the Ministry of Finance, the government is allocating most of its capital investments into the construction area which is becoming a core strategy. In the last few years bigger loans have been raised to expand hydro-power stations (Ministry of Finance, 2012:38). The increase in construction activities within education since 2006 follows the education program launched at that time as stated in section 6.4.5.

Figure 6-14 Distribution of the public capital expenditure in Greenland from 2006 and 2015 Source: Ministry of Finance, 2012

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In order to support the overall political goals of the government, the Ministry of Finance has a political and financial focus on (Naalakkersuisut, 2013):

 Structure of the education sector especially the sectors ability to support the labour market  Creation of better incentives to participate in the labour market and a better interaction between social support and taxation  Sustainable development in the use of natural resources  Maintenance of fixed assets and the need of prioritisation between possible coming and on-going projects. 6.4.6.3 Power supply

Presently, 75 percent of the energy produced in Greenland comes from electrical power. A total of 408 people worked in the sector of electrical and water supply in 2011, Table 6-5.

To support the increasing investment toward renewable energy, a loan of DKK 250 million has been raised for expanding hydro-power stations (Ministry of Finance, 2012:38).

The rest of the required energy is produced with diesel, particularly in small settlements. Power mainly comes from long distance power plants supplying the smaller local settlements with energy.

6.4.6.4 Drinking water

Drinking water is primarily supplied from lakes and rivers. The water is filtrated and treated with chlorine, among other treatments. Some households do not have running water and therefore there are free of charge drinking water stations in all towns and settlements.

6.4.6.5 Telecommunication

TELE-POST is the main internet and tele-communication provider in Greenland. As well internet connections and tele-services are available in all towns and most settlements, however there is no service outside towns and settlements.

As seen in Table 6-5 the sector of communication employed around 500 people in average by month in 2011 (www.worldbank.com).

6.4.6.6 Transportation of goods

Royal Arctic Lines holds a concession for supplies to and from towns in Greenland by sea. The concession stipulates city and places and routes which are under the concession. Cargo for the mineral and oil sector in Greenland is exempt from the concession, however RAL bids on these projects also, and has been involved in transporting equipment to other Greenlandic mining projects.

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6.4.6.7 Educational institutions

Primary school starts with first grade the year children turn six years old and is mandatory for ten years. Then this can be followed by the upper secondary schools for three years. Several schools have 1st to 10th grade but small settlements have only to 7th grade and then children are sent to schools in towns where they live in school dormitories.

There are many upper secondary schools in Greenland and free youth education programs (paid through the tax system) and Greenlandic students receive financial support.

University education is free in Greenland (paid through the tax system).Students with a certain grade average from upper secondary school are admitted.

In Greenland there are eight schools (brancheskoler) which offer a business directed education which are:

 The School of Metal and Mechanics (Saviminilerinermik Iliniarfik) in Nuuk  The Building and Construction School (Sanartornermik Iliniarfik) in Sisimiut  The School of Commerce (Niuernermik Iliniarfik) in Qaqotoq  The School of Commerce (Niuernermik Iliniarfik) in Nuuk  The Food Service and Preparation School (Inuili) in Narsaq  The School for Fishing Industry (ATI) in Maniitsoq (to be merged with Inuili)  The School for Merchant Mariners (Imarsiornermik Ilinniarfik) in Paamiut  The School for Hunting and Fishing in Uummannaq.

Greenland School of Minerals and Petroleum opened in 2008 and is part of the Building and Construction School in Sisimiut. The school runs offshore training programs during a four year education.

6.4.6.8 Health care system

All health care treatment is free, including medication and dental treatment financed through the tax system (www.naalakkersuisut.gl or www.aka.gl).

Greenland has since 2011 been divided into five health districts. Each region consists of a regional hospital which holds the overall responsibility of the health service in the region, further to the hospital there are several other health-centres in each region (www.peqqik.gl).

Queen Ingrid’s Hospital, located in Nuuk, is the largest specialist hospital in Greenland with the most modern equipment. (www.peqqik.gl).

Settlements with over 50 inhabitants have a nurse and a social and health care assistant attached. There are 17 dental clinics, one in each town. There are no dental clinics in the settlements.

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The alcohol treatment centre Qaqiffik is financed by the Self Government and has been operating since 1995 (www.qaqiffik.gl). The Centre for Health Care Studies manages the nursing, health assistant and dental studies in Nuuk (www.pi.gl).

In the summer of 2010, telemedicine equipment (‘Pipaluk’) was set up. In total, a ‘Pipaluk’ will be set up in 77 towns and settlements with more than 50 inhabitants by December 2010 (www.peqqik.gl).

6.4.7 Public Authorities covering the Danish Realm

The police in Denmark, in the Faroe Islands and in Greenland constitute one national force, employed directly by the state.

Danish Police

The Danish Police consists of the National Danish Police Service (Rigspolitiet) and 14 districts, one of which is the Greenlandic district. The district is headed by a Chief Constable based in Nuuk under the Ministry of Justice. Since April 2012, the police district has been divided into four geographical police regions coinciding with the four municipal boundaries.

The responsibilities of the police district are: protection of citizens from harm and danger, investigations, Search and Rescue operations and for pressing charges. If the Greenland police finds it necessary, they can call on assistance from other police districts.

Further to criminal investigations, the Greenland Police is responsible for the coordination of Search and Rescue (SAR) operations in Greenland. (https://www.politi.dk/Groenland/da/om_os/om_politikredsen/).

Danish Ministry of Defence

Joint Arctic Command

The Joint Arctic Command was established in October 2012 with a merger of Island Command Greenland and Island Command Faroes. The Joint Arctic Command has its main headquarters located in Nuuk.

The command’s main tasks are the military defence of Greenland and the Faroe Islands, surveillance, show of sovereignty, fishing inspection, search and rescue, environmental surveillance, pollution control, hydro graphic surveillance and support to the civilian society.

The territorial command reaches from the waters of the Faroe Islands in the east to the Greenland Sea and the Arctic Ocean in the north, to the Denmark Strait, Irminger Sea, David’s Strait and the Baffin Bay between Canada and Greenland in the west.

In addition to the Headquarters in Nuuk, the Joint Arctic Command has a liaison element in Tórshavn (Faroes), a liaison element at Thule Air Base as well as smaller units at Kangerlussuaq, Station Nord, Daneborg, Mestersvig and at the Training and Maintenance Section Greenland at Airase Aalborg, Denmark (www.forsvaret.dk).

Station Nord and Sirius Patrol

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Station Nord is a military station under the responsibility of the Command. The base is staffed by five Danish officers on a 26-month tour of duty. The mission for Station Nord is to support the Danish Air Force in Greenland and the sledge patrol Sirius and sending daily weather reports to the weather station Danmarks Havn.

Sirius Patrol (Slædepatruljen Sirius) is an elite Danish navy unit that conducts long-range reconnaissance patrolling, and enforces Danish sovereignty in the Arctic wilderness of northern and eastern Greenland. Sirius unit is comprised of 12 patrol officers, two station specialists at Station Mestervig and six station specialists at Station Nord.

Danish Maritime Authority

The Danish Maritime Authority is a governmental agency under the Ministry of Business and Growth. The Danish Maritime Authority holds responsibility for:

 the construction, equipment and operation of Danish ships (including safety, terror prevention, navigational regulations, manning, occupational health and environmental protection) as well as port State control of foreign ships calling at Danish ports  ship registration  seafarers’ employment, health and conditions of social security  shipping policy, maritime law as well as industrial policy, both nationally and internationally  tasks related to buoying at sea and navigation marks ashore (lighthouses and buoys), including ships and repair workshops  navigational information in the form of navigational analyses, warnings, GIS and specialist publications  the National Pilot Authority. The Danish Maritime Authority consists of the central authority, eight survey offices, including the office in Nuuk, as well as the Centre of Maritime Health and Safety on the island of Fanø, Denmark. (www.dma.dk).

Administration of Justice in Greenland

The courts exercise judicial power in Denmark. The Court of Greenland is part of the Danish courts, and the highest authority is the in Copenhagen.

The Courts of Greenland consist of 18 district courts, the Court of Greenland and the and employ approximately 70 persons. Most cases are solved in the first instance by the district courts. The district court judges are not lawyers but lay judges with special education and thorough knowledge of the Greenlandic society. However, the judges in the following The Court of Greenland processes legally complicated cases in the first instance and handles supervision and education of district judges. The judges in the Court of Greenland and the High Court judge of Greenland are lawyers. Rulings issued by the district courts and the Court of Greenland may be brought before the High Court of Greenland. Rulings issued by the High Court of Greenland may, with the permission of the Appeals Permission Board, be brought before the Supreme Court in Copenhagen (www.domstol.dk).

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The Danish Working Environment Authority

The work environment in Greenland is still under Danish law and the Danish Working Environment Authority which is an agency under the Ministry of Employment and is the authority which contributes to the creation of safe and sound working conditions at workplaces. The authority has an office in Nuuk. The authority is responsible for inspections of companies and has authority to penalise enterprises which do not comply with the working environment rules. Greenland has its own working Environmental Act and the Working Environment Authority in Greenland is administrating and exercises its authority according to this act.

Greenland has its own Health and Safety at Work Act which applies work on land and to a limited degree to aviation, navigation, and fishing. It does not apply to work offshore. There is no obligation to report industrial accidents in maritime transport, fisheries, aviation, and the offshore industry to the Work Environment Supervisory Authority.

6.4.8 Transport facilities and infrastructures

The main airport in Greenland is Kangerlussuaq with regular flights to and from Denmark. From here airplane and helicopter traffic is distributed to the towns of Greenland. Moreover, there are 13 airports near towns with smaller landing strips and the major settlements have a helistop (in total 46 helistops) for emergency evacuations.

There are 16 towns with harbours and 60 minor ports in settlements across Greenland. These harbour facilities have different capacities for cargo ships and passenger boats as well as cruise ships. In north Greenland harbours are closed due to the heavy ice conditions during the winter months (Statistics Greenland, 2009).

6.5 Health

6.5.1 Public Health

The 2005-09 population survey of Greenland (Bjerregaard, P. and Aidt, E.C., 2010) maps Greenlanders’ health habits, lifestyle, health status and self-perceived health. The survey is based on the collection of data from 2,971 adults from eight towns and 10 settlements and will together with previous population studies provide information about the public health situation before the public health program, Inuuneritta4 was initiated in 2007. Below the survey’s conclusions are summarised, unless otherwise indicated.

There is a tendency that Greenlanders are abandoning the traditional Greenlandic lifestyle and foods. They are increasingly adopting the Western lifestyle, which has resulted in an increase in more Western lifestyle diseases such as diabetes, heart diseases, cardiovascular diseases and obesity. Approximately 28 percent of the population above 65 years has type 2 diabetes with the highest rates occurring in the settlements.

4 Inuuneritta was the first public health program covering all of Greenland. After finalising the ’Inuuneritta II’ program was launched for implementation in 2013-2019. See more under health strategies.

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Some 66 percent of the persons surveyed are smokers, which is less than in 1993. Particularly men have stopped smoking and currently more women than men smoke. Nevertheless, the number of smokers is still higher than in other countries. Less alcohol is consumed now than in 1993, particularly among men. Similarly, the weekly consumption of hashish has dropped since 1993.

The population’s self-perception of their health has become more negative than in 1993. The reason may be that people expect to be in better health because of the improved sanitary conditions. Around 96 percent had experienced one or more health-related inconveniences or symptoms within the 14 days prior to the survey.

Satisfaction with the health system is higher than in 1993. In general, Greenlanders would like to have more permanent doctors and other trained health personnel.

Tuberculosis and sexually transmitted diseases

Tuberculosis (TB) has been recognised as a prevalent disease in Greenland. On average, 88 persons have contracted TB each year for the past five years. The majority of the cases have been reported in municipality of Sermersooq, especially Tasilliaq have had many cases since 2010, see Figure 6-15 (Landslægeembedets årsberetning, 2011 & 2012).

Reported TB cases in Greenland, 2008- 2012 60 Municipality of Kujalleq 50

40 Municipality of Sermersooq (excluding Tasilliaq and 30 Ittoqqortoomiit) Tasilliaq and No.of cases 20 Ittoqqortoomiit

10 Municipality of Qeqqata

0 2008 2009 2010 2011 2012

Figure 6-15 No. of reported TB cases in Greenland, 2008-2012 Source: Landslægeembedets årsberetning 2011 & 2012

The number of reported sexually transmitted diseases (STDs) is shown in Figure 6-10. STDs have been a problem in Greenland for many years, and the number of cases of Gonorrhoea and Chlamydia have been increasing over the past decade.

Table 6.10 Number of reported cases of gonorrhoea and chlamydia in Greenland in 2012 Source: Landslægeembedets årsberetning 2011 & 2012

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Age <15 15+ Total Gonorrhoea 17 1,418 1,435 Chlamydia 65 3,085 3,150

6.5.2 Vulnerable groups

The population groups that are considered to be vulnerable are young mothers, the elderly, handicapped persons, families where one or more members have alcohol or drug abuse problems and the unemployed.

According to SLiCA (Poppel et al., 2007), Greenlanders consider that their country’s most important social problems are unemployment, alcohol abuse and suicide, see Figure 6-11.

Table 6.11 Perception of social problems among adult Greenlanders. Based on 37,401 interviews Source: SliCA, Poppel, B, et al 2007

Social problems Unemployment 84 % Alcohol abuse 79 % Suicide 67 % Drug abuse 68 % Family violence 63 % Sexual abuse 58 %

The health-related problems and conditions of vulnerable families frequently have a recurring theme: alcohol and abuse problems in the families.

6.5.2.1 Suicide

Suicide rates are significantly higher in Greenland compared to other Nordic and Western European countries.

The frequency of serious suicidal thoughts has been surveyed twice, in 1993 and in 2005- 2007, and while suicidal thoughts in the towns have stayed at the same level in the two periods, there has been a significant increase in the settlements. The frequency of suicidal thoughts is twice as high in the settlements as in the towns (surveys have been carried out only in the western part of Greenland). It is primarily younger people having suicidal thoughts (Bjerregaard and Dahl-Petersen, 2008).

As can be seen in Figure 6-16, the number of suicides has varied over the past ten years, still there is not been observed a declining tendency. More males than females commit suicide.

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Suicides, divided by gender, 2002-2011 45 40

35

30 25 Females 20

15 Males No ofsuicides No 10 5

0

2003 2004 2005 2006 2007 2008 2009 2010 2011 2002

Figure 6-16 Suicides, divided by gender, 2002-2011 Source: Statistics Greenland, SUDLDM2, 2014

6.5.2.2 Abortion and young mothers

In 2012 there were 87 children being born to mothers younger than 20 years of age and 192 legal abortions carried out on teenagers.

Greenland’s abortion rates are generally high. In 2010 the total abortion rate for Greenland was more than four times higher than that of Denmark. Table 6.12 shows the abortion rates for the younger age groups as well as the overall abortion rate. Compared to the Danish abortion rate for women aged between 15-19 years (15 per 1,000 women in 2010) it is seen that the abortion rate is high especially for younger women in Greenland.

Table 6.12 Abortion rates in Greenland in 2012 Source: Landslægeembedets Årsrapport for 2011 og 2012

Age group Abortion rate (per 1,000 women in the age group) 12-13 years 1.2 14-15 years 31.2 16-17 years 91.6 18-19 years 93.0 15-49 years 55.1

A study from 2001 (Bjerregaard, P. (red), 2001) shows that abortion seekers have a tendency to have low education level and poor proficiency in Danish and that the proportion of young and older abortion seekers is equally large. They have also been intoxicated more frequently than other groups during the last month.

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6.5.2.3 Alcohol and hash

Abuse of alcohol and hash is according to the self-government’s health program for 2013- 2013, Inuuneritta II, the largest, isolated, public health issue in Greenland. The abuse of alcohol and drugs is a contributing factor to many of the issues confronting children, teenagers and young families.

It is not the amount of alcohol that is the main concern, however the pattern where many units of alcohol is consumed in a short period of time (binge drinking) leads to social problems and acute and chronic health issues (Inuuneritta II, 2013).

6.5.2.4 Families and well being

According to a survey on Greenlandic children’s wellbeing (Christensen, E. et al, 2008), 12 percent of the children questioned had experienced neglect to some degree and 15 percent were seriously affected. Child neglect can be linked to caretakers’ lack of wellbeing. Moreover, violence against mothers (physical and sexual) tends to occur in combination with alcohol problems.

6.5.3 Health strategies

Paarisa – the agency for health and prevention - was established by Greenland’s Home Rule Government in 1997. Paarisa is in charge of preventive and health promotion efforts through information and counselling as well as coordination of central and cross-sectorial health promotion activities (www.paarisa.gl).

The public health program Inuuneritta was implemented by Paarisa in the period from 2007-2012, the public health program was based on a broad and close dialogue with the population as well as health workers. Building on Inuuneritta the ‘Inuuneritta II’ program covers the strategies and goals for the public health in 2013-2019. The themes of Inuuneritta II are abuse of alcohol and hash, smoking, physical activity and diet. Furthermore the efforts on the prevention of suicide, early efforts towards pregnant families and information to the public will continue from Inuuneritta (Inuuneritta, 2013).

In 2011 the Self-Government approved a national strategy for combating tuberculosis for 2012 to 2016. The strategy builds on lessons learned from the 2007-2012 strategy5.

A 2010 children’s strategy has been prepared by the Social Affairs Ministry (Departementet for Sociale Anliggender, 2010). This strategy focuses on providing a targeted effort towards children and families, to combat sexual abuse and violence and strengthen children’s rights. To achieve this, the number of drop-in centres will be increased, family treatment programs will be established as well as children centres, and crisis centres will be strengthened.

5 National TB strategy 2012 - 2016

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7 POTENTIAL IMPACTS AND MAXIMISATION OF DEVELOPMENT OF OPPORTUNITIES AND MITIGATING NEGATIVE IMPACTS

This chapter describes the assessment of potential social and socio-economic impacts and benefits of the Citronen Fjord Project.

The key categories which are expected to be affected by the Project are:

 economic environment  education and training  public service and development plans  social aspects  health  culture and natural values  cumulative effects. Positive and negative impacts have been identified and qualified as far as possible for each category. The qualification takes into consideration the likelihood of the impact (very unlikely, unlikely, probable and highly likely) and the magnitude of the impact if it occurs (low, moderate, high or very high).

The result of the assessment for each impact is presented using the following colour codes indicating whether the impact is significant, major, minor or negligible (positive or negative) (Table 7.1). The result is found by combining the likelihood and the magnitude of the impact.

Table 7.1 Risk assessment matrix Positive Impact/ Magnitude Adverse Impact Benefit Very High High Moderate Low Low Moderate High Very High Highly likely

Probable Significant Major Minor Negligible Negligible Minor Major High

Likelihood Unlikely significant Not Very unlikely

At the end of each section a summary of the potential impacts resulting from the Project are presented in table format. The summary indicates the magnitude and likelihood of the specific impact before and after mitigation measures for the construction phase, the operation phase and the closure of the Project. The result of the impact assessment is indicated by the colour code.

Mitigation measures are then identified and proposed for impacts likely to occur which are adverse in nature and significant enough to require mitigation ie. negative impacts which are major or significant in nature. For the areas where positive impacts have been identified measures to optimise the benefits are proposed.

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Following the mitigation measures, an overview of the impact assessment with the review of impacts both before and after proposed mitigation measures is shown, followed by the proposed measures (Table 7.2). A complete list of all measures (mitigations and enhancement) for all impact categories is described in the proposed Benefit and Impact Plan which is found in Table 7.29.

A summary of the benefits for Greenland are summarised below.

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7.1 Summary of Benefits for Greenland

Value/ Benefit Item DKK (6.8 DKK : 1 USD)

Capital Expenditure (CAPEX) 3.3 billion

Operating Expenditure 24. billion

Personal tax - construction 88 million

Personal tax - operation 1.9 billion

Corporate withholding tax – operation 2.0 – 2.7 billion

National Employment - construction 60 persons

235 persons by Year 5 National Employment - operation 423 persons by Year 7

Salary, location allowance, travel allowance (variable %- home Employment package to Kangerlussuaq), training. Pre-employment and on-the-job training program for the required job categories during operation phase, in cooperation with local authorities, education institutions and construction contractor early in the detailed planning of the project. Education and training Underground mining training facilities established with education institutions. Apprenticeships. Opportunity to bid for contract packages for supply of goods and services, including catering services, cleaning, laundry and similar tasks, provision of local food. Opportunity to bid for contract packages for transportation of goods and staff. Opportunities for contracts for local tradesmen such as carpenters, engineers, electricians etc Business and enterprise Opportunities for contracts for IT and communication services. Potential opportunities for local fuel providers (as Polaroil). Special attention will be given to type of fuel and opportunities of transport of fuel to the location. Establishment of a forum with GA, Nusuka and the municipalities (business councils). This forum will be used before and during tending process to provide information and clarification of the tenders.

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Table 7.2 Overview of assessment Issue Source of potential impacts and benefits Construction phase Operation phase

Before After Before After mitigation mitigation mitigation mitigation

Economic impacts

6.1.1 Employment6 The project can attract many employees from all over Negligible Minor Minor Major Greenland within numerous fields of expertise Over time it is expected that an increasing share of employees will be local 6.1.2 Business life The project offers opportunities for local provision of goods and Negligible Negligible Negligible Minor service Due to the remoteness of the mine many goods will be imported directly from outside Greenland to the mine 6.1.3 Conflict with other sectors: If and/or when more mines in Greenland start operating there Negligible No Major Minor Mineral sector will be competition for employees – a competition which might mitigation result in difficulties for the Citronen Fjord Project due to its required location 6.1.3 Conflict with other sectors: The project offers job opportunities to persons with education Negligible No Major Minor Building and construction and/or experience in the building and construction sector, mitigation sector which increases the competition for workers in the sector required 6.1.3 Conflict with other sectors: There are no fishing and hunting activities in or close to the Not No Not No Fishing and Hunting project area significant mitigation significant mitigation activities required required 6.1.4 Salary boost Employment at the mine will lead to increased local income Negligible No Negligible No and development of new skills mitigation mitigation required required 6.1.5 Taxes and revenue Company tax and income taxes from increased workforce Major No Significant No mitigation mitigation required required

Education and training

6 The impact on employment has also been assessed for the closure phase, see section 6.1.1 7-94

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Issue Source of potential impacts and benefits Construction phase Operation phase

Before After Before After mitigation mitigation mitigation mitigation

6.2 Education and training Training opportunities at the site and in cooperation with the Negligible Minor Minor Major mining school and stakeholders

Public service and plans

6.3.1 Existing Infrastructure The project is placed in a very remote location and will not use Negligible No Negligible No the public infrastructure other than for transportation of local mitigation mitigation employees and local supplies from Kangerlussuaq required required 6.3.2 Public services The project will use services from the police, customs, defence Major Minor Major Minor (Arctic Command) and health authorities

Social Aspects

6.4.1 Demography and The project can impact the current negative emigration rate by Not No Minor No population generating new employment opportunities significant mitigation mitigation required required 6.4.2 Social conflicts Risk of conflict between international and local employees at Minor Negligible Major Negligible the mine Risk of increased marginalisation of persons without skills to work in the mining sector 6.4.3 Vulnerable groups There is a risk of indirect impacts on vulnerable families if the Negligible No Negligible No most functional adult in the household is employed at the mitigation mitigation Project required required 6.4.4 Potential criminality at the Risk of criminal actions by employees while at the mining site Major Minor Major Minor mining site

Health Aspects

6.5.1 Occupational Health and OHS issues due to remote location of the mine Major Minor Major Minor risk of accidents 6.5.2 Health of employees at the Many employees living in a relatively small camp can lead to Minor Negligible Minor Negligible mine fast spread of illnesses The mental health of employees may be influenced by being situated at a very remote location over time

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Issue Source of potential impacts and benefits Construction phase Operation phase

Before After Before After mitigation mitigation mitigation mitigation

6.5.3 Public health and quality of Public health will not be influenced by the mine, unless Negligible No Negligible No life persons employed at the mine return to their home mitigation mitigation communities with potentially contagious infections contracted required required at the site

Cultural and natural values

6.6.1 Sites of monumental or There is a need for an archaeological registration and Major Negligible Negligible No cultural importance documentation of the probable sites of monumental cultural mitigation importance required 6.6.2 Access to natural areas There is no current use of the Project area Not No Not No significant mitigation significant mitigation required required

Cumulative impacts

6.7 Cumulative impacts If more mines open in Greenland this will result in increased Negligible No Negligible No competition for workers. This may potentially lead to a higher mitigation mitigation share of international workers at the Citronen Fjord Project and required required a potential increase in social conflicts

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7.2 Economic environment

Under economic environment the following aspects are analysed:

 employment  business life  conflicts and synergies with other sectors  salary boost  taxes and revenues.

7.2.1 Employment

During the initial stages of the project, the construction activities will require an equivalent of approximately 300 full time employees (local and foreign) at the Project over a period of two years. Once construction is completed and operations have commenced, the number of employees per year will increase to approximately 470 per year for the first 10 years of operation and thereafter the number of employees will decrease until the end of the Project after 14 years of operation. Approximately 290 people (local and foreign) are expected to be on site at any time.

Table 7.3 provides an overview of the jobs at the mine during operation within the different categories, and the corresponding number of employees required on site and the total number of employees. It should be noted that all activities will not take place at the same time.

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Table 7.3 Project Job categories, functions, number required on site and total number.

On site in Total employed (No.) Greenland (No.) General and administrative 16 32 Including: General Manager, Administrators, IT Technical staff, Occupational health advisor, Occupational health technician, Safety Advisor, Environment & Community Advisor, and Medical. Security/Emergency Response. Maintenance Manager and Shared 25 44 Maintenance Manager, Electrical Engineer, Mechanical Engineer, Maintenance Planner, Maintenance Foreman, Electrical Foreman, Mechanical Foreman, Boiler Maker, and Process Plant Operations. Warehousing Stores and Logistics 13 20 Warehouse and stores manager, warehouse personnel, and port personnel. Camp 33 50 Camp Manager, cooks, kitchen hands,

cleaners, and maintenance. Off-site Management and Personnel 31 31 Operations Manager, Finance Manager, Business Analyst/Accounts, accounts clerks, Supply Manager, Supply Officer, Logistics Manager, HSEC Manager, Occupational Health Coordinator, Safety Coordinator, Environmental and communications. Coordinator, Human Resources Manager, Recruitment Advisor, HR Advisor, payroll, travel and accommodation staff. Process Management 5 10 Process Manager, Plant Metallurgist, and Chemist/Environmental Monitor. Process Operations 18 27 Loader Operator, Crushing Operator, HMS & Grinding Operator, Floatation & Filter Plant Operator, Tailings/Relief Conc Loadout, Plant sampling and lab assistant and Lab Tech. Maintenance Process 4 6 Electrician- Mill and Fitter-Mill Mine Management 24 48 Mining Manager, UG manager, Senior Mining Engineer, Mine Planning, Mining Engineer, Senior Geotech Engineer, Geotech Engineer, Geology Manager, Senior Geologist, Geologist, Geological technician, and Surveyor Underground Labour 108 171 Mining Foreman, Shift Boss, Jumbo Operator, Long-hole Operator, Boltec Operator, LHD Operator, Truck Driver, Shotfirer, Nipper, Service Crew, Backfill Operator, Explosives Facility/Mag keeper, relief operators, Grader Operator (UG), and Dozer Operator. Maintenance Mining 20 30 Electrician -UG/OP, Fitter-Heavy Diesel, Fitter-Light Vehicle, and Fitter-Drill. Open Pit Labour 24 51 Mining Shift Boss, Driller, Excavator Operator, Truck Operator, Grader Operator (OP), Dozer Operator, Shotfirer, Shotfirer Assistant, and MMU Operator.

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The total number of employees will change over the course of the Project. During the operations phase, the Project will start with an underground mine, followed by a transition period ending with an open-pit and finally the decommissioning and closure of the mine.

The aim of the Project is to operate with a maximum of local workforce in all job categories. Thus, Ironbark has defined very ambitious targets for the share of local employment over time in the Project’s lifetime. The share of the local workforce is aimed to start at 20 percent during the construction phase if personnel with appropriate qualifications and experience can be recruited on competitive terms. This goal of local employment increases to 50 percent by year three of the operation phase, and increases further to 90 percent by year seven of operation.

Table 7.4 illustrate the expected number of employees over the Project’s lifetime and includes the local workforce target share at the different project phases.

Table 7.4: Number of employees per year and the expected share of local employees Phases Year (-1 – 0) Year 1-10 Year 11 Year 12-14 Year 14 Decom & Closure

Construction 300 Underground operation 469 455 Transition from 333 underground to open pit Open pit operation 200 Decommissioning and 94 closure Expected % local 20% 20-90% 90% 90% 90% 90% workforce

In December 2013, 3,960 persons were registered as unemployed. This is equivalent to 13 percent of the potential workforce. Unemployment is mainly seen among unskilled workers however, workers with vocational training also experience unemployment. The baseline information shows that there is an increase in students commencing and finishing vocational education compared to ten years ago.

As indicated above, it is expected that local employment will increase from 20 percent to 90 percent over seven years. In order to progressively replace the foreign operators, labourers and supervisors, recruiting of local Greenlandic staff for training is expected to start during the construction period, subject to support and guidance from the Greenland government agencies. The early start and support from the government agencies will ensure sufficient time to achieve the training competencies required, and at the same time ensure a close collaboration with the local authorities and labor market offices to identify and attract the best candidates.

It has been raised during the stakeholder engagement that Ironbark has defined very ambitious targets for local employment, however, it was also commented that an ambitious approach is appreciated for the possibility to put focus on the initiatives which will support local involvement.

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The experience from Greenland Contractors (stakeholder engagement December 2013) when operating at Thule AirBase is that they are able to achieve and maintain a local employment rate of 20 percent. In order to increase the share of locally employed workforce even further, Greenland Contractors states that there is a need for additional skills upgrading as well as training and education activities.

Similarly, during the engagement activities stakeholders have raised the issue that there is a need to start planning and engaging the local workforce during construction (as training activities, apprenticeship, etc.) in order to achieve the target local employment during operations. It should also be noted that the Mobility Study (2010) emphasises that Greenlanders are very mobile and willing to move to where the jobs are.

Based on experience from previous mining projects and inputs from stakeholder, barriers for achieving the expected high share of local workforce may include:

 the remote location of the project will make the location less attractive compared to other mining projects in Greenland  lack of minimum qualifications/experience for the required positions  low retention level of local workers due to difficulties to adapt to the working conditions  health limitations among qualified candidates  competition with other mining and oil projects for qualified workers  lack of access to communication (such as telephone and IT) to keep in touch with home, as Greenlanders have a very strong relationships with their family  provision of local food at camp  language barrier: it is expected that a basic level of English will be required for most job position especially with regards to safety issues as the language of communication of safety procedures is English.

7.2.1.1 Closure

The decommissioning and closure of the mine is expected to last up to three years, including monitoring (with expected monitoring visits at for instance year five and ten after the closure). The number of closure personnel in year 15 will be 78 on-site and 16 off-site (but still in Greenland). For year 16 and 17 the monitoring will consist of summer visits only, no permanent on-site personnel.

7.2.1.2 ASSESSMENT

The jobs expected to be filled locally cover a wide range of qualifications and specialisations: medical staff, kitchen personnel, security, laboratory technicians, secretaries, IT, assistant, training coordinators, human resources, environmental technicians and professionals, health and safety officers, drivers, operators of shovels, trucks and bulldozers and operations at the port facilities including support to navigation.

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Most of these positions will require as a minimum a basic level of English due to safety reasons. Language proficiency in English and/or Greenlandic and Danish may be required for positions where good communication is crucial.

There will be no restrictions related to gender or origin if qualifications are met. A number of jobs, both support and technical, are expected to be filled by female workers, of local or international origin.

Potentially, unemployed workers can benefit from the job opportunities created by the Citronen Fjord Project during the construction and operation phase. However, the most likely scenario is that the project will attract mainly workers already employed in other sectors and new graduates. Indirectly, this will create new opportunities for the unemployed workers throughout Greenland. This scenario applies to workers and unemployed from all municipalities in Greenland.

7.2.1.3 Conclusion of the assessment

The impact of the direct employment during the operation phase is characterised as positive minor (before mitigation) to major (after mitigation), and for construction phase negligible to minor (Table 7.5). The Citronen Fjord Project does not require the employees to move close to the mine, and therefore the positive effects of local employment will not be geographically concentrated, but distributed around Greenland.

The main potential negative impact following the closing of the mine is if employees have no alternative place of employment. This will not only lead to an increase in unemployment but also a decrease in income to the Greenland Government and an increase of social benefits to be distributed. Thus, the impact is considered to be negative minor to negligible.

Table 7.5 Assessment of the project’s impact on Greenlandic employment Assessment of the project’s impact on Greenlandic employment Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Economic Low Probably Moderate Probably Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Economic Moderate Probably High Probably

Assessment of the project’s impact during the closing of the mine Before mitigation After mitigation Closure Magnitude Likelihood Magnitude Likelihood Economic Moderate Probably Low Probably

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Proposed mitigation measures a) Provide a detailed description of the requirements for the different work and job categories for the construction and operation phase. b) Assistance in understanding requirements of the future workplace, such as health and safety issues, in cooperation with the local authorities. c) Develop a plan for recruitment of local employees. This plan should be developed during the IBA negotiations with the municipalities and the Greenland Government d) Ironbark company personnel physically present in Greenland including a Greenlandic speaking human resources person to support the development and implementation of recruitment plans. e) Develop a program to stimulate representation of local employees to be represented in all positions. f) Undertake a gender sensitive workforce assessment, in order to ensure that both women and men will apply for the jobs during the operation phase. g) For retention of local workforce the camp area should offer communication services in order for the local employees to have reliable communication with family. Communication services will be determined by what is technically possible in such a remote location. In addition there should be Greenlandic food served at the camp. h) A travel allowance in employment packages to provide assistance to travel from home to Kangerlussuaq and on to site. i) Consider transportation of staff via Iceland in order for potential workforce from the south east Greenland to be employed at the site as there are regular flights to Iceland from east Greenland and south Greenland. j) Clearly communicate a zero-tolerance towards alcohol and drugs for all potential employees. k) As education and training measures are key to ensure local employment this has been assessed separately in section 7.2. Mitigation measures for mine closure: l) On site education should be of international standards and if possible certified so that employees can use their skills on other mining projects.

7.2.2 Business life

Factors such as the remote location of the Project site, the limited shipping window, environmental and safety concerns, together with the high cost to transport materials, equipment, fuel and personnel to the site, will require detailed planning and co-ordination of activities throughout the design and construction phases of the Project. Due to these factors logistics management is a critical activity that will need to be closely monitored. Expediting of materials and equipment is a critical to the success of the Project. Goods and services providers will need to be experienced in dealing with these issues.

The scope of the logistics plan will encompass the services necessary for the efficient expediting, transport, traffic, warehousing and marshalling of personnel, materials and equipment, including living quarters, food, fuel and cement required to construct the facilities. It is imperative that materials and equipment transported during the shipping window arrive at the site according to the planned window sequences to enable all work to be completed on schedule.

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The Project will require one main marshalling point close to the site to take advantage of the limited shipping window. This will be a location suited to the transfer of equipment and materials from normal ocean-going ships onto ice-classed vessels. This location will be Akureyri in Iceland, or similar location.

It is estimated the project will have approximately 30,000t of process and mobile equipment, structural steel and other architectural materials, pipes, valves, fittings, cement, and other equipment, for its construction and development.

Table 7.6 provides an overview of equipment and material required for the project.

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Table 7.6 Equipment and materials required for the Project

Equipment and materials required (not an exhaustive list): a) buildings including administration facilities and the accommodation camp b) pre-engineered buildings (mill building, main warehouse, truck shop, power plant) c) arctic corridor d) potable water treatment plant e) civil works, piping, electrical, pumps and tanks f) sewage treatment plant and included civil works, piping and heat tracing g) pumps and associated electrical equipment h) waste incinerator including commissioning i) generating sets, instrumentation, piping, HVAC, waste oil system, exhaust system, lube oil system, water systems, coolant system, pumps, hoists and lube oil storage j) external site communications using the Iridium OpenPort system and additional equipment including applications, instrumentation and electrical k) airstrip, including de-icer, jet fuel trailer, surface friction trailer, trolley trailer and meteorological equipment l) port equipment, crawler crane and container handlers shiploader and link conveyors m) offshore mooring buoys, anchor chain and sea bed anchors n) port area fuel storage including fuel oil and jet fuel together with distribution systems, non- insulated steel tanks, two jet fuel non-insulated steel tanks together with all required pumps, motors, associated electrical, hose station, pipelines and hoses and containerised fuel station complete with pumps based on supplier quotations o) fresh water supply system including two submersible pumps, HDPE transfer pipeline inclusive of heat tracing, two sets of diesel driven pumps and a fresh water tank p) process water supply, including installation q) mining surface infrastructure including ANFO mobile mixing unit and explosive magazines r) mobile equipment required at site including the equipment required for the underground mine s) dewatering infrastructure t) equipment and electrical requirements specific to the underground operations u) underground ventilation requirements v) boiler system, pumping and piping requirements for the glycol storage and distribution system with all equipment w) major electrical equipment, power cables, electrical room cable tray systems, indoor lighting, etc. x) temporary facilities and services including additional accommodation for the first year of construction, with camp managing, check-in, catering, laundry, cleaning and technical maintenance.

During operations, procurement and contract packages for goods and services will be prepared and issued to the pre-qualified and approved bidders in Greenland as well as overseas. The procurement and contracts group will monitor the tender process and, in conjunction with the relevant discipline engineering leads, evaluate tenders received and prepare recommendations for award.

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Ironbark will outsource activities related to transportation of goods and staff as well as servicing of the camp. Where possible and competitive, local businesses will provide these services.

7.2.3 Provision of service of camps

The servicing of the camp will be tendered and is expected to involve approximately 33 workers at site and 50 in total. Such services include catering services, cleaning, laundry and similar tasks. Arrangements can be done by the catering company with local fishers and hunters for the provision of fish and meat for traditional food. Moreover, there will be a number of services provided for the mine when contracting local tradesmen (such as carpenters, engineers, electricians). IT services could be requested during the operation and provided locally. Greenlandic IT companies will be involved in the provision of communication services if possible.

7.2.3.1 Provision of goods

The majority of the process plant equipment and steelwork will come from outside of Greenland. Equipment for the mining activities such as dump trucks, excavators, wheel- loaders and drill rigs are expected to be purchased directly from outside Greenland.

Other consumables to be purchased during the operation phase of the project are light vehicles and vehicles supplies, furniture and equipment for the camp, stationery, clothes and safety shoes, protective gear and equipment. Most of these articles are likely to be purchased from outside Greenland.

Unfortunately, Greenland does not yet have the large scale fabrication yards and employment pool with appropriate skills in sufficient quantities to enable Citronen to be exclusively using local resources.

7.2.3.2 Provision of fuel

Provision of fuel will be purchased from Iceland or northern Europe, as fuel on site will have to be brought to site using ice class barges or ships. Local suppliers such as Polaroil would be welcomed to participate in this supply, but at this stage the requirement for specialist ships may prevent their participation. Yearly consumption is estimated to approx. 50,000 to 75,000 m3 arctic diesel fuel.

7.2.3.3 Transportation routes and provision of transportation

The planned transportation route for local employees will be from Kangerlussuaq directly to the Project. This flight will be paid for and organised by Ironbark. Ironbark will also provide a travel allowance that will notionally cover the cost of flights from the capitals cities of each municipality to the mine site via Kangerlussuaq.

Employment package agreements (Employment terms and conditions, salary) will include this travel allowance (on top of their agreed salary).

Employees living outside Kangerlussuaq or a municipal capital city will be required to organise and pay for their own transport to these cities.

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Flights from Akureyri to the Project may also be possible should the amount of employees utilising this service be of an economically viable scale. Employees could fly to Akureyri from the east coast of Greenland (using existing flights) to transfer to the Citronen flight. Foreign employees could fly to site via Longyearbyen in Svalbard.

Local transportation companies such as Air Greenland and other companies who operate in Greenland as Air Iceland and Nordland air could provide the staff transport.

Transport of equipment and materials will primarily be on ships originating from Akureyri or from a designated northern European (for example Narvik, Norway) port depending on which method of shipping is decided. Some materials and equipment may be transported via aircraft from Kangerlussuaq. A total of six trips will be required each year to resupply the project, and to ship the concentrate to market.

Transportation of goods to Citronen Fjord will require detailed planning as there are special concerns regarding ice condition and type of ships required to transport to Citronen Fjord. Royal Arctic Line raised several concerns during stakeholder engagement and that there is need for detailed planning where Royal Arctic Line could play a role of providing detailed local knowledge.

7.2.3.4 Multiplier effect

The direct jobs, the indirect jobs and the induced jobs together constitute the jobs to be created in relation to the project. The direct jobs are described in section 7.1.1 whereas the indirect jobs in relation to provision of services and goods are described in section 7.1.2.

In addition to these jobs are the so-called induced jobs. These jobs are generated when the employees (from Project-generated direct and indirect jobs) spend their earnings on consumption in Greenland. This increase in demand will in turn create new jobs and hence new revenue. This new revenue, in turn, will be spent partly on consumption, which again will create new jobs and hence new revenue. So these induced jobs are the consequence of the direct jobs at the mine project as well as the indirect jobs from outsourcing activities. This effect is generally referred to the multiplier effect.

The Input-Output model developed by Statistics Greenland for 2005 uses detailed information on the domestic production structure and use of goods and services to estimate a multiplier effect with regards to both production and job creation in Greenland. The multiplier effect with regards to an increase in output by 1 mill DKK in the extractive industries in Greenland is estimated to be 1.8 (0.7 in direct jobs and 1.1 in indirect and induced jobs). However, there are considerable variations across sectors due to the different degrees of labour intensity.

Different studies from Canada and Alaska indicate a multiplier factor of 1.6 to 2.2 in the mining sector. This information was verified in 2010 by Keith Storey (Department of Geography at Memorial University, Newfoundland) and supplemented by a study from the Mining Association of British Columbia (Economic Impact Analysis by PWC October 2011) which was referred to at the web-site www.miningfacts.org indicates a multiplier employment factor of 2.2.

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No experience exists on the multiplier effect on employment in Greenland. Due to Greenland’s very large proportion of imports and the remote location of Citronen Fjord Project this SIA proposes to use a multiplier effect factor of 1.2 ± 20 percent for employment. However, the use of 1.2 is considered to be very conservative.

Based on a multiplier of 1.2, when 450 jobs (average over time) are created at site where 405 will be filled by local workforce (90 percent), these jobs will create a further 90 jobs locally.

7.2.3.5 ASSESSMENT

There are opportunities related to the Project with regards to local provision of goods and services. However, it will be difficult (primarily due to transport issues) and initiatives such as planning and corporation with local suppliers need to be in place. To date Greenlandic companies have not serviced this remote location. For example, Royal Arctic Line do not have the ships or experience with the type of ships required for transport to the project. Also Air Greenland do not have planes available that can travel the full distance to the project.

Based on the opportunities that exist, these are assessed to be positive negligible during construction and negligible (before mitigations) to minor (after mitigations) during operation (Table 7.7).

Table 7.7 Assessment of the project’s impact on Greenlandic business life Assessment of the project’s impact on Greenlandic business life Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Economic Low Unlikely Low Probably Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Economic Low Unlikely Moderate Probably

Proposed mitigation measures a) procurement and contract packages for goods and services will be prepared and issued to the pre-qualified and approved bidders in Greenland as well as overseas. b) outsourcing of activities related to transportation of goods and staff. Where possible and competitive, local businesses will provide these services. c) servicing of the camp will be tendered. Such services include catering services, cleaning, laundry and similar tasks. There will be a number of local services provided for the mine such as carpenters, engineers, electricians and IT services. d) close dialogue with local transportation providers will be established to discuss local opportunities and challenges (Air Greenland, Royal Arctic Line). e) close dialogue with local fuel providers (as Polaroil) will be established to discuss local opportunities and challenges. Special attention will be given to type of fuel and opportunities of transport of fuel to the location.

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f) close dialogue with local communication service providers will be established to clarify if the need of Ironbark in connection with what Greenlandic Tele companies can provide. g) close dialogue with KNAPK in order to organise provision of local food to the camp. h) establishment of a forum with GA, Nusuka and the municipalities (business councils). This forum will be used before and during the tender process to provide information and clarification of the tenders.

7.2.4 Conflicts and Synergies with other sectors

7.2.4.1 Conflicts and synergies with the oil and mineral sector

It was emphasised during the stakeholder engagement activities (see section 9) that the Citronen Fjord Project might face difficulties in recruiting local workforce due to the Project’s remote location and thus difficulties in getting home in case of emergency situations occurring at home. Based on this it is foreseen that the Project may potentially be in competition for human resources with other potential mineral and oil projects should they be discovered and developed.

If Greenland has several mining projects in operation it is foreseen that synergies could occur within the mining sector, for example common education and training activities across the sector.

7.2.4.2 Conflict with the building and construction sector

It is also foreseen that there will be competition for human resources in the building and construction sector for Citronen Fjord Project. The building and construction sector in Greenland mainly operates during the warmer months, with workers experiencing unemployment or part time employment three to four months a year. It is likely that some of the workers from the construction sector (including carpenters, electricians) could look for opportunities to join the workforce involved in the activities of the Citronen Fjord Project.

7.2.4.3 Conflict with fishing and hunting activities

There are no fishing or hunting activities, neither commercial nor subsistent, in or close to the Project area. As such, there will not be any conflict with fishing and hunting activities due to the Project activities.

For potential synergies with the fishing and hunting sector with regard to supply of local food to camp (see section 7.1.3).

7.2.4.4 ASSESSMENT

Potential conflicts and synergies with other sectors have been identified especially with the completion of human resources. This impact is considered to be negative negligible during construction and minor during operation (Table 7.8).

The conflict with fishing and hunting are considered to be not significant for both construction and operation, thus no mitigation measure are required.

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Table 7.8 Assessment of the project’s impact on conflicts and synergies with other sectors Assessment of the project’s impact on conflicts and synergies with other sectors Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Conflicts and synergies Low Probably No mitigation is required with mineral sector Conflicts and synergies Low Probable No mitigation is required with building and construction sector Conflict with fishing and Not Significant No mitigation is required hunting activities Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Conflicts and synergies High Probably Moderate Probably with mineral sector Conflicts and synergies High Probably Moderate Probably with building and construction sector Conflict with fishing and Not significant No mitigation is required hunting activities

For mitigation measures, see section 7.2.1 employment.

7.2.5 Salary boost

It is expected that there will be an increase in the economic activity due to a project like Citronen Fjord in Greenland. This is as a result of salary increase for the local workers which will boost the economic activities through an increased demand for services and goods.

However, as there is no local community near the Project and hence no off-work base for the workers in the immediate proximity, the impact of the salary boost will be spread all over Greenland and thus it will be difficult to accumulate and stimulate the local economic environment within a small community.

From other mining projects in Greenland it has been emphasised that spending patterns stemming from income increases are likely to follow socio-economic status. Well- functioning families are likely to spend the increase on long term investments such as education for their children, better housing and pensions, where as dysfunctional families are more likely to spend the income increase on consumable goods such as food, alcohol and electronics. (Tanbreez, 2013).

7.2.5.1 ASSESSMENT

A salary boost and the opportunity for economic development is assessed to be positive negligible for both construction and operation phase, and thus no mitigation measures are required (Table 7.9).

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Table 7.9 Assessment of the project’s influence on salaries Assessment of the project’s influence on salaries Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Economic Low Probably No mitigation is required Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Economic Low Probably No mitigation is required

7.2.6 Taxes and revenues

The project will contribute to increased public revenues through paid fees and taxes. As there is no royalty provision included in the current Ironbark exploration licence, the direct revenues and tax contribution of the project are calculated as corporate taxation and personnel taxation (See Section 3.2.5 Royalty).

The main direct economic benefits from the Ironbark mining project arrives from corporate taxes and income taxes from local and international employees whom will be liable to pay tax in Greenland according to the Greenland tax regulation (Act on Income Taxes No. 12 of 2 November 2006).

Table 7.10 and Table 7.11 summarise the estimated contribution of the sources7:

Table 7.10 Overview of expected income tax of personnel during construction phase Income taxation of personnel8 Calculated to be approximately DKK 87.9 million.

Table 7.11 Overview of expected corporate tax and income tax of personnel during 14 years of operation Taxes and dues Status

Corporate taxation9 Calculated to be approximately DKK 2006 million. Income taxation of personnel10 Calculated to be approximately DKK 1879 million.

7 Exchange rate of 6.8DKK : 1 USD has been used. 8 The calculation is based on an equal distribution of employees in the two years of construction. In total 301 FTE are expected to be used for the construction. A discount rate of 4 % is used. 9 The source for corporate tax is Ironbark. 10 Yearly income from income taxes varies between DKK 60 million and DKK 150 million . A discount rate of 4 % is used.

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7.2.6.1 Income tax calculations

The construction phase as well as the production phase will carry positive impacts on taxes and revenues during the project’s lifetime. Below is a compilation of the figures for employment, salary and income tax generated from the Project.

7.2.6.2 Personnel income tax during the construction period

The construction phase is expected to last two years with a total use of labour equal to 300 full time employees. The number of employees will be variable throughout the construction phase.

As the Greenlandic workforce is expected to come from all four municipalities, a conservative estimation has been used by applying an income tax rate of 42 percent and a personnel allowance (tax-free threshold) of DKK 58,000/year for all employees. For the non-Greenlandic workforce a tax rate of 35 percent and no personnel allowance is applied. The expected amount of income taxes generated during the construction is illustrated in Table 7.12.

Table 7.12 Estimated number of workers, expected wage expenditure and expected income taxes during the construction period Year 1 Year 2

Expected local workers 30 30 Expected international workers 120 120 Total wage expenditure (million DKK) 114 115 Annual income tax (million DKK) 40 41

7.2.6.3 Personnel income tax during the operation period

Table 7.13 shows a summary of the staffing divided over local staff and non-Greenland based staff over an operating period of 14 years. With the shift from underground mining to open pit mining, the estimated staff size varies over the period. The table includes the expected salary and expected income taxes. The total income tax revenue during operations is calculated to be DKK 1879 million, using a discount rate of 4 percent.

Table 7.13 Estimated number of workers, expected wage expenditure and expected income taxes during the operation period Annually, Year 11 Annually, Year 14 Total year 1-10 year 12-13 Total number of workers 469 455 33 200 Expected local workers 141 - 422 410 300 180 Expected international workers 47 - 328 46 33 20 Total wage expenditure (million 389 374 264 156 4949 DKK) Annual income tax (million DKK) 140-150 144 102 60 1879

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7.2.6.4 Other aspects of Revenues to Greenland Society

In addition to the direct revenues to Greenland from personal taxes, other revenues would be generated from indirect employment and indirect business activities that will support the operation of the mine. Furthermore, some of the employees will spend part of their earnings on consumption in Greenland, which in turn will create new jobs and thus create further taxes and revenues (induced jobs). The total jobs (direct, indirect and induced jobs) have been estimated with the use of the so-called multiplier employment factor.

The effect of an increase in economic activity due to jobs created is generally referred to as the multiplier effect and is normally calculated as a percentage of primary income. The size of the multiplier effect depends on how much of the income is used for savings or surplus imports to the society.

Studies from Canada and Alaska indicate a multiplier employment factor of 1.6 – 1.8 in the mining sector. In Greenland’s case the very large proportion of imports has the effect of making the multiplier effect relatively low, and especially for this project as it has a very remote location. For this project as a whole, the multiplier effect has been estimated at 1.2 ± 20 percent for both the international and local staff wage share. This estimation obviously carries some uncertainties.

In general, there is a positive medium to high impact related to income due to taxes and revenues, with the biggest contribution likely being due to taxes (e.g. profits), income tax from employees’ salaries, direct local employment and boost on local businesses (also leading to further increases in tax revenue).

7.2.6.5 ASSESSMENT

As the Project generates income and corporate taxes this is assessed to have a positive major impact during the construction phase and a significant impact during operation.

It should be noted that the assessment and the estimation is based on the number of local and international employees as stated in Table 7.14. However, if the project will not succeed in obtaining the high number of local employees the assessment will remain as the international employees will also pay tax.

Table 7.14 Assessment of the project’s influence on Greenland’s tax and revenue income Assessment of the project’s influence on Greenland’s income from taxes and revenues Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Economic Moderate Highly likely No mitigation required Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Economic High Highly likely No mitigation required

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7.3 Education and training

Working on a mine site and a processing plant requires certain skills and education which are currently not 100 percent available in Greenland. It is anticipated that initially 80 percent of the workforce will be held by foreign employees. However once construction is finished and as the project progresses (training and education programs are completed), Ironbark aims to increase the local percentage of employment to 50 percent by year three and 90 percent by year seven.

Ironbark is planning to evaluate the need for on-the-job training during the construction phase. The training will be developed during the construction phase based on project development and as interest from the local community in employment at the mine is determined.

There are a limited number of persons in Greenland that have the required qualifications to work at the mine site. Table 7.15 gives an overview of the total number of persons with an education within selected relevant sectors. The overview is divided in persons born in Greenland and outside Greenland, and it can be seen that within a number of fields a high share of the persons with relevant training are born outside Greenland. One likely explanation for the high share of persons born outside Greenland with these specialisations is that the job market demands a higher number of workers with these profiles compared to the available supply educated in Greenland.

Table 7.15: Number of persons with an education in selected fields, 2012 Born in Greenland Born outside Greenland

Physical science - broad programs 0 2 Physics 0 8 Chemistry 5 3 Earth science 7 26 Engineering and engineering trades - broad 392 68 programs Mechanics and metal work 131 118 Electricity and energy 248 156 Chemical and process 9 12 Mining and extraction 0 0 Building and civil engineering 759 430 Environmental protection - broad programs 0 0 Occupational health and safety 0 0

As described in the baseline the overall unemployment rate varies between eight and 12 percent, being lowest during the summer (numbers from 2012).

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7.3.1 ASSESSMENT

Education and training is mentioned by numerous stakeholders as the most important factor relating to the Citronen Fjord Project. Today there is a large gap between the number of local workers who have the qualifications to work at the project and the number of local workers expected to be employed in the Project description. In order to close the gap there is a very high need for targeted skills upgrading and coordinated training programmes, ensuring that there are qualified local workers to take the offered jobs.

To assist construction contractors in securing qualified and trained Greenlandic local workers on the Project, it is recommended to enter early discussions with the Greenlandic authorities to encourage and support them in their work with training programs for the local work force.

Today the mining school experiences problems in attracting students for studies and training programs qualifying the students to take job in the mining sector (stakeholder engagement). This is likely due to the high insecurity of whether and when, and to what extent, these skills will be demanded in Greenland.

The required degree of English language competency for potential employees has been raised by the stakeholders (SIK and Mining School). Some knowledge of English will be required by persons seeking employment at the mine as most safety instructions will be in English. In order to ensure a high level of local employees, this issue will need to be evaluated during the training needs assessment.

The impact from training and education is positive. The impact is dependent on how many persons complete the training programs, the quality of the training and how successful the cooperation between education institution, local administrations, other mining companies and Ironbark will be.

The impact is assessed to be positive negligible during construction (before mitigation) and minor (after mitigation). During the operation phase the impact is assessed to be positive minor (before mitigation) to major (after mitigation) (Table 7.16).

Table 7.16 Assessment of the projects impact on education and training Assessment of the projects impact on education and training Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Skill upgrading Low Unlikely Low probable Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Skill upgrading Moderate probable High probable

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Proposed mitigation measures a) undertake an assessment of training needs and cooperate with local authorities. b) develop a pre-employment and on-the-job training program for the required job categories during operation phase, in cooperation with local authorities, education institutions and construction contractor early in the detailed planning of the project. c) discuss with educational institutions how to set-up training facilities for underground mining. d) development of a dedicated training programme for staff on specific duties, safety. e) general training programmes and on-the-job training for staff will be part of all employees’ work profile. f) cooperation with other mining companies in terms of offering training and apprentices g) focus on continuously up-grading of employees at all levels. h) offer apprenticeships within different fields of work.

7.4 Public service and infrastructure

Public service and existing infrastructure have been identified as possible areas of impact inflicted by the Project.

7.4.1 Existing infrastructure

No infrastructure exists at the Project site, other than a temporary camp and a gravel airstrip. All required infrastructure will have to be established by Ironbark.

The planned transportation route for local employees will be from Kangerlussuaq to Citronen. Flights from Akureyri to Citronen Fjord Project may also be possible should the amount of employees utilising this service be of an economically viable scale. Employees could fly to Akureyri from the East coast of Greenland (using existing flights) to transfer to the Citronen flight. Foreign employees will fly to site via Longyearbyen in Svalbard.

Transport of equipment and materials will primarily be on ships originating from Akureyri or from a designated northern European (for example Narvik, Norway) port depending on which method of shipping is decided. Some materials and equipment may be transported via aircraft from Kangerlussuaq.

The establishment of the airport will be in accordance with the relevant legislation such as AIP Greenland and BL 5-24 and in close cooperation with the Greenlandic Authorities (the former Department of Health and Infrastructure) and the Danish Authorities (Danish Transport Authority) when needed. Furthermore, close cooperation with the Danish Maritime Authority is required during planning of the shipping routes.

It has been stated by the former Department of Health and Infrastructure that it is not possible to fly directly from Kangerlussuaq to Citronen with certain aircraft, for example a Dash 8, and access to alternative airports (for emergency landings) will probably be needed in order to fly to Citronen.

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During the construction phase, it is possible that an agreement with Defense must be made to access the airstrip at Station Nord. Furthermore, the airstrip at Station Nord will, if an agreement with the Defense is reached, be one of two alternatives airstrips for the project, if landing at Citronen is not possible.

7.4.2 ASSESSMENT

As the international workforce will be transported directly to the site from an airport outside Greenland, and as Ironbark will organise chartered transport from Kangerlussuaq to the site for local workforce, the pressure on the existing infrastructure and services are considered to be negative negligible.

The potential impact on the settlement Kangerlussuaq in relation to the international workforce flying via Kangerlussuaq is considered to be negative negligible as Kangerlussuaq is already the main transportation hub in Greenland (Table 7.17). For mitigation measures see also section 6.4.2.

Table 7.17 Assessment of the projects impact on infrastructure Assessment of the projects impact on infrastructure Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Public services and plans Low Unlikely No mitigation Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Public services and plans Low Unlikely No mitigation

Proposed mitigation measures: a) Additional dialogue between Ironbark and the Department of Housing, Construction and Infrastructure is needed to clarify further the needs and further procedure in the establishment of an airport at site.

7.4.3 Public services

Public services that are expected to be influenced by the Project during the construction phase include:

 increased work load for the police, including customs and control of the international workforce travelling in and out of Greenland as well as other tasks such as investigations and rescue activities  increased work load for immigration authorities and inspectors in Greenland  increased pressure on health services.

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7.4.4 Tasks for the police and tax agency

In relation to the Project, increased tasks for the police and tax agency are expected in regard to the activities directly related to the project and customs control of the international workforce when travelling in and out of Greenland. Furthermore, as the majority of freight will originate from outside Greenland and be transported directly to Citronen Fjord Project, it is expected that new positions will be created in the customs office to service the Project on site.

The police act as a rescue authority in Greenland both on land and on the sea and there is a potential risk of increased rescue activities in relation to the Project. In addition, the police will have the role as the coordinator if any accident/incident occurs at the site such as fire.

There is a need to develop an emergency management plan in close cooperation with the authorities taking into consideration the remote location of the Project.

7.4.5 Working and resident permits

Working permits for foreign workers are normally issued by the Danish Immigration Service. A special procedure (see footnote below) has been established for quick and flexible processing of working permits11. Work and resident permits related to the mining industry are sent for consultation to Greenland Authorities. The processing of working permits for the construction period is expected to put pressure on public services during construction.

7.4.6 Health service

Ironbark plans to have a dedicated medical room equipped with the appropriate equipment taking into account the remote location. Two medics will be employed, with one on site at any time. Their qualifications will be at paramedic level as a minimum and most likely at the level of a nurse. Furthermore there will be a Mine Rescue team that will have received first aid training as well as trained first aid leaders for work teams that will work with the medic person on site regarding health and injury issues.

However, there will be situations during the Project’s lifetime, when Ironbark will require use of an external health service. It is anticipated that preferred health services will be outlined in the site Health and Safety Management Plan. The chosen health services will be decided taking into consideration adequate and appropriate patient care, transportation issues and health insurance requirements.

The health authority in Greenland has several concerns regarding the additional pressure the Project may have on health services in Greenland. Currently the provision of health service is already under pressure due to cost of infrastructure, the lack of sufficient personnel resources and a small Government budget. In addition, the small population of Greenland and the struggling health service means Greenland is vulnerable to diseases which are currently not present in Greenland.

11 https://www.nyidanmark.dk/en-us/coming_to_dk/greenland/work.htm

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7.4.7 ASSESSMENT

As there is a need for further consultation with the Police and other authorities, the pressure on the public services are considered to be negative major (before mitigations), therefore impacts after mitigations cannot be further assessed at this stage.

The increased pressure on the health system is expected to be negative major (before mitigation) for both construction and operation mainly because of Greenlandic health service that service is already under pressure and the concerns raised by the health authorities (Table 7.18).

Table 7.18 Assessment of the projects impact on public services Assessment of the projects impact on public services Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Public services and High Probable Moderate Probable plans Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Public services and High Probable Moderate Probable plans

Proposed mitigation measures: a) Develop a plan and an approach together with the Police covering aspects of customs and the role of the Police on site b) Develop a Health and Safety Management Plan in close cooperation with the authorities, including procedure for use of external public health care services c) Establish contact with local health service and develop agreements between both parties d) Pre-employment health screening and annual checkups to be implemented. The parameters to be included in the health check should be agreed with the health authorities e) Establish contact with local health service and work out cooperation between both parties and other major local work places.

7.5 Social aspects

The following social aspects have been identified as possible social issues of the Project:

 demography and population  social conflicts  vulnerable groups  criminality at the mining site.

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7.5.1 Demography and population

The Citronen Fjord Project is expected to employ approximately 490 employees per year. During the construction and the first years of the operation phase the majority of the employees will be foreigners. These are expected to be men/women without accompanying spouse, or children). The employees will first be housed at the accommodation facilities at the construction site and thereafter in the camp site during the operation. The site is very remote with no public transportation means to access the area. During the operation phase an increasing number of local employees are expected.

Over the past ten years Greenland has experienced a larger emigration than immigration, as can be seen in Figure 6-6 in the baseline chapter. The yearly net-migration for persons born in Greenland has varied between -191 and -653 persons, whereas the net-migration for persons born outside Greenland has varied between -151 and +176 persons (see section 6.2.4in baseline). Most persons migrate to and from Denmark.

7.5.2 ASSESSMENT

A possible positive impact of the Citronen Fjord Project is an expected reduction in the negative net migration rates of Greenlanders, as a result of increased job and business opportunities. This positive impact will be obtained both if more persons choose to stay in Greenland, and if Greenlanders who have earlier moved away from Greenland choose to return.

The impact on demography is assessed to be not significant during the construction phase and positive negligible during the operation phase (Table 7.19).

Table 7.19 Assessment of the project’s impact on demography and population Assessment of the project’s impact on demography and population Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Social aspects Not significant No mitigation is foreseen Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Social aspects Low unlikely No mitigation is foreseen

7.5.3 Social conflicts

The assessment of impacts of social conflict is based on experiences from other mining projects worldwide. It is not possible to verify the assessment at this stage and no former project implementation in Greenland can give qualified input as to what could be expected. This means that the assessment is primarily based on an assessment of potential risks that should be given attention in order to establish effective mitigation measures.

The risk of two forms of social conflicts is foreseen:

 conflict between local and international employees at the mining site

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 increased marginalisation of persons without skills to work in the mining sector.

7.5.3.1 Risk of increased social exclusion

Many of the jobs at the Project will require minimum qualification and language skills. This may pose a risk for increased social exclusion, limiting those without the required qualifications and language skills to employment or jobs in other sectors.

7.5.3.2 Risk of conflict between local and international employees

There is a risk of cultural conflicts between international and local workers employed by the project due to differing values, opposing interests, poor communication or personal problems and language barriers. Awareness of cultural differences and active recognition of where cultural differences are at work is the first step toward understanding each other and establishing a positive working environment.

7.5.3.3 ASSESSMENT

The risk of social conflicts during construction is assessed to be negative minor (before mitigation) and negligible (after mitigation) due to the risk of conflict between local and international employees at site. The risk of social conflicts during operation is assessed to be negative major (before mitigation) and negligible (after mitigation) as there is a risk of both social exclusion and conflict between local and international employees at site (Table 7.20).

Table 7.20 Assessment of possible social conflicts Assessment of possible social conflicts Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Social aspects Moderate Unlikely Low unlikely Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Social aspects High Probable Low unlikely

Proposed mitigation measures: a) Establish introductory sessions for all workers on intercultural understanding and provide an overview on Greenlandic culture for international workers as part of their introduction process. b) Set up a program for intercultural understanding, to be provided to all of the workforce and contractors. c) It should be ensured that the camp accommodates where practicable the cultural needs of the different nationalities living at the camp.

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7.5.4 Vulnerable groups

In general the vulnerable groups in Greenland are often identified as families with alcohol and drug abuse issues, either from both parents or one parent, as well as young mothers, the elderly, disabled persons and persons who have not completed an education (see also section 5.5.2 in baseline).

No direct impact on any vulnerable groups is expected. However, indirect negative impacts may occur with regards to children in vulnerable families, should the most functional adult in the household be employed at the Project.

7.5.4.1 ASSESSMENT

The Project’s impact on vulnerable groups is assessed to be negligible in the construction and operation phases (Table 7.21).

Table 7.21 Assessment of the project’s impact on vulnerable groups Assessment of the project’s impact on vulnerable groups Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Social aspects Low Very unlikely No mitigation foreseen Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Social aspects Low unlikely No mitigation foreseen

7.5.5 Assessment of potential criminality at the mining site

During the hearing process of other proposed mining projects in Greenland, the Police have raised potential crime at the mining site as a concern. If no rules and controls are in place this may lead to crime, eg violence and stealing.

7.5.5.1 ASSESSMENT

The risk of criminality at the mining site is assessed to be negative major (before mitigation) and minor (after mitigation) during both the construction and operation phases (Table 7.22).

Table 7.22 Assessment of potential criminality at the mining site Assessment of potential criminality at the mining site Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Social aspects High Probable Moderate Unlikely Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Social aspects High Probable Moderate Unlikely

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Proposed mitigation measures: a) Development of rules of behaviour and code of conduct/ethics, and include these in the introduction sessions for new employees. b) Ironbark should consult with the police of Greenland in the planning of the project regarding management and monitoring of criminality at the site. c) Having a zero-tolerance policy with regard to possession and use of alcohol, drugs and firearms.

7.6 Health

Within the health assessment the following aspects have been considered:

 occupational health and safety of workers at the mine  public health and quality of life.

7.6.1 Occupational health and risk of accidents

7.6.1.1 Health facilities at the site

Ironbark is planning to have a dedicated medical room equipped with the appropriate equipment taking into account the remote location, the number of personnel on site and the major health/injury risks on site. First aid posts will be located around the site as well as an on-site Ambulance.

7.6.1.2 Health and Safety Management System

Ironbark is committed to developing and implementing a Health and Safety Management System (HSMS) that follows a continuous improvement model in accordance with North American regulations pertaining to mining, which are benchmark statutory regimes. The Ironbark HSMS will be a structured, documented approach to managing risks and potential health and safety impacts arising from the Project.

The key elements of Ironbark’s health and safety management framework include:

 an assessment of health and safety risks  identification of relevant government policy, law and guidelines  incorporation of conditions of approval and other commitments  development and implementation of health and safety controls and improvements  monitoring of health impacts and safety performance  corrective action to address issues as they are identified; and  review of procedures and plans to ensure continual improvement.

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Ironbark will report, investigate, analyse and document safety incidents. Information will be analysed to monitor trends and to develop prevention programs which include corrective and preventative actions taken to eliminate the causes of incidents. All employees, contractors and sub-contractors will be required to adhere to the Ironbark Health and Safety Management Plan (HSMS) and the non-conformance and corrective action system in place at the Project.

7.6.1.3 Health and safety management plan

A Health and Safety Management Plan will be developed for the project which outlines commitments and management measures that Ironbark will implement to ensure the Project risks are managed to an acceptable level. Within this plan will be Emergency Management and Response Plans. The commitments outlined in the HSMP will aim to provide a basis for which health and safety performance and compliance can be measured throughout the Project.

More detailed health and safety management plans will be developed for specific areas closer to commencement of the Project. Work procedures will be developed from these plans. The HSMP(s) and work procedures will be periodically reviewed and updated over the life of the mine. All Ironbark employees, contractors and other personnel employed on the Project will be made aware of the HSMP(s) through the site induction process.

7.6.1.4 Emergency management

A Site Emergency Response Plan will be developed, covering all potential safety, health and environmental emergency situations and their management. The development of the plan and associated procedures will use risk and probability analysis tools, and will include necessary contingency and required resources to adequately manage an emergency situation. The Site Emergency Response Plan will set forth specific actions to be followed and management controls should an emergency arise. The basic premise is that emergencies, whilst not expected, will be well planned for.

The Citronen Fjord Project will have in place an Emergency Response Team (ERT), which will comprise of specialist personnel from the work force and trained in various aspects of emergency response. A full time ERT co-ordinator will be appointed on site, who in addition to fulfilling this role will also be the site medic. Supporting the ERT co- ordinator will be ‘on-call’ personnel drawn from operations and management having been trained as paramedics, fire-fighters and in other rescue disciplines.

The ERT will receive suitable resources in the form of site ambulance, fire tender, medical resources and health care facilities, as well as regular training and practice drills to ensure the highest provision of emergency service. Through training and maintaining a well- equipped ERT the site at Citronen will be able to deal with emergencies, be they fire, or environmental incidents.

ERT provisions will be ancillary to back-up systems and safety controls designed to minimise potential hazards. Back-up power facilities will be available to ensure continued operation of life critical systems, namely ventilation, communications and power/heating to the accommodation, healthcare and runway facilities. Emergency evacuation planning will be undertaken and allowance made to ensure timely evacuation can be affected.

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7.6.1.5 ASSESSMENT

There is a potential risk of accidents during the construction, operation and closing phases of the mine, mainly related to the operation of heavy machinery, explosives, and processing along with human error and harsh weather conditions. Adverse weather conditions can also lead to accidents during transportation of goods, staff and concentrate. Furthermore, the long distance to health facilities outside Project area is also a risk factor.

Even though the likelihood of accidents is low, the repercussions are very serious if anything is to happen to workers and transporters. Because of the amount of workers involved and type of accidents involving explosives and heavy machinery the risks are significant. Safety training and instructions, as well as use of protective equipment mandatory for all workers, contractors and visitors may reduce the likelihood and severity of accidents in the mining and processing operations.

The risks of accidents during construction and operation are therefore assessed to be negative major (before mitigation) and minor (after mitigation) (Table 7.23).

Table 7.23 Assessment of occupational health and risk of accidents Assessment of occupational health and risk of accidents Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Health High Probable High Very unlikely Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Health High Probable High Very unlikely

Proposed mitigation measures a) develop and implement health and safety management plan for staff at the mine site. b) establish a health and safety committee with joint participation of workers that help to monitor and provide health and safety programs on mine site. c) training of all staff on safety and emergency response on the mine site. d) contractual requirements to providers of transportation services (Air Greenland, charter boats for staff, etc.) regarding safety measures, response time. in order to minimise risk of accidents, appropriate and timely response in case of accidents, emergency evacuation from mine site. e) pre-notification of operations and traffic of vessels to authorities. f) develop emergency and contingency plans in coordination with Greenland Contingency Committee and other major local workplaces.

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7.6.2 Health of employees at the mine

All personnel will go through a pre-employment health check and annual checks such as hearing, respiratory function and eye tests. The test parameters will be agreed with the health authority. Pre-employment checks will be required prior to coming on site, for instance at a local health centre.

Working at a mine can have adverse effects on personal health, including:

 illnesses (immediate or long-term) deriving from dust exposure  hearing issues occurring due to noise exposure  respiratory diseases. Furthermore, the Citronen Fjord Project is placed in a very remote and extreme location, which means conditions may influence employee mental health if not taken into account.

Communicable diseases such as TB and HIV/AIDS are also a risk due to many employees living in a small community. A health screening for TB and HIV/AIDS will be required before employment at the Project.

7.6.2.1 ASSESSMENT

Based on the remote location or the Project and the advantages of a strong preventive and corrective health and life style campaigns among the workers, the impacts on health are assessed to be negative major (before mitigations) and minor (after mitigations)(Table 7.24).

Table 7.24 Assessment of the projects impact on the health of employees Assessment of the projects impact on the health of employees Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Health Moderate Probable Low Unlikely Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Health Moderate Probable Low Unlikely

Proposed mitigation measures: a) dust and noise controls on machinery eg water sprays, noise inhibitors. Provision of personal dust and noise protective equipment eg ear plugs, dust masks. b) health screening prior to employment to ensure that the workers do not have any Sexually Transmitted Disease (STD) or Tuberculosis (TB).

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7.6.3 Public health and quality of life

The negative impacts on health and quality of life of the community related to a mining operation are often related to interactions between the local community and the influx of staff. In other parts of the world mining has resulted in increase in STDs and HIV/AIDS among the general population and sex workers (Desmond N, 2005; Campbell C, 1997).

7.6.3.1 ASSESSMENT

Due to the remote location of the Project, where foreign employees are expected to fly to the site from outside Greenland, there will be no influence of foreign workers on towns and settlements.

With many employees from different countries and cultures living full time at the mine site for several weeks, the largest risk for impacts of the public health derives from infections received at the mine site and brought back to the home communities. This impact is assessed to be negative negligible (Table 7.25).

Table 7.25 Assessment of the project’s impact on public health and quality of life Assessment of the project’s impact on public health and quality of life Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Health Low - Unlikely No mitigation required Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Health Low - Unlikely No mitigation required

7.7 Cultural and natural values

Greenlandic cultural and natural values (such as access to hunting/fishing, use of Greenlandic language and access to Greenlandic food) are closely connected to social values as the traditional and cultural activities involves many social events and a rich social life compared to western societies.

Within the assessment of the projects impact on cultural and natural values the following aspects have been considered:

 sites of monumental or cultural importance  access to natural areas. 7.7.1 Sites of monumental or cultural importance

In July of 1994, the Greenland National Museum and Archives conducted an archaeological survey of the Citronen Fjord area (Kapel, 1994 – see Section 5.9.2 in the EIA) to ensure that no protected sites or other archaeological interests would be affected by exploration activities undertaken by Platinova A/S (the liciense owners at the time).

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The archaeological survey covered an area of 6.5km², including the river delta, investigating the eastern side of Citronen Fjord to Frederick E. Hyde Fjord, and the Eastern and Esrum River valleys to a distance of 4-5km from Citronen Fjord.

No evidence of former Eskimo settlements were found within the area, with the only sign of potential pre-historical activities being a site on the eastern shore of Citronen Fjord, marked as “A2” in Kapel (1994). This site comprises of three stones arranged in a row, and may have been placed by members of the Thule culture to support an “umiak” – an 8- 10 metre long open boat used in summer to move people and possessions to seasonal hunting grounds.

Subsequent discussions with the Greenland National Museum and Archives have expressed that the Kapel (1994) report sufficiently characterises the archaeology of the Citronen Fjord area. However, prior to works, there is a need for an archaeological registration and documentation of the sites of monumental or cultural importance and near surroundings. It is planned to complete the documentation and registration during the next field season at the Project.

7.7.1.1 ASSESSMENT

Based on the previous surveys the impacts of the project on sites of monumental or cultural importance’ during the construction phase are assessed to be negative major (before mitigation) and negligible (after mitigation). During operation the impact is assessed to be negligible.

Table 7.26 Assessment of the project’s impact on sites of monumental or cultural importance Assessment of the project’s impact on sites of monumental or cultural importance Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Cultural and natural Moderate Highly likely Low Very unlikely values Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Cultural and natural Low Very unlikely No mitigation foreseen values

Proposed mitigation measures a) Contact the Greenlandic National Museum and Archive for them to further study and register the affected archaeological features.

7.7.2 Access to natural areas

According to the EIA, it was decided that a local use study was not necessary due to the remote nature of the project and that Peary Land has been un-inhabited for the last 600 years.

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Furthermore, the nearest Greenlandic settlement (and the northernmost settlement in the world) is Qaanaaq in North-west Greenland, 940km from Citronen Fjord.

Peary Land, including Citronen Fjord, is not used for fishing, hunting or other human activities by the Greenlandic population or people from other nations This is due to the remoteness and the fact that sea ice covers the ocean around North Greenland most of the year. Furthermore, as the licence area is located in the National Park, hunting and fishing activities are not allowed unless you have obtained a permit (Order no. 7 of the 17th June 1992).

A small military and scientific base, Station Nord, which includes a landing strip (but no port), is situated on the north-east coast of Greenland, 240km from Citronen Fjord. The base has a permanent staff of five people.

7.7.2.1 ASSESSMENT

Based on this, the impact of access to natural areas is considered to be not significant (Table 7.27).

Table 7.27 Assessment of the project’s impact on access to natural areas Assessment of the project’s impact on access to natural areas Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Access to natural area Not significant No mitigation required Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Access to natural area Not significant No mitigation required

7.8 Cumulative impacts

Cumulative impacts are those that result from the successive, incremental, and/or combined effects of an action, project, or activity when added to other existing, planned, and/or reasonably anticipated future ones (IFC, 2013).

For the Citronen Fjord project it is considered that the cumulative impacts of relevance for this project is with regards to completion and recruitment of local staff with other mineral projects in Greenland. It must be considered that other mining projects may impact the number of skilled staff that are available to work on the mine.

The impact is assessed to be negative negligible as increased competition of local workers will lead to a higher share of international workers, which again can lead to an increased number of negative social conflicts (Table 7.28).

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Table 7.28 Assessment of the project’s impact on cumulative impacts Assessment of the project’s impact on cumulative impacts Before mitigation After mitigation Construction Magnitude Likelihood Magnitude Likelihood Cumulative impacts Low Probably No mitigation required Before mitigation After mitigation Operation Magnitude Likelihood Magnitude Likelihood Cumulative impacts Low Probably No mitigation required

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Table 7.29 Overview of impacts, proposed mitigations and impacts after mitigation (Benefit and Impact Plan)

Issue Proposed measures (mitigation or enhancement)

Economic Impacts 1 Employment a) Prepare a description of the requirements for the different work and job categories for the construction and operation phase. b) Assistance in understanding requirements of the future workplace, such as health and safety issues etc., in cooperation with the local authorities. c) Develop a plan for recruitment of local employees. This plan should be developed together with the municipalities (Labour Market Offices) and should start in the early construction phase. d) Ironbark to be physically present in Greenland including a Greenlandic speaking human resources person to support the development and implementation of recruitment plans . e) Develop a program to stimulate representation of local employees to be represented in all positions, including employment packages to make Citronen Fjord Project an attractive workplace for local workers. f) Undertake a gender sensitive workforce assessment, in order to ensure that both women and men will apply for the jobs during the operation phase. g) For retention of local workforce the camp area should offer communication services in order for the local employees to have reliable communication with family. Communication services will be determined by what is technically possible in such a remote location. In addition there should be Greenlandic food served at the camp. h) A travel allowance in Employment packages to provide assistance to travel from home to Kangerlussuaq and on to site. i) Consider transportation of staff via Iceland in order for potential workforce from the south east Greenland to be employed at the site as there are regular flights to Iceland from east Greenland and south Greenland. j) Clearly communicate a zero-tolerance towards alcohol and drugs for all potential employees. k) As education and training measures are key to ensure local employment this has been assessed separately in section 6.2 of this table l) On site education should be of international standards and if possible certified so that employees can use their skills on other mining projects.

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Issue Proposed measures (mitigation or enhancement)

2 Business life a) Procurement and contract packages for goods and services will be prepared and issued to the pre-qualified and approved bidders in Greenland as well as overseas. b) Outsourcing of activities related to transportation of goods and staff. Where possible and competitive, local businesses will provide these services. c) Servicing of the camp will be tendered. Such services include catering services, cleaning, laundry and similar tasks. Arrangements can be done by the catering company with local fishers and hunters for the provision of fish and meat for traditional food. Moreover, there will be a number of services provided for the mine when contracting local tradesmen (carpenters, engineers, electricians etc.). Also, IT services could be requested during the operation and provided locally. d) Close dialogue with local transportation providers will be established to discuss local opportunities and challenges (Air Greenland, Royal Arctic Line). e) Close dialogue with local fuel providers (as Polaroil) will be established to discuss local opportunities and challenges. Special attention will be given to type of fuel and opportunities of transport of fuel to the location. f) Close dialogue with local communication service providers will be established to clarify if the need of Ironbark in connection with what Tele Greenland can provide. g) Close dialogue with KNAPK in order to organise provision of local food to the camp. h) Establishment of a forum with GA, Nusuka and the municipalities (business councils). This forum will be used before and during tending process to provide information and clarification of the tenders.

Education and training

3 Skill upgrading a) Undertake an assessment of training needs in cooperation with local authorities. b) Develop a pre-employment and on-the-job training program for the required job categories during operation phase, in cooperation with local authorities, education institutions and construction contractor early in the detailed planning of the project. c) Discuss with educational institutions how to set-up training facilities for underground mining. d) Development of a dedicated training program for staff on specific duties, safety, etc. e) General training programs and on-the-job training for staff will be part of all employees’ work profile. f) Cooperation with other mining companies in terms of offering training and apprentices. g) Focus on continuously up-grading of employees at all levels. h) Offer apprenticeships within different fields of work.

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Issue Proposed measures (mitigation or enhancement)

Public Service and Plans 4 Public services a) Develop a plan and an approach together with the Police covering aspects of customs and the role of the Police on site. b) Develop a Health and Safety Management Plan in close cooperation with the authorities, including procedure for use of external public health care services. c) Establish contact with local health service and work out cooperation between both parties. d) Pre-employment health screening and an annual check. The parameters to be included in the health check should be agreed with the health authorities. e) Establish contact with local health service and work out cooperation between both parties and other major local work places.

Social Aspects 5 Social conflicts a) Establish introductory sessions for all workers on intercultural understanding and provide an overview on Greenlandic culture for international workers as part of their introduction process. b) Set up a program for intercultural understanding, to be provided to all of the workforce and contractors. c) It should be ensured that the camp accommodates the cultural needs of the different nationalities living at the camp. 6 Potential criminality at a) Development of rules of behaviour and code of conduct/ethics, and include these in the introduction sessions for the mining site new employees. b) Ironbark should cooperate with the police of Greenland in the planning of the project. c) Having a zero-tolerance policy with regard to possession and use of alcohols, drugs and use of firearms. Health Aspects 7 Occupational Health a) Develop and implement health and safety management plan for staff in the mine site. and risk of accidents b) Establish health and safety committee with joint participation of workers that help to monitor and advice health and safety programs on mine site. c) Training of all staff on safety and emergency response on the mine site. d) Contractual requirements to providers of transportation services (Air Greenland, charter boats for staff, etc.) regarding safety measures, response time, etc. in order to minimise risk of accidents, appropriate and timely response in case of accidents, emergency evacuation from mine site, etc. e) Pre-notification of operations and traffic of vessels to authorities. f) Develop emergency and contingency plans in coordination with Greenland Contingency Committee and other major local workplaces.

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Issue Proposed measures (mitigation or enhancement)

8 Health of employees at a) Dust and noise controls on machinery eg water sprays, noise inhibitors. Provision of personal dust and noise the mine protective equipment eg ear plugs, dust masks. b) Health screening prior to employment to ensure that the workers do not have any Sexually Transmitted Disease (STD) or Tuberculosis (TB). Cultural and natural values 9 Sites of monumental or a) Contact the Greenlandic National Museum and Archive for them to further study and register the affected cultural importance archaeological features.

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8 DRAFT MONITORING PLAN AND DRAFT EVALUATION PLAN

The draft monitoring and the draft evaluation plan have been prepared using a logical framework according to international standards and Best Practice (ICMM, 2005).

The SIA report contains the draft monitoring and evaluation plans to be consulted with authorities and stakeholders. When developing the Impact Benefit Agreement, these plans will be incorporated as final versions, including the feedback received during the consultations.

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Impact and Benefit Plan Inputs/outputs Objectively verifiable indicators Sources of Risks and assumptions (Monitoring Plan) verification 1 Economic Environment 1.1 Monitoring Plan for Recruitment Programme for Local Workforce

Goal: Achieve the proposed percentage of local workforce for operation

20 percent local workforce during the two years of construction, subject to availability, qualifications, experience and to the possibility of mobilising the local workforce.

50 percent local workforce during the first three years of operation, subject to availability, qualifications, experience and to the possibility of mobilising such a level of workforce in Greenland

90 percent local workforce after seven years, subject to availability, qualifications, experience and the possibility of mobilising such a level of workforce in Greenland. Outcome 1: Creating an attractive Input: Addressing cultural, gender, competences Stakeholder engagement process conducted Meeting protocol working place for recruitment and and geographical issues under SIA, incorporating retention of local workforce findings into planning of the project (rotation scheme, transport arrangements and working conditions at camp) Output: Elimination of main cultural, gender and Number of workforce from the four Annual report Female workers available and geographical barriers within the main municipalities municipalities. interested in working in mine in Greenland Percentage of female workforce per job operation and related category. services Outcome 2: Increased awareness Input: Detailed job description and requirements for Job descriptions and qualification requirements Report and list of Local workforce available and on the requirements for applying for all categories of job during operation phase made developed and distributed to all relevant descriptions interested in working in the the different job categories for the public available to community, municipality, unions stakeholders mine operations operation phase and technical schools Output a): Training Needs Assessment carried out Number of initiatives taken by authorities and Training Needs Resources allocated to the in cooperation between Ironbark and authorities organisations to improve qualifications of Assessment report cooperation between the potential candidates mining company and authorities

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Impact and Benefit Plan Inputs/outputs Objectively verifiable indicators Sources of Risks and assumptions (Monitoring Plan) verification

Output b): Authorities and relevant organisations Number of people enrolled in specific courses Reports of training take measures in order to ensure qualifications of on relevance to the mining sector activities of local workers relevant organisations

1.2 Monitoring plan for business life

Goal: Positive impact on general business life

Outcome: High level of purchase Input a): Open day events in all four municipalities Number of participants of open day events in Meeting protocol and contracts with local for local businesses the four municipalities businesses. Input b): Unbundling of contracts for services and Number of contracts tendered Tender documents supplies to camp with no cost hindrance to the project Input c): Sensitive elaboration of tender documents Output a): Local businesses engaged and informed Number of local businesses involved in the Received Local business has the about tender procedure and type of contracts tender process proposals necessary capacity to invest available from the mine in service delivery Output b): Local businesses able to engage in specific contract agreements with the mine 1.3 Monitoring plan for education and training

Goal: Contribute to the development of skills and competencies of the workforce in Greenland

Outcome: High level of skills and Input a): Recruitment program involving the School Number of participant in the recruitment Training protocols competences among the workforce of Minerals and Petroleum program Input b): On-the-job training program for staff on Agreement with specific duties, safety etc. Number of on-the-job training conducted School of Minerals and Petroleum Input c): Trainee positions available for students Number of trainee and apprenticeship per year from School of Mineral and Petroleum

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Impact and Benefit Plan Inputs/outputs Objectively verifiable indicators Sources of Risks and assumptions (Monitoring Plan) verification Input d): Apprenticeship available Input e): Reinsertion program for workers after mine closure Output: Provision of high quality competency Staff motivated to invest time development of staff in training activities

2 Public services and development plans 2.1 Monitoring plan for impacts on public services

Goal: Minimise pressure on relevant public services

Outcome: Reduced pressure on Output a): Plan developed together with the Police Plan developed including description how Plan developed Local services willing to public services covering the aspect on how to handle customs and customs will be handled and role of the Police cooperate in preparation of role of the Police on site the plans Output b): Contingency plan developed Contingency plan developed Plan developed Output c): Plan for condition and use of Public Plan for condition and use of the Public Health Plan developed Health Service Service 3 Social aspects

Goal: Minimising social conflicts on the site between local and international staff

Outcome: Reduced social Output a): Program for intercultural understanding Program document is prepared and available Program conflict between local and available for all local and international staff developed international staff at site Output b): Camp which accommodates the cultural Camp accommodates the cultural needs of Design of camp to needs of the different nationalities living at the different nationalities. accommodate camp. cultural needs 4 Health 4.1 Monitoring plan for Occupational Health and Safety

Goal: Avoid accidents related to the mine (zero-tolerance)

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Impact and Benefit Plan Inputs/outputs Objectively verifiable indicators Sources of Risks and assumptions (Monitoring Plan) verification Outcome: High standard of OHS Input a): Emergency and contingency plans in Emergency and contingency plans developed Emergency and on the mine site and in related coordination with Greenland Contingency contingency plan operations Committee document Acknowledgement from Greenland Contingency Committee Input b): Health and safety plan for the mine site Health and safety plan developed Health and safety plan document Input c): Contractual requirements to suppliers Requirements to suppliers developed Supplier contracts regarding safety measures and response time Input d): Training of staff on safety and emergency Number of staff trained Training protocols response on the mine site Input e): Establish health and safety committee with H&S committee established List of committee joint participation of workers helping to monitor and members advice health and safety programmes Agreement on committee authority Input f) Pre employment and annual medical check of workforce

Output a): Minimise the risks of accidents directly at Number of accidents at the mine site Quarterly report on Local authorities has the the mine site accidents necessary capacity and resources allocated for Output b): Minimise the risks of accidents related to Number of accidents related to the mine Emergency report response the mine operation operation from authorities Output c): Ensuring appropriate and timely Preparedness exercise Report – response in case of accidents and emergency authorities evacuation from mine site

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9 PUBLIC PARTICIPATION

9.1 Introduction

In 2014, the Greenland parliament, Inatsisartut, amended the Mineral Resource Act, which meant that new rules concerning public consultation came into force in July 2014. This means that mining companies, which start the SIA process after July 2014 will have to submit a project description for drafting the SIA report. The Project description will be subject to a public review, which will last for at least 35 days – a so called “Pre-hearing” of the project. However, due to Ironbark commenced the SIA process before July 2014 the Citronen Base Metal Project has not been subject to the aforementioned “Pre-hearing” (see Section 5).

Based on the Guidelines from the BMP (2009) and local knowledge, relevant stakeholders were identified for the Citronen Zinc project.

The stakeholder engagement activities for the Citronen Zinc Project have been split into two parts as some activities took place in 2010 when the SIA process was started, while follow-up activities took place in 2014.

9.2 Overview of stakeholder involvement 2010

In October 2010 Ironbark started the SIA process with assistance from Greenland Venture. A Greenland Venture representative and two Ironbark representatives held stakeholder meetings (in person and on the phone) in Greenland.

The objective of the stakeholder engagement was to identify parties with interests in the establishment of a mine at Citronen Fjord, and invite the stakeholders for their views on the mine.

Various municipalities, KANUKOKA (Greenland Association of Local Authorities) and the Ministry of Domestic Affairs, Nature and Environment, as well as the Bureau of Minerals and Petroleum were consulted. The four municipalities and KANUKOKA agreed that there was no basis for holding public meetings because the mine is not located in a municipality.

As well as the authorities, additional stakeholders were engaged including education Institutions (The Mining School), several CSOs (Employers Association, SIK and KNAPK) and representatives from private businesses.

The key issues raised during the stakeholder engagement in 2010 were:

 possibilities for local employment  request from the stakeholder to be informed on the different kind of jobs and needed qualifications  that transportation opportunities are important for the local involvement  opportunities for local business  request for collaboration with education institutions.

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Table 9.1 provides an overview of the stakeholder engaged in 2010. See Appendix 1 that includes detailed information from the stakeholder engagement in 2010 (included in the draft SIA Report dated February 2011).

Table 9.1 Overview of the stakeholder engaged in October 2010

Category Stakeholder Type of stakeholder engagement Self Government MLSA (former BMP) Meeting/workshop Mittarfeqarfiit (Greenland Meeting/workshop Airport Authority) National Institutions Environment and Nature Meeting/workshop Agency (Naturinstituttet) Municipalities Kommuneqarfik Sermersooq Meeting/workshop Qeqqata Kommunia Meeting/workshop Qaasuitsup Kommunia Meeting/workshop Kommune Kujalleq Meeting/workshop KANUKOKA Meeting/workshop Civil Society Employers Association of Meeting/workshop Organisations Greenland (GA) SIK Meeting/workshop KNAPK Meeting/workshop Education Mining School Meeting institutions Arctic Technology Centre Meeting Technical college Meeting Other institutions North Atlantic Cooperation Telephone conference (NORA) Manager of port Ilulissat Meeting Private companies Not individually identified. Public open meeting.

9.3 Overview of stakeholder involvement 2014

Follow-up stakeholder engagement activities took place in January/February 2014. The objectives of the stakeholder engagement activities were to update the stakeholders on the status of the project and to share the findings from the consultation with stakeholders in 2010. Additionally, the stakeholders were invited to propose initiatives which could increase the local involvement in the project (employment and business opportunities) in the light of the remote location of the project.

Before the phone interviews a detailed description of the project was distributed along with an invitation letter which clarified the objective of the interview and stated the questions to be answered during the call (Appendix 2). The interviews were held either in Greenlandic or Danish (by preference of the stakeholders).

The following questions were raised:

 What are your comments to the identified key aspects from the stakeholder engagement in 2010? (What would you add/delete?)  What are your comments to the planned initiatives from Ironbark in order to improve the local involvement?

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 Which initiatives does your organisation propose to Ironbark in order to increase the local involvement (local employment and local business)?  What are your comments to the list of stakeholders engaged in 2014 (see below)?

The key issues raised during the stakeholder engagement in 2014 were:

 One additional issue were raised adding to the issues from 2010: health issues (raised by the health authority).  There is a need for a Greenlandic transportation hub in order to ensure Greenlandic involvement on the project. However, in the project description which was distributed to the stakeholders, Nuuk was stated as a possibility. This was questioned and the majority of the stakeholders pointed at Kangerlussuaq as a more suitable transportation hub.  The possibility of involving settlements on the east coast of Greenland using the hub over Iceland was welcomed.  The share of local involvement in the construction phase should be higher than the planned 10 percent in order to ensure a high share of local involvement during the operation phase.  It is important to provide Greenlandic food at the site to retain local workforce.  Additional meetings with infrastructure authorities are needed for the project design.  Need to engage with education institutions.  Need for more cooperation with the local stakeholders (municipalities, local representatives from GA, SIK etc).  The stakeholder engagement activities in Greenland have developed over the past four years. There is a demand for more engagement activities now than in 2010.

Table 9.2 provides an overview of the stakeholders engaged in 2014. See Appendix 3 for details on the stakeholder inputs where received. It must be noted that not all stakeholders contacted replied. Minutes were prepared from all interviews and sent for approval by the stakeholder.

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Table 9.2 Overview of the stakeholder engaged in 2014

Category Stakeholder Type of stakeholder Time Comments engagement Self Ministry of Industry and Mineral Invited for engagement Dec 2013 Invitation sent out for an Government Resources interview, written answer sent from the Ministry to Ironbark Ministry of Industry and Mineral Phone interview 28 Jan 2014 Comments received from Resources (Department of Department of Industry Industry) Minerals Licence Safety Agency Invited for engagement N/A Declined participation in an (MLSA), former BMP interview due to being the licence authority Ministry of Environment and Invited for engagement N/A Declined participation as the Nature SIA was outside their area of expertise. Environment Agency for Mineral No discussion is planned for N/A EAMRA have been contacted Resources Activities (EAMRA) the SIA. regarding the EIA Ministry of Health and Phone interview 30 Jan 2014 Participation from both the Infrastructure Department of Health and the Department of Infrastructure

Teleconference with Department of Infrastructure Teleconference 12 Mar 2014 and Ironbark Ltd Ministry of Education, Church, Invited for engagement 24 Feb 2014 Comments noted Culture and Gender Equality Ministry of Fisheries, Hunting and Invited for engagement 24 Feb 2014 No response Agriculture Municipalities Kommuneqarfik Sermersooq Phone interview 24 Jan 2014 Comments noted Qeqqata Kommunia Phone interview 23 Jan 2014 Comments noted Qaasuitsup Kommunia Phone interview 20 Jan 2014 Comments noted Kommune Kujalleq Phone interview 21 Jan 2014 Comments noted KANUKOKA Phone interview 16 Jan 2014 Comments noted Self- Greenland Airport Authority Invited for engagement Mar 2014 No response Government (Mittarfeqarfiit) owned Tele Greenland Invited for engagement Mar 2014 No response businesses Air Greenland Invited for engagement Mar 2014 No response Royal Arctic Line Phone interview 24 Mar 2014 Comments noted

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Education The School of Metal and Invited for engagement Mar 2014 No response Institutions Mechanics The Mining School Meeting 4 Mar 2014 Comments noted Civil Society Greenland Business Association Phone interview 14 Jan 2014 Comments noted Organisations (GA) NUSUKA Phone interview 24 Mar 2014 Comments noted SIK Meeting in Copenhagen 6 Feb 2014 Comments noted KNAPK Phone interview 30 Jan 2014 Comments noted Greenpeace Invited for engagement 4 Mar 2014 Written comments received WWF Invited for engagement 6 Mar 2014 Written comments received ICC Invited for engagement 24 Feb 2014 No response Avataq Invited for engagement 24 Feb 2014 No response Timmiaq Invited for engagement 24 Feb 2014 No response Transparency International Invited for engagement 24 Feb 2014 No response Greenland Danish Arctic Command Invited for engagement 18 Mar 2014 No response Institutions Danish Maritime Authority Invited for engagement 18 Mar 2014 No response The police in Greenland Invited for engagement 19 Mar 2014 No response

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10 REFERENCES

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Bjerregaard, P. og Direktoratet for Kultur, 2004, Uddannelse, Forskning og Kirke. Folkesundhed i Grønland. INUSSUK – Arktisk forskningsjournal.

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Bjerregaard, P. og Aidt E.C, 2010. Levevilkår, livsstil og helbred. Statens Institut for Folkesundhed. København.

EU Commission, 2013, Study to evaluate Higher Education in Greenland, Report. Available at: http://naalakkersuisut.gl/~/media/Nanoq/Files/Attached%20Files/Uddannelse/DK/Uddannelsesplan er/Study%20to%20evaluate%20Higher%20Education%20in%20Greenland%202013.pdf

Hamilton C. and Rasmus O. Rasmussen, 2010. Population, Sex Ratios and Development in Greenland. ARCTIC VOL. 63, NO. 1 (MARCH 2010) P. 43–52. Available at: http://pubs.aina.ucalgary.ca/arctic/Arctic63-1-43.pdf

Hansen and Andersen, 2013: Hjemløshed i Grønland, Knud Erik hansen and Hans Thor Andersen, 2013, Sbi, ISBN: 978-87-92739-34-6, available at: http://www.sbi.dk/boligforhold/boliger/hjemloshed-i-gronland/hjemloshed-i-gronland-1

Inuuneritta II, 2013, Naalakkersuisuts strategier og målsætninger for folkesundheden 2013-2019, available at: http://www.paarisa.gl/home/inuuneritta.aspx?lang=da

Kapel, H. 1994. Citronen Fjord, Nordgrønland. Arkæologisk rekognoscering udført I forbindeldse med et tilsynsbesøg. 20pp.

Landslægeembedets årsberetning 2011 & 2012, available at: http://naalakkersuisut.gl/da/Naalakkersuisut/Departementer/Landslaegeembedet/Aarsberetninger

Leopold, L. B., Clarke, F. E., Hanshaw, B.B. and Balsley, J. R: A procedure for evaluating environmental impact. Geological Survey Circular 645, government Printing Office, Washington, D.C. 13 pp, 1971

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Ministry of Finance, 2012, Debt and Investment Strategy, Aningaasaqarnermut Naalakkersuisoqarfik, spring session/46. Available at: http://naalakkersuisut.gl/~/media/Nanoq/Files/Attached%20Files/Finans/DK/Gaelds%20og%20inve steringsstrategi/GI-strategi%20_til%20tryk_ENG_hele%20bet%C3%A6nkning.pdf

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MTHojgaard and Landsvirkjun Power, December 2010. Citronen Fjord Hydroelectric Project in North Greenland Site Visit July 2010. LP-2010-023.

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Naalakersuisut, 2013, Politisk-Økonomisk Beretning 2013, Departementet for Finanser og Indenrigsanliggender, available at http://naalakkersuisut.gl/da/Naalakkersuisut/Departementer/Finanser-og- Indenrigsanliggender/Politisk-Oekonomisk-Beretning

NANOK 2013, Feltrapport fra rejsen til Nordøstgrønland 2013, Available at: http://www.xsirius.dk/files/Feltrapport%202013%20DKy.pdf

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Rischel, J. Geografisk dialektfordeling og lydforandring i grønlandsk. Nuuk, 2007, view 21/01/14: http://www.oqaasileriffik.gl/content/dk/om_gronlandsk_sprog

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Det Grønlandske Erhvervsregister, view 15/01/14: www.ger.gl

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Det Grønlandske Sundhedsvæsen, view 27/01/14: www.peqqik.gl

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Courts of Denmarkm wiex 24/01/2014: www.domstol.dk http://www.domstol.dk/ Income Distribution Statistics, view 4/02/2014: http://epp.eurostat.ec.europa.eu/statistics_explained/index.php/Income_distribution_statistics

Danish Defence: www.forsvaret.dk

Nora Region Trends, 2013, view 20/01/2014: www.noraregiontrends.org/economynews/article/greenlands-economy-lack-of-educated-workforce- but-possibly-bright-future-the-mining-industry/87/neste/1/

Peqqissaanermik Ilinniarfik, view 27/01/14: www.pi.gl

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Statens Serums Institut. Abortregistret, Available at: http://www.ssi.dk/Sundhedsdataogit/Registre/Abortregisteret.aspx

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Appendix 1 Public participation summary from SIA (Draft) Feb 2011.

Public participation In October 2010, all municipalities, Kanukoka and the Ministry of Domestic Affairs, Nature and Environment, as well as the Bureau of Minerals and Petroleum were consulted to learn the views of public authorities concerning local engagement in the mining project in Peary Land. The four municipalities and Kanukoka (Greenland Association of Local Authorities) agreed that there was no basis for holding public meetings because the mine is not located in a municipality.

Selecting stakeholders Appendix 2 of the BMP SIA Guidelines provides a list of suggested relevant stakeholders.

A list of stakeholders was drawn up during the scoping phase and, as part of the SIA process, discussions were conducted with selected stakeholders concerning their expectations and requirements.

Stakeholder meetings A series of stakeholder meetings were held between 13 and 19 October 2010 and carried out by either the SIA consultant alone or together with Ironbark Managing Director Jonathan Downes and Engineering Director Gregory Campbell.

The meetings content differed, but were based on the following points of agenda:

 purpose of the meeting (explanation of the SIA and associated guidelines and the requirement to involve stakeholders)  presentation of the Citronen Zinc Project (enclosed)  questions and comments from members of the audience and  SIA issues (the SIA consultant provided a brief introduction to the general situation in Greenland for each issue): a. demographic trends b. labour market, employment and unemployment trends c. education d. income and distribution of income e. business development and f. other factors.

Meetings with representatives for the Central Administration of the Self Rule Ironbark has held regular meetings with the BMP to discuss the progression of the Project.

The Project will take place in a national park. Ironbark was introduced to the existing administrative model for the national park and to possible future models at a seminar held at the Greenland Institute of Natural Resources, Pinngortitaleriffik, in Nuuk from 20 to 21 May 2010.

Mineral resource activities within the boundaries of the national park were the prime area of focus at the last-mentioned meeting.

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Meetings with Kanukoka (association of local governments) and the municipalities Stakeholder meetings were held with all four municipalities and the Greenland Association of Local Governments (Kanukoka).

The municipalities and Kanukoka were primarily focused on the possibility of employing Greenlanders at the mine. The participants’ main concern was the high percentage of Greenland’s workforce that do not have an education with trade qualifications.

One representative pointed out that Greenlanders working on seagoing trawlers were accustomed to being away from their families for weeks at a time – as they would be if they worked at the Project. Participants were particularly pleased that workers could work at the mine without having to move from their current place of residence.

There was a widespread perception that a new mine in Peary Land would have a great socio-economic impact on Greenland. Kanukoka’s representative believes that it will be important to hold public meetings in the future. This will ensure a more positive image of both the mine and Ironbark.

One representative expressed that the municipalities lacked information about mineral resource activities, which meant they did not know enough about local mineral projects, for instance. The municipalities expressed a wish to be continuously informed of the types of job available at the mine and about the working conditions.

One representative requested Ironbark to be aware of the need to establish traineeships for ARTEK students.

The individual municipalities also expressed a wish that flights to the mine would depart from their local airports.

Several people pointed out that seasonal variations in the Greenland labour market would provide unique opportunities for recruiting Greenland labour during the winter in particular.

Both Kanukoka and the individual municipalities expressed a general wish for cooperation between the mine and local areas.

Meetings with local business development councils and business committees Stakeholder meetings were held with Qeqqata Business Development Council, the business committee in Kujalleq Municipality, business department of Kommuneqarfik Sermerooq and the chairman of the business committee from Qaasuitsup Kommunia.

Again, the primary focus was on recruiting Greenland labour for the mine. Participants expressed a wish for Greenland businesses to merge, for instance, to increase their size to give them the capacity to take part in large-scale mineral projects. Small and medium- sized Greenland business should focus on becoming external suppliers to the mine. For instance, most of the food supplies will be imported, but it is important to focus on using Greenland businesses as external suppliers of local products.

Participants also stated that local businesses should receive more information about mineral projects. The general opinion seems to be that virtually all companies should be active in this new sector.

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Meetings with employer associations and trade unions Meetings were held with the Employers’ Association of Greenland (Grønlands Arbejdsgiverforening, GA), the Greenland association of fishermen and hunters (KNAPK), and the S.I.K. trade union.

GA focused on efforts by Greenland companies’ to develop Corporate Social Responsibility (CSR). The organisation wanted to focus on defining what it means for Greenland businesses to become more competitive, cf. the provisions of the Mineral Resources Act concerning preferential practices. In addition, the organisation focused on the fact that certain foreign companies have expressed a wish to import cheap foreign labour. If this were to be accepted, it should be possible for all companies to use cheap labour.

Concerns about the possibility of lead contamination from the mine were expressed at the meetings, as Greenland has already had bad experiences with lead contamination.

KNAPK pointed out that the mine could possibly recruit labour from Qaanaaq, because notably KNAPK members from this settlement had great difficulty in earning an acceptable income.

KNAPK also pointed out that there were very positive experiences from recruiting fishermen and hunters for the former Marmorilik zinc and lead mine. Working in shifts with six weeks at the mine and three weeks at home still enables fishing and hunting during the three weeks they are home.

Two meetings were held with S.I.K.’s coordinator for the mineral resource sector. S.I.K. has prepared a comprehensive document which provides a precise presentation of the union’s wishes relating to general developments in the mineral resource sector. This work has provided an important basis for the analyses in this SIA report, because like the two other organisations mentioned above, S.I.K. has an extensive contact network and is very knowledgeable on Greenland’s business and labour market situation.

In the view of S.I.K., it is important to focus on time-related planning in the future in terms of when various mineral projects are initiated to ensure that the Greenland workforce can be reasonably utilised.

As the main union, S.I.K. wishes to negotiate collective agreements with Ironbark and its external suppliers, including the implementation of a minimum wage. The collective agreements should also include provisions for basic rights, working hours, working conditions, pension schemes, notices of termination, access to leisure activities, a union representative scheme and provisions governing absence, illness-related absence and leave.

S.I.K. thinks it is unfortunate that the SIA process does not include the exploration phase.

S.I.K. believes that many agreements are entered into already during the exploration phase, meaning that Greenland companies and thus Greenland workers could miss out on new opportunities.

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S.I.K. wishes to bring special focus to bear on the problems arising when the immigration of foreign workers increases dramatically. In addition, the union wishes to focus on the rights of migrant workers. This includes both basic human rights and the problem associated with the fact that their payment of income tax is actually a resource tax and does not entitle these workers to benefit from welfare services in Greenland. S.I.K. thinks it is important for migrant workers to be informed of their rights. In this context, S.I.K. wants to have the Workforce Regulation Act in Greenland brought up to date.

S.I.K. proposes that the introduction of a premium scheme for companies that take the initiative to provide educational/training opportunities for Greenland workers, e.g. training at the mine itself, should be considered.

Meetings with private-sector businesses Ironbark met representatives from Greenland’s private-sector businesses at public meetings during trips to Nuuk, Sisimiut and Aasiaat.

The Qeqqata Business Development Council invited local business people in Sismiut to an after-work meeting with Ironbark representatives.

Ironbark gave a detailed presentation to these business representatives and received many relevant questions about procedures relating to the upcoming collaboration with the mine. In a few instances, this gave rise to a specific mutual wish to receive additional material.

Meetings with education institutions The most important partner for the upcoming Project will be the newly established mining school in Sisimiut. A meeting was held with the head of the mining school who presented the school’s activities, and Ironbark presented the project. Ironbark representatives were very pleased with the procedures and quality assurance relating to the common-core courses and study programmes. Both parties expressed a mutual wish for close collaboration and the ongoing sharing of information.

Meetings with other stakeholders The Project will comprise logistics and cooperation between Greenland, Iceland (especially Akureyri), and Norway (Svalbard). For this reason, the SIA stakeholder trip also included NORA, the North Atlantic Cooperation organisation. NORA is a border region committee under the Nordic Council of Minister’s regional policy collaboration program which serves as intergovernmental collaboration.

NORA is funded by the Nordic Council of Ministers, supplemented by national contributions from each of the collaboration's four participants (the Faroe Islands, Greenland, Iceland and coastal norway).

The Nordic framework and project-orientated modus operandi provide a solid basis on which NORA can initiate transnational collaboration based on Nordic objectives and values, and at the meeting between NORA and Ironbark, the parties agreed there is a basis for future collaboration.

At a later date, there will be a more detailed discussion of possibilities and the need for working together on business development, recruitment and education involving Greenland and one or more of the regions represented in NORA.

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Appendix 2 Invitation letter for stakeholder engagement in 2014.

Dear XXX

The Australian based company Ironbark Ltd is developing the Citronen Zinc Project (the Project), a zinc and lead mine at Citronen Fjord in North Greenland.

The objective of this e-mail is to up-date stakeholders on the Project and to invite stakeholders for inputs in finalising of the SIA Report. Ironbark Ltd has engaged the company Grontmij A/S to assist in the finalisation of the SIA Report which includes these stakeholder engagement activities.

In 2010 Ironbark started the SIA process with assistance from Greenland Venture. Stakeholder meetings took place in the autumn of 2010. The engaged stakeholder were authorities (National and Local), Education Institutions (as the Mining School), CSO (as Employers Association, SIK and KNAPK) and representatives from private businesses.

The key issues raised during the stakeholder engagement in 2010 were:  What are the possibilities for local employment?  A request from the stakeholder to be informed on the different kind of jobs and needed qualifications  The transportation opportunities is important for the local involvement  What are the opportunities for local business?  A request for collaboration with education institutions

Follow-up stakeholder engagement activities are planned for January 2014. The objective of this stakeholder engagement is to up-date the stakeholders on the status of the project and to share the findings from the assessment with the stakeholder. Furthermore, the stakeholders will be invited to provide input to recommendation in order to increase the local involvement in the project (employment and business opportunities), in the light of the remote location of the project.

Attached is a project brief which describes the project in details as well as a brief overview of the findings of the EIA.

In the beginning of the construction is it anticipated that 90% of the workforce will be foreign employees. However once construction is finished and as the project progresses, Ironbark aims to increase the local percentage of employment to 50% by year 3 and 90% by year 7.

Ironbark is planning the following initiatives in order to increase the local involvement of the Project:  Planned transportation route for local employees from Nuuk direct to Citronen.  On-the-job training activities through the whole project starting during the construction with the use of NFC’s expertise. NFC has excellent proven experience in training from other projects in Kazakhstan and Zambia where they have achieved a rate of 95% of local employees by 3 years.  Early discussions with the Greenlandic authorities to encourage and support collaboration on training programs for the local work force.  Procurement and contract packages for goods and services will be prepared and issued to the pre- qualified and approved bidders in Greenland as well as overseas.  Outsourcing of activities related to transportation of goods and staff as well as service of the camp, including catering, cleaning of the camp and offices, and laundry. Where possible and competitive, local businesses will provide these services.  Servicing of the camp will be tendered. Such services include catering services, cleaning, laundry and similar tasks. Arrangements can be done by the catering company with local fishers and hunters for the provision of fish and meet for traditional food. Moreover, there will be a number of services provided for the mine when contracting local tradesmen (carpenters, engineers, electricians etc.). Also, IT services could be requested during the operation and provided locally.

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Question for the stakeholder engagement

The interviews to be conducted in January 2014 will take point of departure in below questions. Interviews can be done in Danish and Greenlandic:  What are your comments to the identified key aspects from the stakeholder engagement in 2010?  What would you add/delete?  What are your comments to the planned initiatives from Ironbark in order to improve the local involvement?  Which initiatives doES your organisation propose to Ironbark in order to increase the local involvement (local employment and local business)?  What ARE your comments to the list of stakeholders engaged in 2014 (see below)?

Stakeholders to be engaged

Based on the previous stakeholder engagement, the remote location of the project and the key findings will the following stakeholders be engaged:

 Ministry of Industry, Resources and Labour  Minstry of Health and Infrastructure  Ministry of Environment and Nature  BMP  KANUKOKA  Qaasuitsut Kommunia  Kommuneqarfik Sermersooq  GA/SIK/KNAPK The Social Impact Assessment process

The SIA process includes identifying, analysing, monitoring and managing the social change process that will be initiated by the development of the project. Therefore, the SIA focus on involvement of local community and other stakeholders during the process of completing the assessment. In 2010 stakeholder engagement activities took placed followed by a preparation for a draft SIA Report which has been discussed with the BMP.

A revised SIA is expected to be finalised public available during spring 2014.

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Appendix 3 Detailed responses from stakeholder involvement in 2014.

Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders Greenland Self Ministry for Teleconference  Current legislation (law: BL 5-24, 2nd edition) requires that initial Tele conference between Government Infrastructure entry into Greenland is made at an international airport that has Department of the authority and capacity to conduct immigration and customs Infrastructure, Ironbark checks. Ltd. and Grontmij A/S.  If Ironbark intend to fly employees directly to Citronen Fjord from Minutes has not yet been outside of Greenland, it will be necessary to have officials on site approved by the to conduct immigration and customs checks and have the relevant Department. authorities approve this procedure.  All of the airports run by Mittarfeqarfiit are currently approved as international airports, allowing first entry into Greenland. Military airports, such as Station Nord, have in the past been given permission to conduct border control.  If/when Ironbark wants to build an airport at the site, it is expected that they will have to apply for exceptions to ICAOs standard aviation rules.  It is important for emergency plans to take into account the remoteness of the location and the long distances that would have to be covered by the national emergency response system.  The Danish Transport Authority that has legal jurisdiction over airports and air travel in Greenland. The Danish Immigration Service is responsible for immigration policy and border control.  The use of Station Nord and the extent to which it is possible to use the airport during construction / beginning of operation must be discussed with Arctic Command.  Ironbark can charter any airline they wish who is certified by the Danish Transport Authority, however if they want to use companies with a lot of local experience relating to the legal requirements and the conditions and terrain in Greenland, then there are three operators who operate extensively in Greenland today: Nordland Air, Air Iceland and Air Greenland.  It is not possible to fly directly from Kangerlussuaq to Citronen with a Dash 8.  There will most likely be a need for satellite based internet and phone service (Ironbark: The satellite system is very slow and

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Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders highly expensive, using this system will limit employee’s access to internet). As Tele Greenland has monopoly for establishing telecommunication in Greenland it is recommended that Ironbark investigate their options in cooperation with Tele Greenland.

Royal Arctic Line has a monopoly to ship freight to and from Greenland (Royal Arctic Line holds the right of first refusal after which other companies can bid on or be offered the job). There are some exceptions to the monopoly which can be fully explained by the Head of Section of Maritime Affairs in the Department of Health and Infrastructure Ministry of Health and Phone interview  Arctic Command Health aspects:  It is the Danish Infrastructure  Police  Need of a comprehensive health screening procedure before Transport Authority  Danish Ministry of employment (including vaccination of foreign employees). The who is the authority for Justice content of this health check to be coordinated with the Health aviation in Greenland.  Tax administration Authority.  Danish transportation  Foreign health personnel must be authorised to work in authorities Greenland.  Danish Maritime  Ironbark must set up arrangements with health- and SAR Authorities authorities with regard to possible emergencies  Agreement has to be established on health procedures when health treatment is needed outside the mine.

Infrastructure aspects:  If ‘first-entry’ to Greenland of foreign personnel is at Citronen there must be police/custom personnel at the site.  The use of Station Nord has not investigated further (due to limited resources and fuel).  Air Greenland (the local operator) do not own planes that can fly from Nuuk/Kangerlussuaq to Citronen one-stop.  There exists restricted legislation on flights in Greenland (amount of fuel on board, and access to two alternative airports).  Evacuation has to be planned due to limited airplane possibilities. (usually King Air helicopter is used).

Other comments on project design  Telepost has a concession to install tele- and internet connections outside towns and settlements – Telepost should be contacted to identify possibilities,  Questions whether Royal Arctic Line can deliver all the needed

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Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders services in terms of ships, barges, ice-breaking vessels etc. Municipalities Municipality of Phone interview None  Questions the project designs use of Nuuk as hub in Greenland;  The municipality is Qaasuisup recommend that Ironbark consider using the new international interested in airport Illuissats (expected to open in 2018). cooperating with  There is a need to rethink the current education programs. A Ironbark on combination of “at the site training” and modules at the mining training/skill-upgrading school is recommended. of e.g. hunters/fishers  Local employees and companies should be involved in the and unskilled workers construction phase, in order to prepare these for the jobs under to positions at the mine the operation phase.  It will benefit local companies to be part of internationally led consortia.  In order to contract local companies the municipality suggests that i) The tendered packages are concrete and that the requirements are well described. ii) That tenders are announced in due time. Municipality of Phone interview None  The public opinion with regard to mining project has changed Sermersooq since 2010 and the need for public involvement has increased.  To obtain high local involvement during construction it is important to focus on the involvement already in the construction phase (ensuring a better transition).  The plan with transportation hubs in Greenland and Iceland is positive, especially interesting if the Icelandic hub can lead to involvement of the eastern towns and settlements.  In order to recruit locals it is important that the mine camp offers cultural activities and serves Greenlandic meals.  Need of project specific training programmes, also aiming at higher positions

Municipality of Phone interview  Education sector,  Greenlandic hub very important to ensure high local involvement;  The municipality will be Qeqqata especially the mining questions the project designs use of Nuuk as hub in Greenland; an important point of school. recommends Kangerlussuaq. entry with regard to  Greenland  In order to recruit locals it is important that the camp area suits recruitment of local Contractors, Greenlandic traditions and serves Greenlandic meals. employees. especially with regard  The camp must offer good communication (internet and phone) so  The business council to local recruitment employees can keep in contact with friends and family. will be an important and possible  Ironbark should cooperate with the mining school in developing point of entry with cooperation/synergie training programs that fits their needs for capacities, preferably regard to recruitment of s. trainings should combine time at the mine and at the school. local businesses.

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Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders

Municipality of Phone interview  Education sector,  It might be a challenge to reach the set targets for local  The municipality is very Kujalleq especially the mining employment, especially if other mining projects placed closer to interested in the project school. cities and settlements starts operating (need of competitive and the possibilities it  Regional salaries/conditions). can give to locals in departments of GA,  Necessary that Ironbark are clear on the specific qualifications terms of employments KNAPK, SIA. that employees should have, in order for the municipality to and opportunities for  It should be prepare future employees for positions at the mine. local businesses. considered to include  It should not only be quantity of local employment that is “the West Nordic measured, but also quality – it would be very interesting if the Council” or trade project offers opportunities for Greenlandic specialists and/or mid- funds in the Faroe level managers. Islands and/or  Very relevant if Greenlandic companies can join forces with Iceland – regional international companies to ensure international standards and project. give the smaller Greenlandic companies an opportunity to be involved.

KANUKOKA Phone interview  All municipalities  Main focus for KANUKOKA on the project is that it ensures as should be involved. high local involvement as possible and ensures access to training/  Educational education. institutions.  In terms of Greenlandic employment and volume of trade it will be beneficial if the mine life is longer than 12 years.  Positive and important that the project design includes a Greenlandic hub for transportation.  Use of Greenlandic food products will increase the positive effects in Greenland, especially for fishermen and hunters.  Positive with high ambitions for local employment, however today there is only limited access to qualified workers = focus on education.  It must be considered how families “delivering” workers to the mine can be supported while one member of the family is away.

Organizations Greenlandic Phone interview  The mining school.  Positive with flights from Greenland and Iceland, will increase employers'  Business councils. possibilities for local businesses and employees. association (GA)  Positive with high ambitions for local employment, however the 90 % will be difficult to reach if other more accessible mines start operating.  Local visibility of Ironbark is very important, for instance via an office in Greenland.  The shorter rotations, the easier it will be to attract local

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Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders employees.  Ironbark must focus on attracting young employees who are willing to go through a training program and willing to move.  It will be easier to involve local businesses in the operation phase if they are also involved in the construction phase.  Necessary with enough good time for pre-qualification of companies so that the Greenlandic companies have time to prepare and obtain relevant certifications. competencies etc.

KNAPK Phone interview  Most important to ensure most local employment right from the beginning.  Desirable that all sorts of courses, relevant for the mining projects are applied, so Greenland can train the necessary labor.  Achieve agreements via contracts with local fisherman and hunters, who can deliver fresh supplies.  Sign a three-party contract between Greenland, KNAPK and Ironbark Ltd., Citronen Zinc Project, which involves compensations for the fisherman and hunters in case of pollution or other disasters.  Take consideration of the remote environment and the migration of the animals year around.  Take consideration of the sea ice in construction of roads.

SIK Interview  English should not be a barrier for employment at the project.  To get as much as local employment, 3-5 projects in Greenland at the same time are preferable.  Take consideration of the remote sight of the project, when employing local workforce, this means early planning to prepare local workforce.  Important to establish collective agreements.  A problem that the SIA process does not involve the exploration process.  Preferably establishing ‘on-the-job-training’ especially for the young people. Make use of the experiences from the Nordic countries for example.  SIK would like to have common collective agreements for all the Nordic countries (Greenland, Island, Norway, Denmark and Faroe Island).

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Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders NUSUKA Phone interview  Difficulties in recruiting and retention of local staff, due to the remote location of the project.  Nusuka find it unrealistic to aim for having 50% of local staff by year 3 and 90% by year 7. It’s very ambitious.  Experience from Canada shows that a more realistic figure is about 20%.  Nusuka proposes that Ironbark should focus on education and training activities.  Small companies, who are members at Nusuka could act as sub- contractors to bigger companies who would have the contract with the mining companies.  As stated by Nusuka – it must be a mistake that the staff should cover the cost for their transportation to Kangerlussuaq - this is unrealistic as locals would not be able to cover these costs.

Mining School Interview  Facilities such as IT/communication are very important, due to the remote site of the project.  Students at the mining school have experience in being away from home for a longer period.  Zero tolerance for drugs must be very visible, from Ironbark and other companies.  The Ministry of Education should know that Ironbark’s project is underground.

Greenpeace Written comments  Would like that the mine, as much as possible, will be a benefit for the Greenlandic population.  Greenpeace encourages, however, for a zero tolerance for the discharge of residues, chemicals, etc. to the environment.

WWF Written comment  Generally, the concerns are related to the usual conditions: secure shipping lanes in icy waters, deposits of fossil fuels, leakage from landfills of waste, raw rock and tailings to the fjord, energy and possible alternatives to fossil fuels, disturbance of wildlife in the area.  The social consequences are special because the project here is so remote where there is no fixed habitation. Despite this, WWF hopes that the project will provide jobs for Greenland workers and also trainees.  It is vital that information is shared early on, already in the scoping

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Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders phase, to avoid the public feeling overwhelmed by the rapid consultations.  There should be a rich summary of the EIA and SIA report, which reflects the technical reports in a balanced way.  Civil society organisations, community organisations and others should be invited to join in the debate at public meetings.  Perhaps Ironbark could open up a panel debate in which civil society organisations, environmental organisations and fishing and hunting organisations and research world could be represented.  Perhaps Ironbark in dialogue with the Government or civil society could help to balance expectations.

Royal Arctic Line Phone interview  Very difficult area to operate in, no commercial shipping operates today or passes through this area today.  The main challenge to operate in the area is not operating in the Fjord but at sea (due to drifting multi year pack ice).  Icestrengthed bulk carriers needed for operating in this area is for the time being very limited in the market. Special ice strengthen barges as described in the project probably have to be constructed first. Ironbark should consider the high costs for logistics in this project as well as different density of pack ice from year to year may influent on how much cargo in and out of Citronenfiord can variate a lot.  Potential operators (including RAL) may see the project as a high risk project in view of logistics at sea.  The project is placed in a very sensitive environmental area.  RALs preliminary assessment is that the window for shipping that Ironbark operates with is very optimistic and unlikely to be possible all years.  It should be noticed that the type of ice in North Western Greenland is different to the type of ice that materials to and from mines in Northern Canada are shipped through. Pack ice versus winter ice.  Of the two solutions presented by Ironbark RAL finds the solution with barges more likely than the solution with bulk carriers.  A number of legal and practical aspects of transport of goods in North East Greenland.  RAL holds a concession for supplies to and from Greenland by sea.

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Category Stakeholder Methodology Identification of Key points stated Other comments additional stakeholders  The waters in North Western Greenland have not been surveyed, which leads to different terms of insurance for the operators by sea and may be big issue for this project.  The projects should consider the impact that introduction of the IMO Polar Code may have on this project.  RAL finds the project very interesting and would be interested in having a role on the project and local knowledge should be taken into consideration.  RAL offers consulting services to mining companies in developing solutions for shipping.

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