Stakeholder Engagement Plan Ilovica-Shtuka Gold-Copper Project DRAFT March 2017
SEP – Ilovica-Shtuka Project – Final Draft March 2017 1
Contents
Abbreviations & Glossary of Terms
1. INTRODUCTION...... 3
2. PROJECT OVERVIEW ...... 5
3. LEGAL & POLICY FRAMEWORK FOR STAKEHOLDER ENGAGEMENT ...... 7
4. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ...... 9
5. COMMUNICATION METHODS ...... 10
6. IDENTIFICATION OF STAKEHOLDERS & ENGAGEMENT PLAN ...... 12 6.1. Stakeholder Identification ...... 12 6.2. Engagement Plan per Stakeholder Group ...... 14
7. INFORMATION DISCLOSURE & STAKEHOLDER ENGAGEMENT PROGRAMME ...... 26
8. GRIEVANCE REDRESS MECHANISM ...... 29
9. MONITORING & REPORTING ...... 30
10. CONTACT DETAILS & RESPONSIBILITY FOR SEP IMPLEMENTATION ...... 30 Figures
Figure 1 Local Setting of the Ilovica-Shtuka Gold-Copper Project ...... 5
Tables Table 1 Summary of Stakeholder Groups ...... 12
Table 2 Engagement Plan per Stakeholder Group ...... 14
Boxes Box 1 Stakeholder Engagement Plan (SEP) ...... 3
Box 2 Summary of Public Consultation & Disclosure Process on Spatial Planning & Environmental Documentation ...... 7
Annexes Annex 1 Euromax Grievance Form
ABBREVIATIONS AoP Agency of Pastures ME Ministry of Economy AR Access Road MOEPP Ministry of Environment and Physical Planning EBRD European Bank for Reconstruction and MoC Ministry of Culture Development EOX Euromax MoTC Ministry of Transport and Communications E&S Environmental & Social OHL Overhead Line EIA Environmental Impact Assessment ESIA Environmental & Social Impact Assessment NTFP Non-Timber Forest Products ESP Environmental & Social Policy NTS Non-Technical Summary FC Forestry Company PAP Projected Affected Person FGD Focus Group Discussion PE Public Enterprise IFC International Finance Corporation PLC Public Liaison Committee KII Key Informant Interview PR Performance Requirement km kilometre, used to identify length PS Performance Standard LAR Land Acquisition & Resettlement RAP Resettlement Action Plan LARF Land Acquisition and Resettlement Framework SEP Stakeholder Engagement Plan LRP Livelihood Restoration Plan MEPSO Macedonian electricity transmission network TBC To Be Confirmed operator MoAFWE Ministry of Agriculture, Forestry and Water TMF Tailings Management Facility Environment
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1. INTRODUCTION Euromax Resources Ltd. is a public company incorporated in British Columbia, Canada, listed on the TSX Venture Exchange and operating in Macedonia through its subsidiary Euromax Resources DOO Skopje (“Euromax”). Euromax has a major mining development project in Macedonia which focuses on building and operating the Ilovica-Shtuka Gold-Copper project (the “Project”).
The Ilovica-Shtuka Gold-Copper Project is a proposed copper and gold mine with supporting facilities located in southeast Macedonia, approximately 180 km south east of Skopje, 18 km east of Strumica and 15 km west of the border with Bulgaria.
The European Bank for Reconstruction and Development (EBRD) is contributing finance to the Project and is currently the largest Company shareholder with 19.9% ownership of Euromax. The Project is being developed by Euromax in line with Macedonian legislative requirements and those of EBRD, including EBRD’s Environmental and Social Policy (20141) and Performance Requirements (PR), such as PR 10: Information Disclosure & Stakeholder Engagement.
Since the Project may also seek finance from institutions which abide by the Equator Principles, the Project will also be compliant with the International Finance Corporation’s (IFC) Performance Standards (PSs) on Environmental and Social Sustainability, notably the Stakeholder Engagement requirements within PS1: Assessment and Management of Environmental and Social Risks and Impacts2.
Box 1 Stakeholder Engagement Plan (SEP) This Stakeholder Engagement Plan (SEP) outlines the approach and actions Euromax will undertake for engagement with stakeholders and local communities about the Project and the related land acquisition programme. The SEP includes a grievance redress mechanism for stakeholders and people to raise their concerns about the Project. A previous SEP (SEP 2015) was disclosed during the Environmental Impact Assessment (EIA) process; this SEP shall supersede previous documents and is a Project wide document. The SEP shall be a live document and will be updated periodically by Euromax.
An Environmental Impact Assessment (EIA)3 for the Mining Project was conducted on the Project according to national legislation and submitted for approval to the Ministry of Environment & Physical Planning (MOEPP) on 26.04.2016. A Non-Technical Summary (NTS) of the EIA summarises the Project, the findings of the environmental and social investigations conducted and the risks identified. Open Houses were held in the Municipalities of Bosilovo and Novo Selo on 17, 18th and 19th May 2016 and the official Public Hearing of the EIA was held in the same municipalities on 23rd June 2016. The Strategic Environmental Assessment (SEA) Report on the urbanization process of the Concession Area has been prepared, and submitted to the MOEPP in August 2016, with the Public Hearings held in the municipalities of Novo Selo and Bosilovo on 20th September 2016.
The Project is now completing an Environmental and Social Assessment (ESIA) in line with EBRD PR and IFC PS, which is due to be finished by the end of 2016. This will be disclosed to Stakeholders through the Euromax website (in English) and through an extended Non-Technical summary (NTS) (English and Macedonian) which will include a summary of the key differences between the EIA and the ESIA. Copies of this will be presented to Ministries, local government authorities (Municipalities), key institutional stakeholders such as Strumicho Pole Water Management Company and the local Forestry Companies and with communities through the Information Centre, Public Liaison Committee and other community meetings. In particular, key Management Plans will be disclosed to the municipalities who will be involved in their implementation, and to the Public Liaison Committee. A number of Technical Working Groups may be set up to provide input and feedback
1 http://www.ebrd.com/news/publications/policies/environmental-and-social-policy-esp.html
2 http://www.ifc.org/wps/wcm/connect/3be1a68049a78dc8b7e4f7a8c6a8312a/PS1_English_2012.pdf?MOD=AJPE RES
3 The Macedonian legal framework uses the term EIA (environmental impact assessment), whereas the international community uses the term ESIA (environmental and social impact assessment). The terms are interchangeable.
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on the MPs and their implementation. The ESIA will not be disclosed until the EIA has passed through the approvals process in Macedonia.
The land acquisition process is currently underway, and a Land Acquisition & Resettlement Framework (LARF) has been developed and disclosed to guide and document this process.
This Stakeholder Engagement Plan (SEP 2016) and the previous SEP (2015) for the EIA process and the other key environmental & social (E&S) project preparation documents – the EIA, NTS and LARF - are uploaded on the Euromax (EOX) websites (http://www.euromaxresources.com/ in English and http://euromaxresources.mk/ in Macedonian language).
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2. PROJECT OVERVIEW The Ilovica-Shtuka Gold Copper Project is a proposed open pit mine that will be located near the villages of Ilovica and Shtuka on the slopes of the Ograzden Mountain, in the municipalities of Bosilovo and Novo Selo. The proposed Project is located 15 km from the largest urban centre in the region, the town of Strumica. Figure 1 shows the Ilovica-Shtuka Mine Concession Area, the local communities and surrounding area.
The ‘on-site’ Project mining facilities for the Project, include the open pit, processing plant, tailings management facility (TMF), warehouses, offices and storage areas, water and power supply and internal site roads which are to be located within the Mine Concession Area. In addition to the ‘on-site’ mining facilities within the Mine Concession Area the Project will require the development of some ‘off-site’ infrastructure, including:
Access Road: The new access road linking the entrance of the mine site with the existing Macedonian A4 State road will run approximately 7 km across an area of many privately owned, largely arable farming plots. This will be done in 2 phases, the initial phase providing a temporary access road that will be developed from the A4 and will follow an existing track along the eastern bank of the Shtuka river and around the eastern side of Shtuka village. The temporary access road will be used as access during the initial construction phase of the Mine and during the construction of the permanent access road.
Overhead Line (OHL): 2x 110kV overhead line (OHL) power connections to two existing sub-stations – one in Sushica (approximately 7 km south of the mine site) and the second in Berovo (30 km north of the mine site).
Water Supply Infrastructure: Though water recirculation and use of surface water within the Project footprint will be maximised, it will also be necessary to carry out reconstruction of the existing Turija water canal as a closed pipeline, for additional raw water supply. This water pipeline (shared pipeline) would run approximately 15 km along the existing canal corridor from the Turija reservoir to the water treatment plant located in Ilovica, then onto the Ilovica reservoir, which will be used for temporary storage before water is pumped up to the mine site. The reservoir will continue to provide irrigation water to the local communities.
Figure 1 Local Setting of the Ilovica-Shtuka Gold-Copper Project
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Project Schedule: The Project construction phase is expected to commence in 2017 and take around 2 years with operations continuing for a 20-year life of mine. Operations are expected to commence in 2019 and the main product of the mine, copper concentrate, will be trucked to a smelter in Bulgaria via the A4 state road.
Project Site Setting: The Mine Concession Area is currently a largely forested area under a combination of State, mixed State/private ownership, with licenced and un-licenced users of the area, such as beekeepers, cattle graziers, timber harvesters, gatherers of non-forest products (such as mushrooms and plants of cultural significance) and farmers that cultivate crops. The mine facilities ‘Land Acquisition Area’ will cover an area of approximately 1,148 hectares (ha) within the Concession Area of 1,542 ha.
The Strumica Valley lies to the south west and south of the mountains where the Ilovica – Shtuka mine site is located; the villages of Ilovica and Shtuka lie on the valley’s northern edge and the A4 State road runs along the valley. The Mine Access Road would run in a broadly southerly direction across the valley to join the А4 state road, bypassing the village of Shtuka to the east.
Local Communities within the Project Area (including within the vicinity of the off-site infrastructure):
In the Municipality of Bosilovo, the two closest village settlements to the Mine Concession are Ilovica and Shtuka (approx. 1,907 and 781 population respectively). These are predominantly Macedonian villages, though small populations of other ethnicities do exist in these settlements. There is a Primary School in Ilovica and Secondary Schools in the regional cities of Strumica and Radovish (15 km west and 30 km northwest of Ilovica and Shtuka respectively); a primary healthcare clinic in Ilovica and two hospitals in Strumica.
In the Municipality of Novo Selo the village of Sushica is the closest settlement to the Mine Concession Area. The depopulated village of Barbarevo lies on the Ograzden Mountain 5 km south east of the Mine Concession Area. The village was abandoned from the 1970s due to poor living conditions and limited availability of water, with most of the inhabitants moving to the settlements of Novo Selo, Nova Maala, Chanaklija, Sushica and Samuilovo in the Strumica valley.
The road to the communities of Ilovica and Shtuka and the current access track onto the Mine Concession Area runs from the village of Turnovo on the А4 State road. A temporary access road will be developed from the A4 along an existing track that runs on the eastern bank of the Shtuka river and around the eastern side of Shtuka village. This existing track will be upgraded and then restored to its current width. The proposed permanent Access Road will run south-east of the settlement of Sekirnik running across agricultural land in the Strumica valley. The permanent access road joins the temporary access road as it bypasses the eastern edge of Shtuka and then climbs up to the Mine Concession Area.
At the two end points of the proposed OHLs are the settlements of Sushica, in the Municipality of Novo Selo and Berovo, in the Municipality of Berovo.
Once the final water supply option is selected, nearby settlements will be identified and engagement activities will be planned.
Agriculture is the dominant economic activity in the local Project area and most households maintain arable land and receive some agricultural income from selling a portion of their harvest or livestock Some households also maintain vineyards for personal consumption, or pastureland for livestock grazing. Arable farming takes place in the valley through which the Access Road would pass, but not generally in the hills of the Mine Concession Area.
Community Investment: Euromax has been making contributions to a variety of projects near the Project site since 2012. Any requests for investments must adhere to Euromax’s Community Investment Framework http://euromaxresources.mk/wp-content/uploads/2013/12/Community-Investment-Framework_180914.pdf and fall under at least one of the Company’s funding categories: Culture and Art, Education and Environment, or Community and Sport.
Employment & Procurement: Once in operation, the Project is expected to have approximately 500 direct employees, as well as indirect employment opportunities through local contractors. The Project’s recruitment strategy will meet Macedonian labour law requirements and be geared towards maximising local employment to the extent feasible, and will include a training component to enhance the skill levels of local job applicants. The Project will tailor its contracting and procurement strategy to maximise the local economic development of the local municipalities, to the extent feasible.
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3. LEGAL & POLICY FRAMEWORK FOR STAKEHOLDER ENGAGEMENT Stakeholder engagement for the Project will follow the national legislative requirements in Macedonia as well as applicable international standards. These are summarised below:
Macedonian Legal Framework
Requirements for public consultation and information disclosure activities during the preparation of project documentation (e.g. Environmental Impact Assessments (EIAs), Spatial Planning documents etc.) are mainly covered under the following laws:
Law on Spatial and Urban Planning (OG of RM No. 199/14 and 44/15) - sets out requirements for public participation on plans (i.e. process of public hearings and public survey etc.); and
Law on Environment (OG of RM, no. 53/05, 81/05, 24/07, 159/08, 83/09, 48/10, 124/10, 51/11, 123/12, 93/13, 187/13, 42/14) – sets out the requirements for disclosure of documents (e.g. EIAs) and decisions related to the environment and the process for public participation and comment.
In Macedonia there are other laws which foresee disclosure of project information or support access to information, encompassing processes for raising grievances and appeals, including: Law on Construction (OGRM No. 130/2009 and amendments); Law on Mineral Resources (OG of RM, 136/12,25/13, 93/13, 44/14 and 160/14), Law on Concession and Public-Private-Partnership (PPP) (OG of RM, no 6/12, 144/14) The Law on Access to Public Information (OGRM Nos. 13/06, 86/08, 06/10, 42/14); and The Law on Acting Upon Complaints and Proposals (OGRM Nos. 82/08, 13/13).
In 1999, Macedonia signed on to the terms of the Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (1998). The Aarhus Convention grants the public rights regarding access to information, public participation and access to justice, in governmental decision-making processes on matters concerning the local, national and transboundary environment. It focuses on interactions between the public and public authorities.
Public Consultation & Disclosure Process:
The legal framework sets out the process for consultation and disclosure of spatial planning and environmental documentation (including EIAs), as well as the statutory time periods for consultation with Public and public comments to be received within. This comprises of 5 main steps outlined below:
Box 2 Summary of Public Consultation & Disclosure Process on Spatial Planning & Environmental Documentation 1. Draft Document/Plan Disclosed.
2. Public Informed via Media of Disclosure of Draft Document/Plan: Public informed about details of disclosure of the Draft Document/Plan (where the hard copy is available for review, the dates and time when it can be reviewed) through the media and citizens/organisations are invited to send comments and to attend the Public Consultations/Hearings
3. Public Consultations/Hearing(s): are held in an appropriate local venue (e.g. Municipality Office, Village Hall etc.) and the plan/document is presented.
4. Public Comments & Update of Draft Document/Plan: Comments received from all stakeholders are processed and the plan/document is revised to reflect them. A report on which comments have been adopted and which have not, with a justification, is delivered together with the final plan/document to relevant authorities who judge whether the comments have been meaningfully considered and addressed.
5. Response to Public Comments: All comments received within the statutory timeframe are responded to in written form.
The Public should be involved in every stage of the procedure for EIA and SEA studies and all decisions made during the process must be published in the appropriate media. The EIA process in Macedonia requires certain documents are disclosed, including: Notification of intention for project implementation; EIA Screening & Scoping Decisions; Announcement of Availability of the EIA study; Disclosure of the EIA study; Consultation with Public on
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the EIA study; Report on Adequacy of the EIA study; and MOEPP Decision on granting consent to, or rejecting the application for the Project.
Consultation during Land Acquisition/Expropriation:
The Expropriation Law (OG of RM Nos. 5/12, 131/12, 24/13, 27/) governs the acquisition and expropriation of land and assets for projects in the Public Interest and the provision of compensation for affected property. In some instances, issues related to provision of compensation for land and assets can also be addressed through the implementation of the Law on Obligation (OG of RM Nos. 18/01, 78/01, 04/02, 59/02, 05/03, 84/08, 81/09, 161/09). Under the Macedonian legal framework relating to expropriation, affected land owners and users with legal rights must be consulted. Euromax will be responsible for payment of compensation to Project affected land owners and users, including for the loss of immovable assets/structures. The process focuses on trying to reach an amicable compensation settlement first to acquire properties to avoid expropriation. Cases in which an amicable settlement on compensation cannot be reached, can be referred to the Courts to determine.
Stakeholder Engagement International Standards
The Project is being developed by Euromax in line with international stakeholder engagement good practice standards and requirements, specifically the EBRD Environmental and Social Policy (2014) and Performance Requirements, and IFC Performance Standards on Environmental and Social Sustainability (2012). International standards on stakeholder engagement generally recommend that the extent and degree of engagement should be commensurate with the project’s risks and adverse impacts and concerns raised by Affected Communities.
EBRD Stakeholder Engagement Requirements: The Project has been screened as a Category A project under EBRD’s Environmental & Social Policy 2014. The Project needs to meet the requirements for stakeholder engagement and public consultation as specified in the EBRD Environmental and Social Policy (2014), its Public Information Policy (2014) and Performance Requirements (PRs). This Stakeholder Engagement Plan (SEP) has been developed in accordance with PR 10 (Information Disclosure and Stakeholder Engagement) of the Policy. Under PR 10, EBRD requires that stakeholder engagement is an ongoing process which involves:
Public disclosure of appropriate information so as to enable meaningful consultation with stakeholders.
Meaningful consultation with potentially affected parties.
A procedure or policy by which people can make comments or complaints (grievance mechanism).
IFC Stakeholder Engagement Standards: The IFC Performance Standards (2012) form part of their Sustainability Framework. Performance Standard 1 (PS1) sets out their recommendations for stakeholder engagement, specifically:
That stakeholder engagement is an on-going process, and for projects with potentially significant adverse impacts, the client will conduct an Informed Consultation and Participation (ICP) programme.
A Stakeholder Engagement Plan (SEP) will be developed and implemented that is scaled to the project risks and impacts and development stage, and be tailored to the characteristics and interests of the Affected Communities. The consultation process will be tailored to language preferences of Affected Communities, their decision-making process, and the needs of disadvantaged or vulnerable groups.
That Affected Communities will be provided with access to relevant information on: the Project; any risks to and potential impacts on such communities and relevant mitigation measures; the envisaged stakeholder engagement process; and the grievance mechanism.
A grievance mechanism will be established to receive and facilitate resolution of Affected Communities’ concerns and grievances about the client’s environmental and social performance.
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4. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT Previous consultation and engagement has been undertaken by Euromax during the Project’s development and specifically connected to the ESIA programme. These activities were to provide stakeholders with information on the Project and to obtain their views, and some were used to collect data and inputs into the ESIA. A summary of the key activities is provided below:
Focus Group Discussions (FGDs), including with municipalities, community representatives, local agricultural business representatives, Farmers’ Association representatives and representatives of the Emergency Services, Youth, Healthcare and Education sectors.
Key Informant Interviews (KIIs), including with school principals, local religious leaders, beekeeper representatives and the hunting association.
Stakeholder engagement meetings with national and local stakeholders, including with Government Ministries (e.g. Ministry of Environment & Physical Planning (MOEPP); Ministry of Economy; Ministry of Transport and Communication); Municipality of Bosilovo and Municipality of Novo Selo; Water Management Company “Strumicko Pole”; Public Enterprise for Forests “ Mekedonski sumi”, their subsidary “ Belasica” “Belasica” and the State Forestry Inspectorate; and the Strumica Museum.
Open House events for the public to access and review information on the Project, the EIA studies and findings and to meet and ask questions of Euromax representatives. Open houses were held to share EIA baseline information (Sep 2015) and during the EIA report disclosure period (May 2016) in Ilovica/Shtuka school sports hall (to cover Ilovica, Shtuka and other communities in the Municipality of Bosilovo) and in Novo Selo school sports hall (to cover the communities within the Municipality of Novo Selo).
Project messaging activities have disseminated information on the Project and specifically environmental, social and safety issues using various other communication methods to those noted above, including Project Update Newsletters, communication through the Project’s Information Centre in Ilovica, Euromax’s national and local websites and social media (e.g. the Project’s Facebook page).
During the preparation of the Land Acquisition and Resettlement Framework (LARF), meetings were undertaken with the Municipality of Bosilovo to discuss the Access Road and development of the LARF. Meetings were also undertaken with certain agencies to obtain inputs to the land acquisition planning and review roles in relation to land acquisition, including with National electricity transmission network operator MEPSO, the local Water Management Company “Strumicko Pole”, the Ministry of Agriculture, Forestry and Water Management, the State Public Enterprise for Forests “Mekedonski sumi”, subsidiary “Belasica”, and Public Enterprise for Pasture Management.
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5. COMMUNICATION METHODS The main Project communication methods Euromax uses for engagement activities are summarised below:
Information Centre, Ilovica: Since February 2013 Euromax has established an Information Centre in Ilovica village which serves as a key communication channel with the local affected communities of Ilovica and Shtuka and any other local interested stakeholders. The Centre is staffed with two full time Community coordinators.
During the Project’s development, Euromax have provided information related to environmental, social and safety issues to members of the public and other stakeholders through a variety of communication methods, including:
Group and One-on-One Meetings.
Open House (OH) events.
Project Update Newsletters delivered to the local stakeholders through the Information Centre and in local shops and via institutions.
Through communication in person at the Information Centre.
Through posting and updating information on the Euromax’s national and local web sites, as well as the Project Facebook page.
Through these communication methods, Euromax provided information mainly to address the most frequently asked questions received in the Information Centre, during meetings and the OH events but also included general Project information.
Public Liaison Committee (PLC): Euromax established a Liaison Committee in July 2016, representing the affected communities near the proposed Mine, namely the villages of Ilovica and Shtuka. The purpose of this Committee is to ensure information is provided to residents and businesses in a timely, easily understood and efficient manner and that concerns of the communities represented by the Committee are effectively communicated to Euromax.
The composition of the Committee is drawn from Euromax and the residents of the villages of Ilovica and Shtuka, including community representatives, elderly representative, youth representative, NGOs, local businesses, associations, education workers, and those undertaking livelihood activities (i.e. within the Mine Concession Area). Representatives of the Municipality of Bosilovo, Public Enterprise for Forests “Mekedonski sumi and subsidiary “Belasica” are also invited to attend the Liaison Committee meetings as observers.
The inauguration meeting of the PLC was held on 8th July 2016 in Strumica . Present PLC members included representatives of: beekeepers, Ilovica football club, mushrooms harvesters, NGO Ceor, local vet, Turk-Roma population and Ilovica population.
Frequently Asked Questions & Answers: Euromax has developed a ‘Question and Answer’ (Q&A) list to highlight the key questions that have been asked during the stakeholder engagement activities. The Q&A list will be continually updated as new issues are identified and new response information becomes available. This list could be accessed through the following link: http://euromaxresources.mk/prashana-i-odgovori/?lang=mk.
Media Communications: Media communication will be used to advertise the Land Acquisition Public Meetings and other Stakeholder Engagement Public Meetings. The following forms of media will be considered for communication on the Project and regarding the Land Acquisition process:
Newspapers: newspaper advertisements will be prepared and placed on news websites that are commonly read in the region, such as Strumica denes (Strumica Today, an online news website).
Local radio (Express Radio).
Local television (A1 TV, TV VIS and TV Intel).
Notices in local shops, local schools, municipal buildings, local clinics, pharmacies etc.
Notices on Euromax Resources websites (Macedonian and English) and Facebook pages.
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Communication Methods for Land Acquisition Process:
Targeted engagement and communication is required with affected land owners, users and other interested stakeholders, about the land acquisition process, including:
EOX Land Acquisition Office (Magistralna ulica Br. 604, Dabilje, Strumica): EOX legal and Project representatives are present within the Land Acquisition Office to give support to owners and users of the Concession area and area of off-site infrastructure, regarding legal property issues, entitlements and other related questions.
Land Acquisition agenda items are part of the Public Liaison Committee sessions. During Quarter 1 2017 a Land Acquisition Committee will be set up with the purpose of detailed engagement with representatives from the two municipalities; concession owner & user groups (e.g. cattle graziers, beekeepers, timber and mushroom collectors and farmers); Public Enterprise for Forest “ Mekedonski sumi” and their subsidiary “ Belasica”; and community reps (from Ilovica, Shtuka, Turnovo and Sekirnik).
Initial Stakeholder Contact for Land Acquisition: An information package is distributed to potentially affected and key stakeholders for the land acquisition process by mail prior to stakeholder meetings and events. The purpose of the information package is to provide the information necessary to allow affected owners, users and stakeholders to participate meaningfully in discussions. The information packages contain such items as a Project brochure/leaflet on land acquisition and a letter from Euromax introducing the company and describing the purpose of the planned meeting. The information package will also provide the reader with information about the Project, summary of the LARF and the land acquisition process. Brochures on the Project and land acquisition process will also be placed in common public places such as Municipality of Bosilovo and Novo Selo offices and on the Euromax websites (http://euromaxresources.mk/wp-content/uploads/2016/09/Leaflet-MK_FINAL.pdf) and http://www.euromaxresources.com/wp-content/uploads/2016/09/leaflet_en_final.pdf).
Open Houses/Public Meetings: will be held in affected communities and affected groups in the Municipality of Bosilovo (e.g. Ilovica, Shtuka, Turnovo and Sekirnik,) and Novo Selo (e.g. Sushica, Novo Selo and Samuilovo) etc. For the OHL component meetings will also be held in affected communities in the Municipality of Berovo (Rusinovo, Ratevo).
Focus Group Discussions and One-on-One Meetings: Discussions and consultations will be undertaken with:
Affected users (e.g. within the Concession Area of cattle graziers, mushroom gatherers, wood collectors, beekeepers, farmers of agricultural plots). Owners of the land in the affected Project areas (e.g. land owners along the Access Road and OHL route). Vulnerable groups (e.g. elderly, widows etc.): these meetings will be held in appropriate places (e.g. Sports Hall in Ilovica, Etno home in Shtuka, halls in Municipalities of Bosilovo, Novo Selo and Berovo, and Cultural Hall in Novo Selo). Euromax will encourage vulnerable groups to attend meetings and will provide support to vulnerable people to access and participate in these meetings (e.g. provision of transport etc.).
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6. IDENTIFICATION OF STAKEHOLDERS & ENGAGEMENT PLAN
6.1. STAKEHOLDER IDENTIFICATION Stakeholder engagement will be ongoing throughout the course of the Project’s future planning, construction and operation. Affected communities and stakeholder groups have been identified by Euromax for the Mine Concession Area and the off-site Access Road. Euromax have undertaken initial identification of affected communities and stakeholders for the OHL and water support infrastructure, however the list will be updated once further details are confirmed on these off-site infrastructure components. Local and national stakeholders have been identified for each Project component. Table 1 identifies the key external and internal stakeholder groups and provides an overview of the individual stakeholders per Project component.
Table 1 Summary of Stakeholder Groups No. Stakeholder Group Project Component - Stakeholders Mine Concession Access Road OHL Water Supply Infrastructure4 External Stakeholders: LOCAL STAKEHOLDERS 1 Project Affected Municipality of Bosilovo, Municipality of Novo Selo and Strumica city residents Communities/Residents of Municipality of Bosilovo: Municipality of Bosilovo: Municipality of Project affected towns and villages within Ilovica, Shtuka, Sekirnik, Ilovica, Shtuka, Sekirnik, Novo Selo: communities within the vicinity of the Project Turnovo. Municipality of Novo Turnovo,. Municipality of Sushica. area/whose water area/components. Selo: Barbarevo Novo Selo: Barbarevo Municipality of supply may be shared. (depopulated), Sushica, Novo (dopopulated), Novo Selo, Berovo: Berovo,: Selo, Samuilovo. Samuilovo, Sushica Rusinovo, Ratevo Supply and logistics facilities related to the Project may be located within Strumica and therefore ‘Strumica’ residents and residents of the wider area will, as appropriate, be stakeholders. 2 Owners and users of land Private part owners of mixed Private owners of affected Private owners of Private owners of and assets (including those State/Private land parcels land parcels. affected land affected land parcels. with legal & no legal within Land Acquisition Area in parcels. (If land acquisition is rights/documentation) the Mine Concession. required). which may be acquired Owners of agricultural plots (permanently/temporarily) within the Mine Concession. for the Project who may be Asset/structure owners/users Agricultural tenants/users Tenants/users of Tenants/users of physically and/or within Mine Concession. of affected land parcels. affected land affected land parcels. economically displaced. Land users within Mine parcels. (If land acquisition is Concession: cattle graziers, required). timber harvesters, beekeepers, mushroom & plant gatherers, farmers of agricultural plots. 3. Vulnerable & Marginalised Elderly and very low income (land-based livelihoods dependent) households, widows and elderly with children Groups in the Project who have emigrated abroad, in villages with Project affected area. Specific vulnerable and marginalised Affected groups/households/individuals will be added as identified through engagement with the communities, Public Communities/Villages (i.e. Liaison Committee and the socio-economic surveys and land acquisition planning. Groups 1 & 2). 4. Businesses/Companies. Municipality of Bosilovo: Municipality of Bosilovo: Companies of Companies of Vistoni-ZP Dooel, Dalvina Vistoni-ZP Dooel, Dalvina relevance in relevance to selected Vinery, Zdravje Radovo Milk Vinery, Zdravje Radovo municipalities and water supply solution production, Greenhouse Milk production, locations that the will be added when Hamzali, MN company trade. Greenhouse Hamzali, MN OHL will pass agreement on the Company for mushroom company trade. through will be solution and details of trading “Fungi Flora” v. Municipality of Novo added as the the solution are Oraovica, Radovish. Selo: Ilmada Janevi planning of the available. Parties Local veterinary “’Di Veterina” Dooel, Eco garden, Dooel, OHL develops. potentially affected by v.Turnovo. SlogaPromet JTD, AD the water supply Local company for trading Zemjodelski Stocarski solution or who may vegetables “DOOEL”Trofej 08” kombinat Sushica, share the supply will v. Ilovica. Agronova MiK Susica. be engaged with Municipality of Novo Selo: during the planning Ilmada Janevi Dooel, Eco process for the water garden, Dooel, SlogaPromet supply. JTD, AD Zemjodelski Stocarski kombinat Sushica,Agronova MiK Susica.
Local Authorities: 5. Municipalities. Municipality of Bosilovo.
4 Stakeholders will depend upon water support infrastructure solution.
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No. Stakeholder Group Project Component - Stakeholders Mine Concession Access Road OHL Water Supply Infrastructure4 Municipality of Novo Selo. Municipality of Municipalities within Berovo. area/whose water supply may be shared.
6. Local Government Municipality Registry offices. Municipality Registry Municipality (Municipality offices as Companies/Agencies. Subsidiary of PE for Forest in offices. Registry offices. required) Strumica and Berovo. Subsidiary of PE for Subsidiary of PE Strumichko pole Water Branch Office of the PE for Forest in Strumica. for Forest in Management Pastures Management (AofP) Branch Office of the PE Strumica and Company. in Strumica and Berovo.. for Pastures Management Berovo. National company for Primary Court Strumica. (AofP) in Strumica. Branch Office of water Management Public Utility Company. Primary Court Strumica. the PE for “Vodostopanstvo AD”. Agency for Real Estate Public Utility Company. Pastures Cadastre subsidiaries in Agency for Real Estate Management Berovo and Strumica Cadastre subsidiaries in (AofP) in Strumica Strumica and Berovo.. Primary Court Strumica. Public Utility Company. Agency for Real Estate Cadastre subsidiaries in Berovo and Strumica 7. Local Community Services. For all affected Municipalities, specifically the Municipalities of Bosilovo and Novo Selo: Emergency Services: including Fire Brigade and Police. Health & Social Assistance Services. Utility Owners & Operators. Local Non-Government Organisations (NGOs) and other organisations. 8. Local NGOs/Associations Municipality or Bosilovo: of Citizens & Other Orgs. Bela Breza’ ecological organization, Bosilovo. Struma Strumica. Z.G Mana, Strumica. ECO CHUKAR GREEN NGO, Ilovica. CEOR (Center for education and sustainable development) NGO, Ilovica, Youth Council of Bosilovo. “Zolto Zlato“ – Association of tobacco producers, Ilovica. Municipality of Novo Selo: Local Youth Council of Novo Selo. Youth organization “Feniks”. Civil organization “Utro”, Environmental organization “ ED -Izvor” Radovo. Agro- Eko Assosiation of farmers, Borievo Z.G Mana, Strumica.
Relevant NGOs in the Municipality of Berovo for the OHL will also be covered in the engagement planning.
NATIONAL STAKEHOLDERS 9. Macedonian Government Ministry of Environment & Physical Planning. Authorities. Ministry of Agriculture, Forestry & Water Economy. Ministry of Transport & Communication. Ministry of Culture, Culture Heritage Protection Office. Other Ministries, as relevant: Ministry of Finance. Ministry of Economy. Ministry of Labour & Social Policy. State Labour Inspectorate. Spatial Planning Agency. Ministry of Interior Ministry for Health 10. Other Government State Level - PE, for Forest PESR. MEPSO. Water Management Agencies. “Makedonski Sumi”, PE for Company / “”, Public Pastures Management. Utility Company.
11. National NGOs and E.g.: Front 21/42; Regional Environmental Center; Eco Svest; Makedonski Zelen Centar; Eco.Net; Eko associations for activities in Chukar, CEOR; “Environmental organization “ ED -Izvor” Radovo; Macedonian Association of Mining and the field of environment. Geology Engineers; etc.
INTERNAL STAKEHOLDERS: 12. Euromax Employees/Project representatives. 13. Trade Union representatives. 14. Contractors. Construction companies (for each component/package of work). Subcontractors. Transportation/haulage contractors. SEP – Ilovica-Shtuka Project – Final Draft March 2017 13
6.2. ENGAGEMENT PLAN PER STAKEHOLDER GROUP Table 2 below outlines the methods of communications and currently envisaged timeframes for engagements with the stakeholder groups identified above in Table 1 regarding general Project development activities (including ESIA and permitting activities) and the land acquisition process.
Table 2 Engagement Plan per Stakeholder Group No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
External Stakeholders: LOCAL STAKEHOLDERS 1 & 2 Project Affected Communities of Ilovica, All Project General Project Development, EIA and Permitting: Ongoing from early in the Communities/Residents Shtuka, Turnovo, Components. Raise understanding and awareness amongst communities of the Project Public Notices. Project planning (during of towns and villages Sekirnik. Sushica, Novo (including its effects, planned mitigations and monitoring measures) and EOX letters to individuals. 2013 when the Information within the vicinity of the Selo. Other communities provide periodic updates to communities on the Project progress. Local EOX offices / Info Centre in Centre was opened) Project area/components along OHL (i.e. in These updates will include required public consultation activities for the Ilovica. through exploration, – including owners5 and Municipality of Berovo) ongoing EIA, Urbanisation permitting and other permitting processes. EOX Land Acquisition Office. permitting & pre- users of land and assets and along selected water This will include any Public Hearings as required under Macedonian law Community meetings. construction phase (those with legal & no supply infrastructure and public consultations to meet international standards (see Section 3). Public Liaison Committee through construction and into operation of the Mine legal rights / solution. Hear comments and concerns on the Project from the community. meetings. and commissioning of the documentation) which Discuss and agree mitigation measures with the community and EOX visits to external Access Road, OHL and may be acquired stakeholders. stakeholder offices. water supply infrastructure. (permanently/temporarily) Disseminate the grievance mechanism and inform stakeholders where to EOX Project leaflets.
for the Project. get Project information. Local Media. Land Acquisition: August Identify vulnerable persons amongst Project Affected Communities, for User Group meetings. 2016 onwards until Project whom special engagement measures are required (see below). Public meetings on land land acquisition for all acquisition. Land Acquisition: components is complete. Raise understanding amongst communities of the land acquisition Targeted engagement methods Plus, further engagement process, including entitlements, land & asset valuation, negotiation for vulnerable people/group e.g. during monitoring of land process and land acquisition timeframe etc. EOX house visits (especially to acquisition implementation. Identify persons affected by land acquisition or restrictions on access to vulnerable, elderly, sick, and land and natural resources. people with disabilities) and Collate socio-economic data on Project affected persons (PAP). provision of transport to attend Collate data on affected assets. meetings. Provide periodic updates to communities on progress in implementing the EOX website and Facebook page land acquisition process. will include land acquisition notices. Hear concerns regarding land acquisition from the community. Disseminate the grievance mechanism and where to get Project Review of any grievances information. received.
5 Owners and beneficiaries of deceased eligible owners.
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Disclosure of the Land Acquisition & Resettlement Framework (LARF – Sept 2016) and Livelihood Restoration Plan (LRP) document. Provide opportunities for PAP participation in developing the compensation & mitigation options in the LRP. Identify vulnerable persons amongst PAP, for whom special engagement measures are required (see below). Negotiate with PAP to agree to land acquisition via negotiated settlement, and sign land acquisition agreements. Deliver compensation and assistance. Monitor LRP implementation, including livelihood restoration. Communities in the Mine Concession. Land Acquisition: As above Land Acquisition: August Municipalities of Bosilovo Identify mixed owners in the Mine Concession area and confirm land 2016 onwards until Project and Novo Selo with mixed ownership. land acquisition for the ownership in the Identify beneficiaries of deceased registered land owners in the Concession is complete Concession (including Concession area. (planned to be completed by former inhabitants of the Identify individuals in user groups – beekeepers, cattle graziers, timber end of 2016). Plus, now depopulated gathers, plant gathers, and mushroom harvesters. implementation monitoring. Barbarevo village and Identify individuals with agricultural plots in the Concession Area beneficiaries of deceased (potentially on State land and privately owned). eligible owners) and users Understand how user groups use the Mine Concession, including income of the Mine Concession derived and livelihood dependency, gather socio-economic data on Area. affected persons. Identify assets and asset owners in the Mine Concession area. Engagement with asset owners to enable the Registered Valuer to value affected assets. Identify and map cultural heritage in the Mine Concession area. Discuss and agree mitigation measures with affected user groups, the community and stakeholders. Identify alternative areas for user groups outside of the Concession (e.g. cattle grazing, bee hives, mushroom and timber gathering). Hear any concerns from the community and affected owners/users. Communities of Ilovica, Access Road. General Project Development, EIA & Permitting: - see list above in first As above Land Acquisition: Shtuka, Turnovo, entry of table. September 2016 onwards Sekirnik. Sushica and in until Project land acquisition Land Acquisition: Municipalities of Novo for the Access Road is Raise community awareness of the Access Road and related process for Selo and Bosilovo. complete. land access and acquisition.
Identify land owners and users along Access Road, Phase 1 and Phase 2 Land acquisition for Phase 1 sections and planned temporary road for construction. Access Road and temporary Identify beneficiaries of deceased registered land owners. road is planned to be Gather socio economic and asset data of affected land owners and users, complete by early Quarter 3 including income derived and livelihood dependency from the land. 2017. For Phase 2 Access Engage with affected community on valuation of affected land & assets Road land acquisition is
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
by Registered Valuer. planned to be complete by Discuss and agree mitigation measures with affected owner/user groups. end of Quarter 1 2018. Negotiation to reach agreements for land access or acquisition. Implementation of compensation payments and assistance, plus Plus, on-going monitoring of implementation monitoring. implementation and livelihood restoration.
Project affected Overhead Line General Project Development, EIA & Permitting: - see list above in first As above Land Acquisition: communities along the (OHL). entry of table Land acquisition two overhead power lines engagements for the OHL Land Acquisition: – one running ~7km south from the Sushica substation Raise community awareness of the OHL related process for land access to Sushica substation and would be during 2017 to and acquisition. one ~30km north to complete by end of 2017; Identify affected land owners and users along the OHLs (e.g. at OHL Berovo substation. and for the OHL from pylon bases). Berovo during second half Gather socio economic and asset data of affected land owners and users, 2017 to complete in Q1 including income derived and livelihood dependency from the land. 2018. Engage with affected community on valuation of affected land & assets by Registered Valuer. Plus, on-going monitoring of Discuss and agree mitigation measures with affected communities. implementation and Negotiation to reach agreements for land access or acquisition. livelihood restoration. Implementation of compensation payments and assistance, plus implementation monitoring. Project affected Water Supply General Project Development, EIA & Permitting: - see list above in first As above Land Acquisition: communities within Pipeline. entry of table. Land acquisition area/whose water supply engagements for the water Land Acquisition: may be shared and pipeline would be during Raise community awareness of the water supply infrastructure solution community along short second half 2017 to and the related process for land access and acquisition. section of new pipeline complete in Q1 2018 Identify affected land owners and users, e.g. along the expected short from existing Turija canal (possibly earlier tbc). section of new pipeline that may be required near Ilovica or Shtuka near Shtuka to mine site. village. Plus, on-going monitoring of Gather socio economic and asset data of affected land owners and users, implementation and including income derived and livelihood dependency from the land. livelihood restoration. Engage with affected community on valuation of affected assets by Registered Valuer. Discuss and agree mitigation measures with affected owners and users. Negotiation to reach agreements for land access or acquisition. Implementation of compensation payments and assistance, plus implementation monitoring. 3. Vulnerable & All vulnerable persons, All Project General Project Development, EIA & Permitting: - EOX staff to check that that Ongoing from early in the Marginalised Groups in including: components. vulnerable people receive Project Project planning (during As stated for Group No. 1 & 2 above - plus to apply targeted engagement the Project Affected Turk community in information and can participate in 2013 when the Information methods for potentially vulnerable and marginalised groups so they have Communities/Villages (i.e. Ilovica. community meetings/discussions Centre was opened) access to Project information and can participate in the engagement with EOX. If not, EOX staff will
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Groups 1 & 2). Women (especially process. Purpose is to ensure such groups are not disproportionately take actions such as visits to through exploration, in Turk community). affected by the Project and specific assistance measures can be specific individuals or groups and permitting & pre- Elderly. identified and applied if needed. transport provision. construction phase Families with sick or Land Acquisition: Socio-economic survey data. through construction and Liaison Committees. disabled members. To ensure that vulnerable people receive Project information on land into operation of the Mine Engagement with Municipalities. People and acquisition, have opportunities to participate in community meetings and and commissioning of the households on very that their formal and informal rights to land are respected and reflected in Access Road, OHL and low incomes. compensation and assistance for land acquisition. water supply infrastructure. Land Acquisition: September 2016 to end of 2016 for the Concession area and Access Road Phase 1 and temporary road. Plus, onwards for other components and implementation monitoring. 4. Businesses/Companies. Businesses directly Mine Concession Land Acquisition: EOX engagement meetings with Ongoing from early in the related to affected land Area. Engagement with companies to help enable smooth running of communities and businesses, Project planning (during acquisition area: e.g. (Any other negotiations with direct land users in the Concession (e.g. mushroom plus communication methods per 2013 when the Information company for mushroom business in direct collectors and cattle graziers). (1 & 2) above. Centre was opened) trading “Fungi Flora” v. areas of impact of Engagement to understand any concerns and affects from Project they through exploration, Oraovica, Radovish other project perceive their businesses potentially could be subject to. permitting & pre- Local veterinary “’Di components will be Engagement with Veterinary to get their inputs re cattle graziers in the construction phase Veterina” v.Turnovo. identified and concession area, including identification of alternative grazing areas. through construction and Local company for trading included as into operation of the Mine vegetables DOOEL”Trofej appropriate in and commissioning of the 08l” v. Ilovica. engagement Access Road, OHL and process). water supply infrastructure.
Land Acquisition: August 2016 onwards until Project land acquisition for the Concession is complete (planned to be completed by end of 2016).
Businesses above & other All Project General Project Development, EIA & Permitting: Ongoing from early in the businesses in Project components. Project planning (during affected area and Raise understanding and awareness amongst businesses of the Project 2013 when the Information Municipalities, including and provide periodic updates to communities on the Project. Centre was opened) (more will be identified These updates will include required public consultation activities for the through exploration, during the Project ongoing EIA, Urbanisation permitting and other permitting processes. permitting & pre- development): Hear comments and concerns on the Project from the local businesses. construction phase Municipality of Discussion of the potential impacts on business trade (positive and through construction and
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Bosilovo: Vistoni-ZP adverse), including effects on access during construction and operation, into operation of the Mine Dooel, Dalvina Vinery, and business opportunities. and commissioning of the Zdravje Radovo Milk Access Road, OHL and production, Greenhouse water supply infrastructure. Hamzali, MN company trade. Municipality of Novo Selo: Ilmada Janevi Dooel, Eco garden, Dooel, Sloga Promet JTD, AD Zemjodelski Stocarski kombinat Sushica,Agronova MiK Susica. Companies of relevance in municipalities and locations that the OHL & Water Supply infrastructure will pass through will be added to stakeholder list as the planning of the OHL develops. Local Authorities: 5. Municipalities. Municipality of Bosilovo. All Project General Project Development, EIA & Permitting: As above under Group 1 & 2, plus: Ongoing from early in the Municipality of Novo Selo. components. Project planning (during Official correspondence & Municipality of Berovo. Raise understanding and awareness amongst Municipalities of the 2013 when the Information regular update meetings. Project (including its effects, planned mitigations and monitoring Centre was opened) measures) and provide periodic updates to Municipalities on the Project. Invite municipality through exploration, These updates will include required public consultation activities for the representatives to Public ongoing EIA, Urbanisation permitting and other permitting processes. permitting & pre- Meetings, Liaison Committee Planning and implementation of the Project, including EIA process, land construction phase and keep them updated on acquisition and permitting – and the development of the Access Road through construction and meetings with community solution (Municipality of Bosilovo). into operation of the Mine members, land owners & users; Hear comments and concerns on the Project from the Municipalities. and commissioning of the companies, vulnerable groups Access Road, OHL and Discussion of the potential impacts on the Municipality. etc. water supply infrastructure. Support with socio-economic surveys, other surveys and engagements
with local communities (Groups 1 &2 above), including vulnerable and marginalised groups (see Group 3 above).
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Municipality of Bosilovo. All components – Land Acquisition & Land Access: As above plus: Land Acquisition: Municipality of Novo Selo. land acquisition & Support will be requested from the Municipality with respect to land Participation of Municipalities in August 2016 onwards until Municipality of Berovo land access. acquisition for the Concession Area, and land acquisition and planning of Public Liaison Committee(s). Project land acquisition is (OHL) routes for the Access Road, water supply and OHL, including with in relation Meetings between EOX and complete. Plus, onwards for to: Municipalities when required. implementation monitoring. To confirm routes and land requirements of Access Road and Water Supply Infrastructure (e.g. pipeline). To help identify persons affected by land acquisition. To help identify beneficiaries of deceased land owners of mixed parcels in Concession and plots along Access Road and other Project components. To help identify owners of undisclosed land parcels in the Cadastre along the OHL. To gain Municipalities advice and assistance with engagement with affected communities. Involvement of Municipalities in LRP implementation monitoring.
6. Local Government Municipality Registry All components, General Project Development, EIA & Permitting: As above plus: Land Acquisition: Companies/Agencies. offices. especially Participation of Municipalities in August 2016 onwards until Subsidiary of PE for Concession Area Raise understanding and awareness amongst Local Government Public Liaison Committee(s). Project land acquisition is Forest in Strumica and and Access Road. Companies/Agencies of the Project (including its effects, planned Meetings between EOX and complete. Plus, onwards for mitigations and monitoring measures) and provide periodic updates to Berovo (FC). Local Government implementation monitoring. companies/agencies on the Project. These updates will include required Branch Office of the PE Companies/Agencies when public consultation activities for the ongoing EIA, Urbanisation permitting required. for Pastures Management and other permitting processes. (AofP) in Strumica and Planning and implementation of the Project, including EIA process, land Berovo.. acquisition and permitting. Primary Court Strumica. Hear comments and concerns on the Project from the Local Government Public Utility Company. Companies/Agencies and discussion of the potential impacts on their Agency for Real Estate remit. Cadastre subsidiaries in Land Acquisition: Berovo and Strumica To obtain data on affected persons with entitlements, including beneficiaries of deceased land owners in Concession area and Access Road. FC and AofP advice on alternative areas for user groups (e.g. cattle graziers) outside the Mine Concession Area. Assistance with Mine Concession Area user group engagement. Local Water Management Water Supply As above (5), plus: Company “Strumicko Infrastructure Land Acquisition: Pole” “ Solution (e.g. To confirm routes and land requirements for the Water Supply pipeline) Infrastructure (e.g. pipeline). (& National Level Agency Agree involvement & responsibilities of water company and Euromax
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Vodostopanstvo AD”. in land acquisition for water supply infrastructure solution. Water Management To help identify persons (owners & users) affected by land acquisition. Company). To gain advice and assistance with engagement with affected communities.
7. Local Community For all affected All Project General Project Development, EIA & Permitting: EOX engagement Ongoing from early in the Services. Municipalities, specifically Components. meetings with Project planning (during the Municipalities of Raise understanding and awareness amongst community services of the 2013 when the Information Community Services, Bosilovo and Novo Selo: Project (including its effects, planned mitigations and monitoring Centre was opened) measures) and provide periodic updates to communities on the Project. Emergency plus relevant through exploration, These updates will include required public consultation activities for the Services: including communication permitting & pre- ongoing EIA, Urbanisation permitting and other permitting processes. Fire Brigade and methods per (1 & 2) construction phase Hear comments and concerns on the Project from the local community Police. through construction and services. above. Health & Social into operation of the Mine Assistance Discussion of the potential impacts on local community services from and commissioning of the Services. Project – there will be an Emergency Response Plan developed by EOX Access Road, OHL and Utility Owners & for the Mine with the emergency services, for which direct communication water supply infrastructure. Operators. will occur. Center for Social Work in Strumica and Centre for Social Work in Novo Selo Local Non-Government Organisations (NGOs) and other organisations. 8. Local NGOs/Associations Municipality or Bosilovo: All Project General Project Development, EIA & Permitting: Meetings with specific NGOs. Ongoing from early in the of Citizens. Bela Breza’ ecological Components. Dissemination of Project Project planning (during organization, Bosilovo. information through media 2013 when the Information Provide information to NGOs on Project. Hear their comments and announcements as well as Struma Strumica. concerns on the Project and review as part of Project planning. Centre was opened) Z.G Mana, Strumica. electronic (as outlined in through exploration, These organisations can potentially help to identify key issues pertaining Section xx). ECO CHUKAR GREEN to the local community (vulnerable groups) and the local environment. permitting & pre- NGO, Ilovica. Public meetings in construction phase These organisations can potentially help to identify possible assistance Municipalities and villages. CEOR (Center for measures for the local community affected by Project - e.g. agricultural through construction and education and sustainable development agencies etc into operation of the Mine development) NGO, and commissioning of the Ilovica, Access Road, OHL and Youth Council of water supply infrastructure. Bosilovo. “Zolto Zlato“ – Association of tobacco producers, Ilovica. Municipality of Novo Selo: Local Youth Council of Novo Selo. Youth organization “Feniks”.
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Civil organization “Utro”, Environmental organization “ ED -Izvor” Radovo. Agro- Eko Assosiation of farmers, Borievo Z.G Mana, Strumica.
Relevant NGOs in the Municipality of Berovo for the OHL will also be covered in the engagement planning NATIONAL STAKEHOLDERS 9. Macedonian Government Ministry of Environment & All Project General Project Development, EIA and Permitting: Meetings with Government Ongoing from early in the Authorities. Physical Planning. Components. Official correspondence and meetings: Authorities when required, Project planning (during Planning and preparation of technical documentation related to including necessary site visits. 2013 when the Information environmental aspects. Official correspondence. Centre was opened) Approval of EIA, SEA and Elaborates for the Environment and other Consultation with Public and through exploration, necessary approvals/opinions. Hearings (as required under permitting & pre- State environmental inspections. law construction phase Regular Project progress reports. through construction and Land Acquisition: into operation of the Mine MOEPP involvement in land acquisition as the parent Ministry for and commissioning of the environmental and special planning issues and activities. Access Road, OHL and water supply infrastructure. Land Acquisition: August 2016 onwards until Project land acquisition is complete, and xxx onwards during implementation monitoring.
Ministry of Agriculture, All Project General Project Development, EIA and Permitting: Forestry & Water Components. Inform Government Authority about Project and undertake official Economy correspondence. Engage on land related matters. Engage on forest matter. Engage with agricultural land matter. Land Acquisition: Official correspondence and meetings: MofAFWE involvement in Concession Access Road, and OHL land acquisition and urbanisation processes. MofAFWE involvement in making decision about conversion of forest land
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
into construction land Ministry of Transport & All Project General Project Development, EIA and Permitting: Communication. components – Inform Government Authority about Project and undertake official focus on the correspondence. Access Road t. Official correspondence and meetings, permit requests: MoTC involvement in the urbanization process of the concession area, MoTC involvement in approval of Infrastructure panning documents for OHL Land Acquisition: MoTC involvement as parent Ministry in approval of State Planning Urban Documentation for Concession Area MoTC involvement as parent Ministry for Issuing construction permit for project on the Concession Area and construction permit for OHLs Ministry of Economy General Project Development, EIA and Permitting: (ME). Planning and preparation of technical documentation related to mining aspects. Regular Project progress reports. Reports from Exploration within the period of approved Concession for Exploration Elaborate for the detailed geological research calculation of geological ore reserves of the deposits of minerals – i.e. the gold and copper at the site. Submission of Elaborate for performed geological exploration on concession space provided for the construction of infrastructure facilities of Mine. Main Mining Project. Land Acquisition: ME involvement as parent Ministry for issuing the Permit for exploration of the concession. ME involvement as parent Ministry for revision and issuing the Permit for mining concession.
Ministry of Culture (MoC), All Project General Project Development, EIA and Permitting: Culture Heritage Components. Inform Government Authority about Project and undertake official Protection Office. correspondence. Approval of Chance Find Procedure and notification process for excavation. Engage on a research on archaeological defined sites. Land Acquisition: MoC involvement as parent Ministry for approval of the plan for research and protection prepared by Institute for Protection of Cultural Monuments and Museum of Strumica for concession area, access road and OHLs Other Ministries, as All Project General Project Development, EIA and Permitting: relevant: components as Inform Government Authority about Project and undertake official Ministry of Finance. appropriate. correspondence. Ministry of Labour & Engage on labour and social policy matters.
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Social Policy. Engage on Spatial planning matters State Labour Inspectorate. Spatial Planning Agency. State Attorney. All Project General Project Development, EIA and Permitting: components as Inform Government Authority about Project and undertake official appropriate. correspondence. Regular Project progress reports. Land Acquisition: Engage with initiation of expropriation process (if required). State Attorney to provide the Government lead role in compulsory land acquisition (if required).
10. Other Government PE for Forest Mine Concession General Project Development, EIA and Permitting: Meetings with Government Ongoing from early in the Agencies. “Makedonski Sumi”. and forestry & Inform Government Agency about Project and undertake official Authorities when required, Project planning (during PE for Pastures pasture areas correspondence. including necessary site visits. 2013 when the Information Management. affected by other Stakeholders official meetings and site visits. Official correspondence. Centre was opened) components (e.g. Land Acquisition: Public Hearings (as required through exploration, potentially parts of PE for Forest “Makedonski Sumi” and PE for Pastures management under law). permitting & pre- Access Road and involvement in Concession land acquisition and urbanisation. construction phase OHL route). Forestry authorities will be due a payment by Euromax for loss of through construction and forestry as defined in the legal framework. into operation of the Mine These agencies will also provide support to identify alterative grazing, and commissioning of the mushroom gathering and timber harvesting locations outside the Access Road, OHL and Concession. water supply infrastructure. Land Acquisition: August 2016 onwards until Project land acquisition is complete, and onwards during implementation monitoring. Public Enterprise for State Access Road. General Project Development, EIA and Permitting: Meetings with Government Ongoing from early in the Roads. Inform Government Agency about Project and undertake official Authorities when required, Project planning (during correspondence. including necessary site visits. 2013 when the Information Seek necessary approvals for Access Road and junction onto A4 State Official correspondence. Centre was opened) Road. through exploration, Land Acquisition: permitting & pre- Land acquisition at Access Road junction with A4 may require land construction phase within the current PESR highway corridor. through construction and into operation of the Mine and commissioning of the Access Road, OHL and water supply infrastructure.
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Land Acquisition: September 2016 onwards until Project land acquisition for the Access Road is complete.
Land acquisition for Phase 1 Access Road and temporary road is planned to be complete by end of 2016. For Phase 2 Access Road land acquisition is planned to be complete by end of 2017
MEPSO. OHL. General Project Development, EIA and Permitting: Meetings with Government Ongoing from early in the Inform Government Agency about Project and undertake official Authorities when required, Project planning (during correspondence. including necessary site visits. 2013 when the Information Seek necessary agreements and approvals for OHL and sub-stations Official correspondence. Centre was opened) and electrical supply agreement. through exploration, MEPSO Involvement in project development documentation. permitting & pre- Land Acquisition: construction phase MEPSO involvement in land acquisition for OHL and sub-stations. through construction and into operation of the Mine and commissioning of the Access Road, OHL and water supply infrastructure. Land Acquisition: Land acquisition engagements for the OHL from the Sushica substation would be during 2017 to complete by end of 2017; and for the OHL from Berovo during second half 2017 to complete in Q1 2018. However, engagement with MEPSO has been ongoing by EOX on land from mid 2015. 11. National NGOs and E.g.: Front 21/42; All Project General Project Development, EIA & Permitting: Meetings with specific NGOs. Ongoing from early in the associations for activities Regional Environmental Components. Project planning (during Provide information to NGOs on Project. Hear their comments and Dissemination of Project in the field of Center; Eco Svest; concerns on the Project and review as part of Project planning. information through media 2013) through exploration, announcements as well as environment. Makedonski Zelen These organisations can potentially help to identify key issues pertaining permitting & pre-
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No. Stakeholder Group Stakeholders Project Purpose of Communication. Communication Methods & Indicative Timing of Component(s) of Activities Engagements/Consultatio Relevance ns
Centar; Eco.Net; Eko to the local community (vulnerable groups) and the local environment. electronic media (as outlined in construction phase Chukar, CEOR; SEP). through construction and “Environmental Public meetings. into operation of the Mine organization “ ED -Izvor” and commissioning of the Radovo; Macedonian Access Road, OHL and Association of Mining and water supply infrastructure. Geology Engineers; etc. Internal Stakeholders: 12. Euromax EOX staff involved in All Project Raise internal awareness of EOX land acquisition process and Internal communications. September 2016 onwards Employees/Project external engagement with Components. external messaging. EOX Commitments Register. until Project land acquisition representatives. community and Ensure that EOX staff do not make any commitments relating to land is complete, and onwards stakeholders. acquisition unless authorised to do so. during implementation monitoring. 13. Trade Union representatives. All Project Inform group on: Human resources policy, Grievance mechanism, Official correspondence Throughout Project Components. health and safety procedures, code of conduct. implementation. Meetings.
Information on request to
union representatives
14. Contractors. Construction company All Project Inform group regarding protocols and requirements for interaction with Official correspondence, During tendering and (companies). Components. the local community. meetings, codes of conduct, contract negotiations, information in contract on signature of contract(s). Inform group on the standards and expectations with respect to standards and expectations environment protection, health and safety at work and code of conduct Subcontractors. with respect to: in local communities etc. environmental protection; Throughout project Transportation health and safety at work; implementation. contractors. security; access to sites; and interaction with the community. Suppliers of goods and services. Regular monitoring performance of contractors in the implementation of the above. Provision of relevant documents in tender: e.g. ESAP, SEP, NTS, EIA, Elaborates, LARF etc.
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7. INFORMATION DISCLOSURE & STAKEHOLDER ENGAGEMENT PROGRAMME Project Documentation Disclosure
Euromax will continue to disclose all relevant information to the public. The SEP (and other key documents, such as the EIAs and, LARF) will be disclosed on the Euromax (EOX) websites (http://www.euromaxresources.com/ in English and http://euromaxresources.mk/ in Macedonian). In addition, hard copies of the SEP will be available at the following locations:
Euromax Resources DOO offices in:
o Strumica – Goce Delchev 58, Strumica 2400, Macedonia.
o Skopje - Blvd Partizanski Odredi, Br.14, 1/2-3, Skopje 1000, Macedonia.
Euromax Information Centre, Ilovica (Ilovica 220a, Municipality of Bosilovo Tel.:+389 34 368 888 [email protected]).
Municipality of Bosilovo (2431 Bosilovo, Macedonia www.opstinabosilovo.gov.mk; E-mail: ops.bosilovo@t- home.mk ).
Municipality of Novo Selo (Manus Turnovski, 2434 Novo Selo, Macedonia www.novoselo.gov.mk; E-mail: [email protected] ).
Euromax Land Acquisition office in Bosilovo, Magistralna ulica Br. 604, Dabilje, Strumica.
As the Project planning of the off-site infrastructure with regard to the overhead power line develops, relevant documents will be deposited at the Municipality of Berovo (Dimitar Vlahov 10, 2330 Berovo, Macedonia). As the Project planning of the off-site infrastructure develops with regard to the water supply for the Project, documents will be deposited at the relevant municipalities.
Public Meetings
A series of public consultation meetings/Open Houses will continue to be undertaken on the Project at key development stages. Announcements will be made in local media (newspapers & radio) and local public places and shops to inform the public on the time, date and location of public meetings/Open House events. These meetings will be set up in co-operation with the Public Liaison Committee and Municipalities. Local community representatives and residents, agricultural land users and business owners in the Project area (or area of relevance for specific off-site infrastructure) will be invited to attend, as well as other interested parties.
Information Office & Notice Boards
There is an Information Office and notice boards in Ilovica and a Euromax Land Acquisition Office located near the site at: Magistralna ulica Br. 604, Dabilje, Strumica.
Information will be disclosed during the construction period, and on the affected community’s Information Boards in Municipality, public places, shops, and other relevant locations. Also, notice boards will be constructed at the entrance of affected areas and at relevant locations near the site. These notice boards will display important information about construction and the Project.
Land Acquisition Consultation Activities
Euromax will undertake consultation with owners and users of Project affected land and assets for the Mine Concession Area, Access Road, OHL and (if land is required) the water supply infrastructure, as outlined in the LARF. The future land acquisition related activities will include:
Consultation on the LARF: Following disclosure of the LARF, a round of consultations with the affected communities and other stakeholders was undertaken to present it and answer questions and gather feedback. A simple 1-page summary was prepared on the LARF, which has been distributed during meetings and is available via the Information Office in Ilovica and the local Municipalities. The LARF has been SEP – Ilovica-Shtuka Project – Final Draft March 2017 26
presented at the Liaison Committee meeting (Oct 2016) and agreement was reached over subsequent engagement activities with affected communities. Ongoing land acquisition and LARF related engagement activities are anticipated to be held with the communities of Ilovica, Shtuka, Turnovo, Sekirnik and Sushica. These may be integrated with data collection activities and engagement with affected land owners and users. Ongoing in parallel to the LARF disclosure and engagement, Euromax will be undertaking the necessary socio-economic data collection in the field on affected land owners and users; this will allow for further engagement with various parties.
Consultation meetings for the development of the Livelihood Restoration Plans (LRPs) /Resettlement Action Plans (RAPs) /Land Acquisition Plans (LAPs): to present the detailed project component footprints and affected land and assets; to announce the socio-economic survey/census and valuations of properties, present the LARF, and present, negotiate and agree on the proposed entitlements matrix and type and method of compensation and assistance.
Socio-economic survey, censuses and valuation of properties (land & assets) will require and be reliant on direct engagement with affected parties. For the collation of additional socio-economic information on land users, specifically in the Concession Area, the Community Liaison Committee and existing relationships with Ilovica and Shtuka (and other affected communities) will be used. Affected user groups (e.g. livestock graziers etc.) will be invited to Open House style meetings to gather data on their use of the Concession and livelihoods, and to discuss entitlement options (e.g. provision of alternative access to other areas etc.). Focus Group meetings of specific land users and owner groups may be established to gather data and engage with affected persons. Other stakeholders (such as community administrators/representatives and other parties (e.g. local vets)) shall be engaged with to obtain data relevant to the LAR process.
Individual meetings as required to support the negotiation of land acquisition and under Macedonian legislation as part of the expropriation process.
Consultation will be carried out on certain specific issues including effects on access to land (e.g. in which season bee hives should be moved as part of mitigation, and how access to agricultural land can be maintained during construction & operation).
Before any of the LRPs/RAPs/LAPs are implemented, Euromax will summarise the information contained in these documents for public disclosure to ensure that affected people understand the compensation procedures and know what to expect at the various stages of the project. When implementation of the Plans begins, Euromax will continue to regularly inform and consult affected people. All meetings and consultations will be documented by Euromax, providing the date when the meeting/ consultation was held, list of attendees, and a summary of the discussions.
Stakeholder Engagement Programme for the disclosure of the ESIA and associated Management Plans
Euromax will ensure that the updated Project description and associated impact assessments are disclosed when the ESIA is in draft form (estimated to be end 2016, although engagement may take place in early 2017). The various Management Plans which describe how Euromax and its contractors will implement controls on environmental, health and safety and community aspects of the project will be shared with affected communities. The Management Plans will be presented at the future Liaison Committee meeting(s) after their finalisation in draft, most likely in groups according to subject matter, and agreement made over subsequent engagement activities with affected communities.
Before any of the Management Plans are implemented, Euromax will summarise the information contained in these documents for public disclosure to ensure that affected people understand the procedures and know what to expect at the various stages of the project. When implementation of the Plans begins, Euromax will continue to regularly inform and consult affected people. All meetings and consultations will be documented by Euromax, providing the date when the meeting/ consultation was held, list of attendees, and a summary of the discussions.
Stakeholder Engagement Programme during the Project Development/Life
Euromax (and their Contractor(s) engaged to undertake the Project) will continue to engage with stakeholders and this Stakeholder Engagement Plan will be continually updated to reflect Project progress. This engagement will cover both the main Mining Project component and the off-site components of the Access Road, Overhead Line and the water supply infrastructure. Particular attention will be placed on communication with any identified
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vulnerable & marginalised groups (through focus group meetings, project leaflets or in other appropriate ways), to ensure Project impacts are appropriately mitigated and relevant assistance provided.
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8. GRIEVANCE REDRESS MECHANISM Euromax recognises that consultation is an ongoing process and that concerns may arise as the Project undertakes land acquisition and moves into construction and operations phases. Euromax has established a Grievance Procedure for the Project. The procedure is designed to receive and address in a timely fashion specific concerns about the Project. It includes a recourse procedure designed to resolve disputes in an impartial manner.
Euromax Grievance Procedure
The full Euromax Grievance Procedure is available on the Company websites (http://www.euromaxresources.com/ in English and http://www.euromax-ilovitza.mk in Macedonian) and at their offices. The procedure covers: Grievance Submission; Grievance Registry Recording; Grievance Analysis & Review (2-stage review); Completion/Corrective Actions and Close Out; and Monitoring.
Euromax is obliged to respond to all complaints according to procedures prescribed in national legislation. The response time for grievances will be in accordance with national legislation for the particular issue in question. Euromax will endeavour to acknowledge receipt of the Grievance within 5 working days, and to respond following the first review process within 15 days of receiving the grievance. At all times, complainants are also able to seek legal remedies in accordance with the laws and regulations of the Republic of Macedonia.
Submitting a Grievance/Concern – Grievance Form
Euromax will accept all comments and complaints associated with the Project and in connection with the land acquisition and resettlement process, submitted either verbally or in writing. A Grievance Form (Part 1) for submission of grievances is provided in Annex A.
The full Grievance Form (in Macedonian and English) is available on the Euromax web site (http://www.euromaxresources.com/ in English and http://euromaxresources.mk/ in both, Macedonian and English), the Euromax Information Centre in Ilovica and all the concerned municipalities (i.e. Municipalities of Bosilovo and Novo Selo) will receive pre-printed forms to be readily- available for the public.
Contact Information for Submitting a Grievance/Concern
Any project affected person or member of the host communities may send comments and/or complaints regarding the Project in person, by phone or via post or email using the contact information provided below.
Borka Kovacevi, Land Acquisition Co-ordinator.
Euromax Resources DOO, Goce Delchev 58, Strumica 2400, Macedonia
Or
Euromax Resources DOO, Blvd Partizanski Odredi, Br.14, 1/2-3, Skopje 1000, Macedonia
Or by telephone: +389 (0) 34 330 088
Or by email to: [email protected]
If additional support is required to complete the Grievance Form the contact information above can be used and support is also available at the Euromax Information Office in Ilovica:
Euromax Information Office, Ilovica 220a, Municipality of Bosilovo
Contact: Elizabeta Stoeva - [email protected] Tel:+389 34 368 888
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9. MONITORING & REPORTING The engagement and interactions with stakeholders are registered in a Tracking Database with defined data about Date of engagement, Group (Name) of stakeholder, purpose of meeting, place and attendees, issues, comments and status or follow up, if required. A more detailed description of the meeting and stakeholder group is recorded in a Stakeholder Engagement Record which summarises the: Attendance, Key discussion points, Type of Engagement, Objectives of engagement, EOX commitments, and Issues Raised/Follow-up Required.
During some of the meetings with stakeholders, socio- economic data is collected from affected owners and users for the land acquisition planning and other Project planning purposes.
The Public Liaison Committee is informed about the process of record keeping and outcomes of engagement with the purpose being to share the aims and progress of the Project planning and land acquisition process with the community and give feedback from the community to the EOX team about issues and concerns.
Any issues or matters for follow up identified during engagements are recorded, passed to the relevant party in EOX and actioned by the relevant party in EOX, including any relevant stakeholder feedback.
10. CONTACT DETAILS & RESPONSIBILITY FOR SEP IMPLEMENTATION Euromax are responsible for the implementation of the SEP and update of this document during the Project’s life. The responsible person in Euromax for fulfilment of the Stakeholder Engagement Plan (SEP) is:
Borka Kovacevic, Land Acquisition Co-ordinator – Ilovica-Shtuka Gold/Copper Mining Project. Address: Magistralna ulica Br. 604, Dabilje, Strumica
Euromax Resources DOO, Goce Delchev 58, Strumica 2400Telephone: +389 (0) 34 330 088 Email to: [email protected]
Support is also available at the Euromax Information Office in Ilovica:
Euromax Information Office, Ilovica 220a, Municipality of Bosilovo
Contact: Elizabeta Stoeva - [email protected] Tel:+389 34 368 888
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GRIEVANCE FORM
Annex A Euromax Grievance Form (for submission of grievance)
EUROMAX RESOURCES LTD. is committed to providing opportunities for resolution of community and environmental grievances.
For our Company to adequately address your grievance, please provide us with as many specific details as possible in this form. Attach pictures or other documents if possible.
All formal complaints must be properly filed out on this form. Please contact the Company Representatives if you require further assistance with this form.
NAME OF COMPLAINANT: TEL NO:
Age: SEX
M F Contact Information (Address):
Town/Community:
PART 1: DETAILS OF COMPLAINT / INCIDENT
COMPLAINT SHORT TITLE:
DATE: PLACE OF INCIDENT (Address/Project Site/GPS Coordinates)
BRIEF DESCRIPTION/STATEMENT
If insufficient space please write on a separate sheet, sign, date and attach to this form.
Signature (Complainant) Date ……………………………………. …………………………………………………………… Signature (CR Staff) ……………………………………. Date ……………………………………………………………
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