Language: English Original: English

AFRICAN DEVELOPMENT BANK GROUP

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) REPORT SUMMARY

FOR THE

ORGANIC SUGAR PROJECT OF PURE DIETS MOZAMBIQUE S.A.

IN

MOZAMBIQUE

0CTOBER 2015

E&S Team: Erika AUER, Senior Social Development Specialist, ONEC3 Kelello NTOAMPE, Environmental Scientist, ONEC3 Sector Director: K. DIALLO Regional Director: K. MBEKEANI Resident Representative: J. RIBEIRO Division Manager: M. CISSE

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) SUMMARY PURELIFE ORGANIC SUGAR PROJECT

1. INTRODUCTION:

This environmental and social impact assessment summary presents the process, approach, outcomes and management plan for the Pure Diets Mozambique SA (herein referred as PDMSA) organic sugarcane cultivation, sugar production and cogeneration (also referred to as ‘cogen’) power plant project proposed at Malangane, Moamba district Maputo Province in Mozambique. The project is located to the South of the Inkomati River bank, in Sabie Administrative Post. Moamba is well connected by road and rail. The distance between Maputo and Moamba is 80 km.

The Pure Life Group is working under the brand “Pure Life” and is operational in several other countries to shift conventional agriculture practices to organic farming. Organic farming is a form of agriculture that relies purely on techniques such as green manure, compost, green harvesting and biological pest control. Organic farming does not uses any chemical, fertilizers or pesticides in the farming practices. Green manure, bio fertilizers bio pesticides are used in farming that have no adverse impact on environment or soil fertility. Organic farming is a strategic fundamental choice for the farmer and PDMSA believes that it is the unique way to ensure a rational and sustainable management of natural resources. The Pure Life Group operates as an organic foods supply chain through its 6 major legal entities in 8 countries with direct access to about 90 boutique corporate consumers / retailers across the world.

As supply chain managers, the Group is involved in the entire farm to fork spectrum from soil preparation to final dispatch of goods to the end customer. It has a team of technical experts handling each level of the supply chain; market analysis, product development, research and development, soil preparation, farming, farmer dialogue and training, production, quality check, food safety, warehousing, dispatch, logistics and distribution.

The Group also collaborates with local agricultural universities in the countries where it has operations to provide technical support to the farmers. It works with over 22000 farmers and over 79000 ha of farmland, some of which are under various organic food certification process. As well as one affiliate organic mill also in India, which is the source of its organic sugar supplies. Pure Life Group also works with farmer groups and has organic food and feed projects in Vietnam, Mozambique and Latin America (in LatAm projects are at nascent stage.) It ensures production and supply of organic produce, including sugar, by deeply involving itself at the grass root level. The company through its team of technical experts in these countries engages in closely monitoring the produce right from soil preparation and overseeing the farm practices to critically observing and evaluating every step of the production processing.

Its project development team identifies local farmers willing to learn and convert to organic farming. Through continuous education and training sessions, Pure Life helps farmers take on organic and Fairtrade practices. Its experts interact with farmers, test soil and seedlings, monitor farming practice, record relevant data required for inspections and audits by organic certification bodies, and ensures compliance with the standards. It has Field Officers trained in imparting knowledge of organic farming.

These experts work with farmers to help them develop farmland and farming activities and practice which meet organic requirements. Pure Life staff organizes regular trainings at its project sites to ensure that the farmers are constantly in touch with the latest standards to be followed. It also provides financial support through distribution of free organic agricultural inputs. The Group has a certification team at its New Delhi office, which works with projects and farmers across India and elsewhere. The Group’s production team regularly monitors the production from the perspective of all the standards like food safety, quality assurance, HACCP, GMP, social and environmental aspects, OSH etc. It ensures that all units have food safety certifications such as ISO 22000, HACCP, Kosher, and Halal if required.

The Group also has track record working with demanding and varied certification agencies worldwide such as OneCert, USDA Organic, FDA, Fair Trade, Control Union and EcoCert. The company has in the past worked with farmers who own their own land, but the company is are closely involved in monitoring farm production and processing activities. It is this wealth of experience working with local farmers and global organic standards which the Group’s management brings to PDMSA. The following table provide a brief overview of Pure Life operations worldwide. The below acreage is totally owned by the farmers, which the Group works with and trains to promote organic farming. Pure Life Group Projects Overview (Organic Crop Production) Name of Country No. of Projects No of registered farmers Reg. area (ha) Tanzania 7 10047 55205.455 Vietnam 7 1361 3575.97 Mozambique 2 2329 8274.35 India 30 8449 12248.717 GRAND TOTAL 46 22186 79304.492

Pure Life Group Projects Overview (Sugar Processing) Name of Country No. of Projects Vietnam 5 India 3

PDMSA has proposed to set up new sugar mill of 3500 tonnes of cane per day (TCD) expandable to a 5000 TCD capacity along with a 12 megawatt (MW) capacity co-generation power project for captive consumption. PDMSA has also proposed to cultivate 4311hectares (ha) of land for organic sugarcane in a phased manner. An additional 650 ha of land shall be used for setting up necessary infrastructure like factory, roads, housing, and reservoirs. Out of this 650 ha, 200 ha is reserved for the factory. The power generated by the cogeneration plant will be utilized for its own consumption and irrigation facilities.

2. PROJECT DESCRIPTION AND JUSTIFICATION:

2.1 Description: PDMSA proposes to implement the organic sugar production 0.45 to 0.9 million metric tonnes (MMT) of cane per year and a sugar mill of 3500 TCD capacity expandable to 5000 TCD for 240 days. In addition, PDMSA will establish a captive cogeneration power plant by end of year 2017. The project will produce sustainable and organic sugarcane and intends to use innovative agriculture practices to support and enhance soil fertility while simultaneously fixing organic matter and carbon in the soil and reduce the environmental and social impacts of the production. Land clearing will be by mechanical methods. Land clearing and preparation will employ procedures to minimize release of greenhouse gases (GHGs). Cleared biomass will not be burnt but chipped and ploughed into the soil during land preparation stage or used to produce compost. Larger biomass will be brought to the plant site and stored for use for producing power during operations.

Irrigation systems will be installed, followed by the planting of the first commercial crop. A variety of irrigation systems will be used including centre pivots, semi-solid sprinkler and sub-surface drip systems in order to optimise agricultural yield and ensure efficient water management for the specific soil. The water rights are issued to all water users based on the water availability and the command area under consideration by the regional water authority Administração Regional de Águas – South (ARAsul). ARAsul will inspect and monitor all the water users in the area every month based on the area under irrigation. PDMSA’s irrigation engineer will monitor the abstraction to ensure compliance with ARAsul requirements. The project will use water from the Corumana dam, which has water storage capacity is 881 million cubic meters without gates. The Mozambique government has provided the approval for installation of gates at the dam during 2016 to 2018 to further increase its storage capacity. After installation of gates the estimated storage capacity of the dam would be 1240 million cubic meters. The command area of the dam for irrigation is 33,000 hectares. Water rights have been given to various stakeholders for irrigation up to 23,000 ha including PDMSA’s 4311 ha. PDMSA has water rights for 43.11 million cubic meters/ annum. ARAsul authorities have confirmed that this quantity of water that can be sustainably abstracted and will not have any adverse effect on the water resources in the area. PDMSA currently has a permit for water usuage, but a more permanent water concession is being discussed with the government to be provided by July 2016; this permit will be valid for 50 years.

The Mozambique Government has also commenced the construction of Moamba Major dam which is expected to be completed in 5 years with the same capacity as that of Corumana dam. This would be advantageous for the project as it will supply water to Maputo city, thereby freeing up water from the Corumana dam for agricultural and industrial users downstream. The project site located nearer to both the dams, and hence it has got high assurance of water supplies.

Planting and harvesting of sugar cane will be done using mechanical planters and equipment respectively. In- field tractor-trailer combination will transport cut sugar cane. Since the sugar content is highest at the base, cane will be cut as close as possible to the ground. The remaining cut will be the base for new cane growth (ratoons) in the following season. The crop is typically replanted after 6 to 8 ratoons. During the replanting phase, minimum tillage techniques will be implemented to minimise the release of GHGs. The replanting schedule will also allow for a fallow crop.

Mechanical harvesting of the cane will leave a blanket of trash leaves and tops in the fields that gradually build up the organic matter and carbon content of the soils which, in addition to being a carbon sink, improves the quality of the soils as well as minimise the growth of weeds.

2.1.1 Sugar Plant Operations Following harvesting, the cut sugar cane is transported within 24 hours to the facility to avoid deterioration of sugar content. Upon receiving at the processing plant, the sugar cane is mechanically shredded, run through a diffuser to extract the juice, and separated from the residual fibres (bagasse). The juice is then put through a clarification and evaporation process. The facility will be designed to be flexible so that some juice can be sent not only for sugar production but also for production.

The processing plant will be in full operation for eight to nine months, approximately June through February (approximately 240 effective days per year). During this relatively dry period sugar cane is harvested and sugar and power shall be produced. Non-operational time shall be used for maintenance of the plant. Production may be extended to later in the rainy season by storing molasses or by purchasing molasses from at other estates.

2.1.2 Power Generation The bagasse will be fed into a high pressure boiler to generate steam and electricity. The steam and electricity shall be used to fully supply the industrial plant and the irrigation system with renewable energy. The facility is designed for efficient and minimum internal use of steam and power in order to maximise the surplus electricity that can be sold to the national power grid. The boiler is designed to also be able to utilise secondary biomass such as wood chips and energy grass as fuel. The boiler flue gas treatment will consist of a filter system to minimise emissions of harmful compounds. Power will be generated for use during the full year with exception for a number of weeks required for maintenance of the boiler.

2.1.3 Effluent & Air Pollutant Treatment Facility Effluent waste stream from the industrial plant has got a high chemical oxygen demand and biochemical oxygen demand makes it a potential hazard to the environment. However, effluent also has high nutrient value. The effluent and the sewage shall be treated and the high quality recycled water used for landscaping. Electrostatic precipitation and wet scrubber will be used to treat other polluting gases generated from project operations.

2.1.4 Utilities & Consumables Water and power are the main utilities required for operating the integrated project. Water will be drawn from the Inkomati River flowing on the border of proposed site. Power required for construction and in case of shut down of plant, will be drawn from the local grid.

2.2 Justification for the Site The proposed site is ideal for the proposed integrated sugar & cogen power project, due to following reasons:  Required land for cane development is available at the project site on lease for PDMSA.  The site is easily accessible by road, and near to Maputo Port and Maputo International Airport.  The command area has huge potential for the sugar cane because of the huge irrigation potential.  The site is near to the Inkomati River which is flowing close to proposed factory premises.

3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

The ESIA for the project was carried out under the following Policy, Legal and Administrative Framework: o The constitution of the Republic of Mozambique in its Article 72 states that "every citizen shall have the right to live in a balanced environment and the duty to defend" and in Article37 "The State shall promote efforts to guarantee the ecological balance and the conservation and Preservation of the environment in order to improve the citizen's quality of life. o The National Environment Policy (approved by resolution 5/95 of 06 December 1995) reinforced the reasoning of other environmental legislation. The main objective of the policy is to provide a tool to ensure that sustainable development can occur, and to allow the use of natural resources in a way that preserves its operation for future generations. o The Environmental Law (Law No. 20/97 of 07 October 1997) applies to public and private sectors and sets the legal basis for the sound use of natural resources in a way that improves the quality of life of citizens, prioritizes the development of techniques that minimize environmental degradation, emphasizes public participation, and integrates principles of payment of polluters. o The legislation of Environmental Impact Assessment (EIA), approved by Decree 45/2004 of 29 September 2004, is applied to all activities of public and private sector. The legislation employs three categories of environment assessment: - Category A: is for projects that could potentially have significant impacts due to the nature of the activity and or environmental sensitivity hosting the project. You are prompted a full EIA. - Category B: is for projects that would have negative impacts but the extent, intensity and duration are less, and the impacts can be largely mitigated. It asked for a Simplified Environmental Study. - Category C: is for projects that have minimal impacts and the completion of an Environmental Impact Assessment are not required.

3.1 Other pieces of legislation and requirements includes: . Prohibition of grasping of marine foliage of Euchema gender by Portaria (Ministerial Legal Instrument) no. 23651 of 12 December 1970 . Regulation of Port Captainship, approved by Portaria (Ministerial Legal Instrument) n. 1097, of March 20th, 1967 . Regulation Relating to the Process of Environmental Auditing, approved by Decree n. 32/2003, of August 20th . Regulation on Bio-medical Waste Management, approved by Decree n. 8/2004, of February 18th) . Regulation on Environment Quality Standards approved by Decree n. 18/2004 of June 2nd . Environmental Regulation on Mining Activity, approved by Decree n. 26/2004, of August 20th vii) Regulation on the Process of Environmental Impact Assessment, approved by Decree n. 45/2004, of September 29th, revokes Decree n. 76/98, of December 29th . Norms of application of fines and other sanctions provided for in environmental legislation, approved by Ministerial Diploma n. 1/2006 . General Waste Management Regulation, approved by Decree n. 13/2006, of June 15th . General Regulation on Marine Fisheries (REPMAR), Decree n. 43/2003, of December 10th . General Aquaculture Regulation, Decree n. 35/2001, of November 13th . Environmental Inspection Regulation, approved by Decree n. 11/2006, of June 15th . Forests and Wildlife Regulation, approved by Decree n. of June 22nd . Land Use Regulation, approved by Decree n. 66/98, of December 8th . Regulation for Industrial Activities Licensing, Decree n. 39/2003, of November 26th . Article 109 – land, Article 110- Enjoyment of Land and Article 111- Rights Acquired Through Inheritance or Occupation of Land of the constitution of Mozambique

3.2 AfDB Requirements: The following Operational Safeguards standards have been triggered:  OS1: an Environmental and Social Assessment will have to be carried out in order to determine the extent of the environmental and social impacts of the project;  OS2: the project and associated project will require involuntary resettlement.  OS3: it is expected that the project will impact the ecosystem service on which the local population depend in in terms of sustenance, livelihood and/or primary income.  OS4: it is expected that the project will cause adverse environmental and social impact owing to emission of pollutants and waste or hazardous materials.  OS 5: the project involves the establishment of workforce.

3.3 Relevant International Treaties and Conventions include:  Dates Relevant International and Regional Conventions; 1982  United Nations Convention on the Law of the Sea (UNCLOS) 1992  United Nations Framework Convention on Biological Diversity (CBD) 1973/78  International Convention for the Prevention of Pollution by Ships (MARPOL) 1998  Convention on Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade (PIC) 2001  Convention on Persistent Organic Pollutants (POPs) 1972 Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (The London Convention) 1997  Convention on the Non Navigational Uses of International Watercourses (Watercourses) 1985 Nairobi  Convention for the Protection, Management and Development of the Marine and Coastal Environment of the Eastern Africa Region and Its two protocols on SPAW and Emergency in Cases of Oil spills) 1968/2003  African Convention on the Conservation of Nature and Natural Resources(Algiers, Maputo) 1992 UN Framework Convention on Climate Change (UNFCCC) 1994  UN Convention to Combat Desertification (UNCCD) 1989  Convention on the Control of Trans boundary Movements of Hazardous Wastes and Their Disposal (Basel) 1991  Convention on the Ban of the Import into Africa and the Control of Trans boundary Movement and Management of Hazardous Wastes within Africa (Bamako).  Millennium Development Goals

4. DESCRIPTION OF PROJECT ENVIRONMENT

4.1 Latitude & Longitude

The area lies between 25 degree, 20’, and 25 degree 30’, south latitudes and between 32 degree 10’, and 32 degree 30’, east longitudes.

4.2 Rainfall The months of June, July, August and September are receiving the lowest rain fall in the year and January to March seems to be highest rainfall receiving months. The rainfall details of the last ten years shows the average rainfall per year is 603 mm. It is noticed that 2003, 2004, 2005, 2006, 2007 & 2008 received below normal rainfall while the balance years in the last decade like 2002, 2009, 2010 & 2011 have received above normal rainfall.

4.3 Temperature & Humidity January to March high temperature levels of about 310C and July to September have low temperatures of about 130C. The wider difference between the day and night temperature is recorded at over 150C during the months June to September is giving the highly favourable diurnal variation for the best sugar accumulation in the sugarcane stalks.

4.4 Evaporation The average evaporation for the last 10 years is about 1505 mm due to less rainfall and high temperature.

4.5 Relative Humidity The Relative humidity is seems to be an advantageous factor as the crop can withstand some prolonged drought with the available irrigation systems. The average relative humidity is 65% in the project area.

4.6 Sunshine hours On average, there is over 8 hours sunshine in Moamba which will facilitate sugarcane crop with better sugar accumulation and sugarcane yield.

4.7 Land Use: Moamba is well connected by road and rail. The distance between Maputo and Moamba is 60 km. An estimated potential arable land of 229,000 ha in the district of Moamba, with land use pattern as follows:  Area occupied by corporate farms are 33,600 ha (24,500 ha of rain fed and irrigated 9,100 ha)  13000 ha are occupied by family farms with an average holding size of 1.3 ha.  Total area occupied by corporate and family farms are 43,600ha which is 20.3% of total arable land in Moamba District.  60,000 ha area occupied as pasture for livestock which is 26.2 % of arable land.  Hence balance of 125,400 ha (53.5%) is the potential area available for further development.  The main crops grown for food by most of the population are Maize, cassava, cow peas followed by sweet potato pea nuts, pumpkins along with vegetables.

4.8 Noise & Air Quality 4.8.1 Daytime Noise Effects During the daytime (0700 to 2200, total Project noise from operations at the factory site ,plus baseline levels is predicted to be well below the IFC daytime LAeq standard of 55 dBA at the closest receptor, Malengane Village. The highest daytime LAeq level (including baseline levels) predicted at Malengane Village (6 km from factory site), is 27 dBA, which is 28.1 dBA below the IFC daytime noise guideline. Based on the information above, no exceedances of the daytime IFC guidelines are projected for any of the nearby receptors within the Study Area (Malengane Village). Therefore, the noise effect of the Malengane Project during the daytime will be insignificant (low severity; low likelihood). No specific mitigation measures are required during daytime operations.

4.8.2 Night-time Noise Effects During the night-time (2200 to 0700), noise from operations at the factory site, plus baseline levels is predicted to be well below the IFC LAeq standard of 45 dBA at the closest receptor, Malengane Village The highest night-time LAeq level (including baseline levels) predicted at Malengane Village (6 km from the factory site), is 26.9 dBA, which is 28.1 dBA below the IFC daytime noise guideline. Based on the information above, no exceedances of the night-time IFC guidelines are projected for any of the nearby receptors within the Study Area (Malengane Village). Therefore, the noise effect of the Malengane Project during the night-time will be insignificant (low severity; low likelihood). No specific mitigation measures are required during night- time operations.

4.8.3 Transportation Noise Effects During the operations phase, movement of trucks (i.e., transport of sugarcane and raw sugar) along the Transport Corridor will result in increased noise levels at nearby receptors along the corridor. Based on observations there are no receptor within 100 m of the factory. Along the corridor (just based on observation; no traffic counts or baseline noise levels were taken along the Transport Corridor). The increase in Project- related truck traffic is expected to increase noise levels along the corridor and as such, result in a moderate noise impact (low severity; high likelihood). Recommended mitigation measures to control the noise emissions are listed below.

4.8.4 One of the main sources of air emissions at the project site and which could potentially generate significant amounts of carbon monoxide (CO) and dust is the burning of open fields which is done as hunting strategy and also the production of charcoal for domestic use is very common.

4.9 Geology / Geomorphology & Soils The project is located in ancient alluvial terraces of the Inkomati River with altitudes ranging between 60 and 85 meters. In this region there is basaltic soils or alluvial terraces in the wide of the Inkomati River floodplain, with a surface layer of organic matter, with a fertility level from medium to high and with a good agricultural potential. The shape, thickness, and the nature of the layers vary according to the extent and strength of the floods that gave rise to the sedimentation process. Most of the proposed area is dominated by alluvial soil and clay being characterized by, deep, well drained with a bulk density of 1.1 to 1.4 g / cm3, total porosity, with groundwater above 4 to 6 feet deep, with a water retention capacity of 12 to 16%. The pH is between 5.7 & 7.1

4.10 Flora Typical vegetation of this region is the savanna and thickets of thorny Acacia spp, and species that accumulate water reserves in the leaves (Euphorbia spp) .These typically occur in shallow soils, reddish, sandy clay. The occurrence of dense forest is limited to a spot the terrain east, with the notable presence of the Euphorbia genus. In sandy and shallow soils, the dominance of Acacia genus species are typical in open woods and alternate with spots with dominance Cobretum spp, occasionally mixed with Terminalia sericea. Associated woody species include Dichrostachys cinerea, Grewia sp. Euclea natalensis, and African Spyrostachys and Sclerocarya birrea. The area is covered with grasses as a result of the conversion by human activity, with the removal of woody component to obtain fuelwood and to open fields for farming and grazing. Much of the area to be occupied at present for the cultivation of cane sugar had its natural vegetation removed during colonial times and was converted to grazing areas

4.11 Fauna In the middle of terrestrial vegetation, it is normal to experience insects, including beetles, mantis, dragonflies, butterflies, moths, flies, ants, bees, wasps, as well as a variety of scorpions and spiders. Larger animals currently exist, only rats and snakes. Due to the proximity of the Inkomati River, in the north land area, we found the presence of gallery forest along their banks constituted by Acacia xanthophloea and Ficus Capri folia showing up sometimes reclinata Phoenix palm tree and the reed Phragmitis communist. Large mammals have not been spotted at the project site but next to the River Inkomati, mammalian species associated with riparian habitats have been observed. These include water ichneumon (Atilax paludinosus), the otter (Aonix capensis) and the mouse sugarcane (Thryonomys swuinderanus). In the very bed of the Inkomati River or on its banks the lizard Nile (Varanus niloticus) and the Nile crocodile (Crocodile niloticus) were observed and nest on the river bank.

In terms of fish fauna, according to Jubb (1967) and Skelton (2001), River Inkomati there is about 50 species of fish. Most of these fish species make seasonal migrations to side tributaries, wetlands, and floodplains for breeding. On the other hand, Anguilla marmorata, Anguilla bengalensis labiata, Anguilla, Mozambican and Anguilla bicolor which go to the sea for reproduction purposes also occur.

4.12 Hydrology Moamba and the area where it is to implement the draft organic production of cane sugar, is located about a hundred meters from the Inkomati the bed, which is the main supplier of water. This Inkomati River rises to about 2000 m altitude in the plateau and mountainous area west of the basin. The Inkomati River Basin has an area of 46,700 square kilometers and is shared by South Africa, Swaziland and Mozambique. About 33.4% of the basin lies in Mozambique and is below 200 m elevation, essentially a flood plain lying east of the Lebombo mountain range. The main tributaries of this river are the Komati, the Crocodile and the Sabie. 80% of the total flow, occurs between the months of November and March.

4.13 Baseline details about Socio Economic status In 2007 the District of Moamba, had 56,559 inhabitants. The projections of the National Institute of Statistics, estimate a population of 68,231 individuals in 2015. A population with a sex ratio of 93 means that the population is affected by male emigration movement. Reasons include close proximity to the border with South African Republic and Swaziland. Moreover, there are no employment opportunities.

4.14 Education Levels 51% people of 5 years or more (predominantly men) attend or have already attended primary school. The highest range of access to schools have been noted in the age group of 10 to 14 years (64%) and being followed by the age group of 5 to 9 years. This reflects that majority of the rural children take late entry to the school. The majority of these children who attend primary education are boys. This is primarily due to the inadequate or non-existent school network teachers in the district.

4.15 Housing, Electricity and Sanitation The district of Moamba has 10,602 houses out of which around 80% are made from straw or other locally available material. ~12% are apartments or constructed houses and ~8 % are made from Zinc and wood. ~22% of the household have municipal water connection and ~57% of the population has access to sanitation facilities. However, good quality facility is consolidated only in the areas where people have apartments or house. The population in the proposed project area has got very limited sanitation facilities.

Power is on the national EDM power distribution system which is present in the town of Moamba. The direction of the current project is in coordination with the EDM and has already made the extension of the power grid to the project area. The availability of electricity is a major problem in the area with only 13% of the total population having access to regular supply of electricity. Around 41% of the population has access to radio and the number is expected to increase drastically due rapid increase in utilization of mobile phones in the area.

4.16 Drinking Water Availability With regards to the sources of supply of water, 40% of the people use water directly from rivers or lakes and 27% from the well or holes. Most of the available existing water supply schemes have quality problems. As a result, many people who use unclean sources suffer from water borne diseases.

4.17 Livelihoods Most of the people practice rudimentary subsistence agriculture, rearing goats and chickens. Some families have small stalls and trade various commodities. Some people are involved in in logging, selling firewood or producing charcoal.

4.18 Conflict Resolution Process The conflicts within the community are generally resolved within the purview of law. In case of any conflict within the community the following are approached in the following order: - Village Authority (Approved by Government) - Local Authority - Forum of Local Leaders (Approved by Communities) - Administrative Level - Provincial Levels - National Level

4.19 Health Facilities, HIV and Vector Diseases Most illnesses are communicable, directly or indirectly, and are related to lack of adequate and safe drinking water supplies and sanitation, low living standards and poor nutrition. Waterborne and vector borne diseases are also prevalent in the area. The prevalent diseases in the project area include malaria, intestinal parasites, diarrhoea, etc. Most of these diseases are not only causes of illness and suffering but also hospitalization. Malaria has the most victims followed by diseases such as HIV/AIDS, diarrhoea, measles, pneumonia, TB and typhoid. Malnutrition is prevalent and observable, especially, among the people in the age group of 5-10 years. More services for the prevention, control and cure of infectious diseases, particularly vector-borne ones, are required. Based on preliminary field assessment, it has been possible to identify the following problems associated with health service system:

- Health institutions are limited and hardly ever located in rural areas. - Lack of qualified health staff - Inadequate supply of drugs and equipment - Budgetary constraints

4.20 Cultural Resources The project surroundings have been investigated in terms of religious and cultural site and archaeological importance. There are no World Heritage listed sites or recorded archaeological sites in the project area. Tsonga language (Tsonga) and Portuguese are the main languages in this region. The main ethnic group is Tsonga and a wide range of religious groups exist in the study area with significant proportion of followers. Major religions practiced in the project area are Christianity (67.6%) and traditional religions (22.9%).

5. PROJECT ALTERNATIVES

5.1 The assessment of alternatives considered alternative in five categories:  Demand alternatives (e.g. producing only rather than developing the proposed project area for edible sugar production, applying less developed power generation concepts, which generate significantly less power to the local grid, locating the project site to a different area in the district, region or nation);  Process alternatives (e.g. re-use of waste material, the use of other technologies);  Schedule alternatives (e.g. restricting construction or operations to a certain time of year).  Input alternatives (e.g. use of other raw materials)  Scale alternatives (e.g. changing the scale of the proposed development in order to comply with environmental and social requirements).

5.2 A range of systematic methods was used to compare and evaluate the various alternatives including checklists, overlay maps, matrices etc. The following economic, environmental and social aspects were considered while selecting this site: - The site is located in upland area with excellent gravitation drainage system (indicated in water management plan) and hence there is absolutely no risk of flooding and damage to the crop. It was observed that the other sugar plantation located in low land areas have the risk of flood and crop damage and hence incurring the economic loss. - The land in this project area is not used for doing any agricultural activity and as per government records it’s a bushy land. Hence redeveloping the land for sugarcane plantation will not result into any loss of agricultural income. - There is sufficient availability of water for irrigation (as indicated by ARAsul post consultation with downstream users and regular monitoring of water levels) and hence scarcity of water for irrigation purpose is not envisaged. - Due to the upcoming Moamba Dam the water security will be even more strengthened. - The area is scarcely populated hence there will be negligible disruption with the population habitat. - There are no world heritage sites, archaeological sites and sacred sites within the project area and hence no loss to the cultural heritage is envisaged. - The community in the vicinity of the site have very limited socio economic resources, the project would make positive impacts on their lives in terms of employment, Medical facilities, education, sanitation and drinking water facilities etc. - The access roads to this area are either not available or damaged, the project would help in developing access roads thereby improvising economic activities and increasing income generation operations. - A railway line is proposed to be developed on the eastern side of the project area thereby providing logistic support to the project. - Maputo International Airport and Port are just 90kms away thereby providing the logistic support and enhanced economic mobility. - Availability of sufficient local workforce to cater the needs of plantation activities, project would generate sufficient employment in the area. - The soil conditions and climate is highly conducive for sugarcane plantation.

5.3 No Project Alternative If the project is not undertaken and if the currently land use were to continue the remaining pockets of valuable biodiversity currently in the area would in all likelihood be decimated by the rapidly increasing unsustainable charcoal making, releasing comparatively great amounts of carbon to the atmosphere. The project’s public benefits such as increased revenue to the government, improved infrastructure, introduction of a new cash crop and thousands of employment opportunities would not be realised. The No Project Alternative would also aggravate the poor socio economic conditions of the community.

5.4 Site Alternatives The project is the one of the largest organic sugar project taken up in a planned manner in Mozambique. The project site was selected due to proximity to Maputo Airport and Maputo Port, access to infrastructure, land ownership structure and the existence of surrounding villages that are willing to participate in the project. After discussions with Government of Mozambique and other relevant stakeholders the company was advised to develop this project in Malangane.

5.5 Technology Alternatives The technology of the operation of a large-scale sugar cane plantation is well established in Mozambique. However the technology of utilising modern irrigation systems and processing sugar cane into sugar and power is well established in neighbouring South Africa, Brazil and India where the process technology providers are coming from. Therefore, the risk of uncertainty in functionality from establishing the chosen technologies is minimal.

6. POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS

6.1 Summary of Negative Impacts Construction Phase - Change in population level due to influx of workers and labourers causing pressure to social services, food and facilities - Soil erosion due to runoff effects and loosened top soil during ploughing and planting - Changes in the quality of surface water due to various pollutants - Changes in the level of crime due to increased number of people in the area - Increase in the risk of communicable diseases (e.g. HIV/AIDS) and human health due to increased population of workers and social interactions - Change in the level of traffic intensity and traffic accidents due to increased number of vehicles concurrently with better transport facilities - Loss in the village workforce to the project - Loss of biodiversity during clearing and establishment of the plantation - Fair compensation for land and other properties to be affected by the project

6.2 Summary of Negative Impacts Operational Phase - Localised changes in surface and groundwater hydrology due to the project activities notably irrigation. - Changes in the quality of surface and groundwater due to waste and other pollutants - Potential interference with migration routes of animals - Increase in the level of crime due to increase in population in the area - Interference with aquatic ecology - Increase in the risk of communicable diseases and human health due to increased population of workers and social interactions - Increase in population due to influx of workers and labourers increasing pressure to social services, food and facilities - Increase in the volume of traffic intensity and traffic accidents due to project activities concurrently with better transport facilities. - Increase in income in the village will lead to youth resorting to prostitution, drinking and loss of morality - Increased resource use conflicts, particularly land and water - Loss in the village workforce to the project. - Loss of access to the natural resources found at the barren project area e.g. for grazing, hunting (poaching) and charcoal making - Gas emissions

6.3 Summary of Negative Impact Decommissioning Phase - Soil erosion due to run off effects and loosened top soil due the removal of sugar cane - Loss of employment and income to workers, local economy and the nation - Change in life style and quality of workers due to loss of employment

6.4 Summary of Positive Impacts of Project - Employment generation for the Community - Economic development of the community - Community will get access to better education facility - Community will get access to medical facility - Community will get access to safe drinking water - Community will get access to better housing, sanitation facility - Community will get access to public infrastructure - Community will get financial inclusion through ATMs and Bank Branch

7. MITIGATION:

7.1 Climate and Air Quality . Dust suppression as needed, i.e., watering disturbed areas during dry and windy conditions; . Use of new bagasse and trash-fired Cogeneration Plant with high energy efficiency boilers; . Regular maintenance of the boilers and all equipment; . Installation of emission reduction systems, such as wet scrubbers or electrostatic precipitator (ESP) technology, on the boilers. . Climate Risk Assessment and Development of Adaption Plan.

7.2 Greenhouse Gases  Ensure densification of vegetation on fringes of cultivated lands  Location of factory at the center of the Project Area to minimize traveling distance for trucks transporting cane to factory and ultimately minimizing diesel consumption;  Use of bagasse (90 percent) and non-hazardous waste (9 percent) as fuel for the Cogeneration power plant boilers to produce onsite power and heat requirements (renewable fuel);  Transport of concentrated vinasse to cane field for reuse as fertilizer;  Facilitate the planting of trees and other afforestation to offset loss associated with cleared areas;  Ensure use of well maintained, high efficiency diesel motors for the portable irrigation pumps and mobile drainage pumps;  Ensure use of energy efficient lighting, heating, and ventilation at factory site;  Where feasible, practice no till and/or minimum till at planting;  Ensure maximum efficiency of tractor passes per hectare during cultivation and crop maintenance;  Ensure precision application of synthetic nitrogen;  Ensure maximum energy efficiency of the conversion process ( and raw sugar production); and  Ensure adequate maintenance of all transport vehicles.

7.3 Noise  Regular maintenance of all trucks in accordance with manufacturer’s specifications;  Install sound suppressive devices (such as mufflers) on the trucks;  Educate truck drivers and ensure they do not exceed a speed limit of 50 km along densely populated areas along the corridor.  Deployment of acoustic chambers wherever necessary

7.4 Geology, Topography, and Soils  Implement soil erosion, storm water runoff, and sediment control measures, including the use of appropriate best management practices during clearance activities.  include clearing only small tracks of land at one time and minimizing the length of time that the cleared areas for industrial use are void of vegetation or for agriculture use not under active cultivation;  Schedule the majority of the construction and land preparation activities, to the extent practicable, to occur in the dry season and when land has been appropriately drained, or by limiting off-road access, and by implementing an awareness education and training program;  Use of improved equipment, such as chain drags between bulldozers and the use of root rakes, floating blades, and careful/knowledgeable equipment operators;  Spill control will be exercised by inspecting equipment, hiring trained and dedicated feelers and implementing a Spill Prevention and Countermeasures Plan (SPCC). The SPCC Plan describes measures to be implemented by PDMSA and its contractors to prevent, and if necessary, contain and control inadvertent spill of hazardous material such as fuels, lubricants, and chemicals, containment walls, and other measures. In addition, a training module will be developed to educate employees on the SPCC Plan.

7.5 Biological Resources

7.5.1 Terrestrial Biological Resources The following measures are recommended to mitigate potential biological resources impacts:  Rehabilitation of the Project Area once the Project is concluded;  Include a 50-90 meter wide buffer area Inkomati River to preserves a band of natural, seasonally  flooded habitat within the most species rich and diverse habitats;  Containment of oil, fuel, and chemicals with bunds or similar devices;  A Spill Management Plan will be developed and implemented, which will contain specific measures for safe handling and storage of hazardous materials;  Enforcement of speed limits on roads to minimize vehicular collisions with wildlife and driver education trainings to reduce wildlife injury and mortality;  Worker education on the species of concern in the area and how to avoid impacting them; and  Maintain corridors to allow for movement of large mammals.

7.5.2 Aquatic Biological Resources Creation of a 50-90 meter wide buffer zone along Inkomati River that preserves a band of natural, seasonally flooded habitat for the aquatic fauna

7.6 Social Economical & Cultural Resources  Completion of archaeological field surveys in previously undisturbed portions of the Project site;  Establishing a Chance/accidental Find Program and training for Project managers and workers; and  Maintaining flexibility in final Project design to protect any unanticipated finds.

8. MONITORING PLAN

SL# Action Plan Budget Timeline/ in USD Frequency 1 Purchase of High Volume Air Sampler for Air Quality (PM10, NOx, SOx, CO), 15000 Jan 2015 Noise ,Water Quality and Soil Quality Monitoring Equipment for carrying out monthly in-house monitoring 2 In house Air Quality & Noise Level Monitoring 50000 Fortnightly 3 In house Effluent Quality Monitoring 80000 Weekly SL# Action Plan Budget Timeline/ in USD Frequency 4 Annual Monitoring of the Air Quality, Water Quality, Noise Levels and Soil 30000 Annually Quality parameters by third party laboratory 5 Conducting Workshop- Worker Health & Safety Management 50000 Quarterly 6 Purchase of Applicable Personnel Protective Equipment for In-house Staff 75000 Annually 7 Purchase of Fire Fighting Equipment’s for Project office- Class A B C as 20000 Annually applicable 8 Comprehensive Capacity Building Program for 2 Safety Engineers 10000 Mar 2016 9 Appointment of dedicated HSE Manager 90000 Jan 2016 10 Health and Safety Training of EPC Contractor 80000 Quarterly 11 Development and Implementation of ISO 14001:2004 and OHSAS18001:2007 30000 Feb 2016 Management System -For Pure Diets Mozambique SA 12 Developing and Implementing EPC Contractor HSE & Social Guidelines for 15000 Dec 2015 Man, Material or Machinery Contract 13 EPC Contractor Monitoring - health Safety Environment & Social Compliance - 60000 Annually Annual Reporting by Third Party 14 Developing and Implementing Social Accountability SA8000:2008 Management 17000 Mar 2016 System 15 Developing GHG Accounting System Framework as per WRI 55000 Aug 2016 Guidelines/ISO14064 SCOPE 1 & SCOPE 2 16 Developing and Implementing Global Reporting Initiative Framework GRI 4- to 105000 Annually Report Pure Deits Annual Performance of Sustainability, Environmental & Social Issues to ALL THE LENDERS & Stakeholders 17 Conducting HIV/AIDS & vector Diseases Awareness Program for Community 20000 Quarterly 18 Conducting Community Perception Survey on E&S, Economic Aspects 50000 Annually 19 Independent E&S audit- annual basis as suggested by lender group 80000 Annually 20 Climate Adaptation studies 50000 Oct 2016 21 Surface and Ground water Hydrology Modelling 40000 Dec 2016 22 Implementation and Training of the E&S management plans (Already 180000 Project Developed): Cycle - Construction Environmental Management ; - Worker Health and Safety Management; - Biodiversity Management; - Catchment Management; - Waste Management, Reuse and Recycle; - Worker Health and Safety Plan - Labour Housing Plan Total (in USD) 1 202 000.00

9. CONSULTATIONS

Consultation were held with communities, Project Affected People (PAP), community leaders, local officials & the district administrator on 7 December 2011 and on 23 September 2013 to ensure that all people are included in the discussions, a total of 120 people in total attended the meetings. The objective of the meetings were: - To give PAPs a chance to have a say and express their views in the planning and implementation of the project that affect them directly. - For PDSA to understand the community needs in order to design relevant and sustainable income generating activities for the community. - To discuss the social value from the project (like school, employment, enhanced medical facilities, overall economic development, stabilized livelihood, Initiatives for HIV/AIDS, vector diseases, Women Health issues, Cattle Management, Drinking water and Food Security - To inform local authorities of the impacts, agree on a cut-off date, solicit their views on the project and discuss their share of the responsibility for the smooth functioning of the overall project operations.

Further consultations were carried out with the following stakeholders: - District Administrator of Moamba - Malengane Community - Gowane Community - Mwamongolonbi Community - Mwamayanga Communities

Key concerns raised by communities mostly were focussed on how the project will benefit them. Specific issues pertained to financial benefits once the project starts making profit, Job creation, irrigation of their own farming areas, development of other areas for agricultural purposes by the community and provision of alternative grazing land. In turn PDSA promised, provision of schools, development of access roads and improvement of transport facilities, electricity supply for the area, development of health facilities, provision of clean drinking water, vocational training facilities, special assistance to people from vulnerable groups such as old people, people with disabilities, medically incapacitated people, assisting in developing community centers and places of worship.

The concerns expressed were captured in a MoU which was signed between the communities Malengane, Mwamungolombi and Mwamanhanga, the District Administrator and Pure Diets Mozambqiue SA on 18 October 2013. However, as the project progressed, PDMSA has not managed to fulfil all of the actions as committed to in the MoU in the planned timeframe such as construction of water tanks and water lines, construction of class room in two communities, construction of health centres, completion of electrical transmission lines and this has led to some concern among the community members and if not addressed adequately may lead to mistrust within the communities against the project. The main causes for the delays are due to challenges faced by PDMSA such as change in the project’s management structure, change in the community relationship team, and delay in mobilization of funds.

Nonetheless, PDMSA has now made some progress in terms of construction of temporary housing for PAPs (to be completed by October 2015) and providing employment to the PAPs. The permanent housing arrangement shall be completed within six months of temporary housing. PDMSA shall ensure the socio economic development of the PAPs as per the requirement of regulations for the resettlement process resulting from economic activities decree 31/2012 of 8 August Article 1- 28.

PDMSA has identified the following community activities to be completed on priority basis:

1 Ploughing Community Lands Ongoing- To be Completed by Nov 2015 2 Construction of 2 class room in Mwamayanga school To be Completed by Aug 2016 3 Construction of 1 class room in Mwamungolombi To be Completed by Aug 2016 school 4 Construction of Water Tank in Mwamungolombi To be Completed by June 2016 5 To be started from Jan 2016- Continual Technical Training Programme for Youth Basis 6 Awareness programme on HIV / AIDS, Vector To be started from March 2016- Monthly diseases Basis 7 To be started from March 2016- Monthly Awareness programme on Women Health Basis 8 Construction of Community Water Tanks Ongoing-To be Completed by April 2016

In order to ensure that corrective measures are taken, PDMSA has developed a Community Engagement Plan (CEP) which lists all of the committed to activities as per the MoU as well as additional social development activities that have not been included in the MoU but that will be undertaken as a result of the project. These activities will be tracked with a completion timeline and progress update and PDMSA will be required to report on the progress to the lenders on a regular basis.

10. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

Standard operating procedure along with high quality pollution control equipment/plants shall be put in place for managing environmental resources. Furthermore, environmental management plans have been developed/proposed for the project to ensure appropriate procedures are in place to mitigate the negative impacts identified in the ESIA. As part of the programme, specific control plans have been developed or proposed for the following: - Construction Environmental Management ; - Worker Health and Safety Management; - Biodiversity Management; - Catchment Management; - Speciality Study – Air Quality & Noise Modelling, Hydrological and Climate Studies; - Environmental Monitoring Plans - Waste Management, Reuse and Recycle; - Carbon Emission/GHG Accounting; - Environmental Pollution Control Equipment - Archaeological and Historical Management; - Community Engagement and CSR Management Plan - Worker Health and Safety Plan - Labour Housing Plan - Traffic Risk and Safety Plan - PDMS- Internal Regulation (Defining employment conditions and labour regulation) - Approved by Government of Mozambique (See Annexure for ESMP)

11. CONCLUSION The negative environmental impacts that may result from the execution of this project can all be managed through implementation of the ESMP (below).

12. CONTACTS:

1. Kelello Ntoampe, Environmental Scientist; Email: [email protected]; Ttel: +22520262708

2. Erika Auer, Senior Social Development Specialist. Email: [email protected]; Tel.: +225 2026 2269.

Annex 1: Environmental and Social Management and Monitoring Plan

Aspect, Potential Actions to Mitigate Impacts Responsible Parties Means of Verification That Training/Resources Schedule for Related Plans Impact/Issue Commitment Has Been Met Required Implementation 1. Construction Phase: Development of Sugarcane Plantation Air Quality: Dust and GHG o Dust suppression as needed, i.e. Construction contractors supervised by Air Quality monitoring If necessary, consultant to Air Quality Monitoring Annexure 25 –P3- emissions from land clearing, land watering disturbed areas during PDMSA’s HSE Team (to conduct visual program; implement Air Quality Program to be carried out Construction conversion (change in carbon dry and windy conditions; inspections); Monitoring program; over the entire construction Environmental stocks) and planting activities. o Ensure densification of vegetation phase with daily readings of Management Plan on fringes of cultivated lands (i.e. Daily visual inspections during dust emissions; Un-cleared forested area); land clearing are done so that Training of construction PDMSA- o Facilitate the planting of trees and vegetation remains dense along contractors with respect to Environmental Policy other afforestation to offset loss fringes of cultivated land and which vegetation and trees One time calculation of associated with cleared areas; matured trees. should not be cleared and expected GHG emissions o Avoid clearing trees which are in where to use no till or use prior to clearing a mature or climax state; minimum till planting Activities. Quarterly o Where feasible, practice no till techniques monitoring of GHG. and/or minimum till at planting Soils: Erosion and sedimentation o Implement soil erosion, storm Construction contractors are supervised by Daily visual inspections during Training of construction Training to be Annexure 25 –P3- from land preparation for new water runoff and sediment control PDMSA’s HSE Team; best practice forest vegetation clearance and contractors on soil erosion, conducted prior to earth Construction agricultural and renovation of measures, including the use of management enforced by relevant national grubbing, ditch/drain storm water runoff and movement/land Environmental existing fields for the sugarcane appropriate best management agencies; construction and canal sedimentation control clearing activities Management Plan plantation (vegetation clearance practices during clearance rehabilitation, landscape measures (i.e. clearing small and grubbing, ditch/drain activities. Best management PDMSA’s staff in charge of logistics to grading and re-contouring to tracks) Daily visual inspections to PDMSA- construction and canal practices can include clearing schedule construction activities during ensure that erosion be carried out during periods Environmental Policy rehabilitation and expansion, only small tracks of land at one preferred times. and sedimentation are of significant land landscape grading and re- time and minimizing the length of minimized by construction preparation contouring to ensure proper time that the cleared areas for Awareness related education and training contractors. drainage) industrial use are void of program to be implemented by PDMSA’s vegetation or for agriculture use HSE Team. not under active cultivation; o Schedule the majority of the construction and land preparation activities, to the extent practicable, to occur in the dry season and when land has been appropriately drained, or by limiting off-road access and by implementing an awareness education and training program; Water Quality: Impacts on o Protect all areas susceptible to Construction contractors are supervised by Daily visual inspections during Training of construction Training to be Annexure 25 –P3- Surface water quality erosion by installing necessary PDMSA’s HSE Team; best practice forest vegetation clearance and contractors on soil erosion, conducted prior to earth Construction temporary and permanent management enforced by relevant national grubbing, ditch/drain storm water runoff and movement/land Environmental drainage works as soon as agencies construction and canal sedimentation control clearing activities Management Plan possible and by taking any other rehabilitation, landscape measures (i.e. clearing small measures necessary to prevent PDMSA’s staff in charge of logistics to grading and re-contouring to tracks) Daily visual inspections to PDMSA- storm water from concentrating in schedule construction activities during ensure that erosion be carried out during periods Environmental Policy streams and scouring slopes and preferred times. and sedimentation are of significant land steep banks. minimized by construction preparation Awareness related education and training contractors program to be implemented by PDMSA’s HSE Team. Water Quality: Increases in o Any runnels or erosion channels Construction contractors are supervised by Daily visual inspections during Training of construction Training to be Annexure 25 –P3- turbidity and salinity in surface developed during the construction PDMSA’s HSE Team; best practice forest vegetation clearance and contractors on soil erosion, conducted prior to earth Construction water from releases of turbid water or maintenance period shall be management enforced by relevant national grubbing, ditch/drain storm water runoff and movement/land Environmental due to the physical disturbance of backfilled and compacted and the agencies construction and canal sedimentation control clearing activities Management Plan soil during earthmoving activities, areas restored to a proper rehabilitation, landscape measures (i.e. clearing small brackish discharges from saline condition similar to the condition PDMSA’s staff in charge of logistics to grading and re-contouring to tracks) Daily visual inspections to PDMSA- soils disturbed by earthmoving and before the erosion occurrence schedule construction activities during ensure that erosion be carried out during periods Environmental Policy acidic drainage from pseudo-acid o Prevent storm water damage, the preferred times. and sedimentation are of significant land sulphate soils in the north block. increase in storm water runoff minimized by construction preparation resulting from the construction Awareness related education and training contractors activities must be estimated and program to be implemented by PDMSA’s the drainage system accessed HSE Team. accordingly. Terrestrial Biological Resources: o Include a 50-100 meter wide PDMSA to ensure buffer is maintained Periodic visual inspections to Training of construction Training to be Annexure 25 –P3- The permanent loss of the MFM, buffer area along the Inkomati during construction; biological resource ensure buffer is being properly contractors with respect to conducted prior to earth Construction SSMFP, MHFS, SWE and SWP River to preserve a band of management enforced by LAW and maintained during land clearing the buffer area that should movement/land Environmental habitats natural, seasonally flooded habitat overseen by conservation institutions. activities. be maintained and the clearing activities and Management Plan within the most species rich and importance of this buffer refreshed bi-annually diverse habitats. PDMSA- Environmental Policy Annexure 25 –P6- Biodiversity Management Plan Terrestrial Biological Resources: o Containment of oil, fuel and PDMSA’s HSE Team and Construction Periodic visual inspections to Training of construction Training to be conducted Annexure 25 –P3- Habitat degradation from chemicals with bunds or similar contractors supervised by PDMSA; proper ensure proper management and contractors and PDMSA prior to use of hazardous Construction Hazardous Material Spills devices. management of hazardous materials handling of hazardous employees on management materials and refreshed Environmental enforced by LAW materials; any evidence of of hazardous materials and quarterly Management Plan o A Spill Management Plan will be significant spills or poor Spill Prevention and developed and implemented, management to be Countermeasures (SPCC) PDMSA- which will contain specific photographed and logged in an Plan Environmental Policy measures for safe handling and HSE database storage of hazardous materials. Annexure 25 –P6- Biodiversity Management Plan Terrestrial Biological Resources: o Enforcement of speed limits on PDMSA to coordinate with local authorities Database tracking traffic related Driver safety training to all Training to be conducted Annexure 25 –P3- Mortality, disturbance, roads to minimize vehicular to enforce speed limits infractions workers, including prior to the start of transport Construction displacement, or injury to wildlife collisions with wildlife and driver contractors, who are activities or land movement Environmental caused by vehicular traffic, education trainings to reduce PDMSA to implement driver education Documentation of driver and expected to drive as part of and refreshed quarterly Management Plan construction equipment, wildlife injury and mortality; program, emphasizing the importance of wildlife management training their duties. construction workers and the loss obeying traffic laws provided and attendance Worker fatigue and stress PDMSA- of habitat. o Worker education on the species records of those training events Integration of a worker management program to be Environmental Policy of concern in the area and how to PDMSA’s HSE Team to implement training fatigue and stress implemented on an on- avoid impacting them; on species of concern and mitigating Implementation of Biodiversity management program for going basis but initiated Annexure 25 –P6- impacts to those species Monitoring Program, which long haul truck drivers. prior to the start of transport Biodiversity o Maintain corridors to allow includes visual inspection of activities Management Plan movement of large mammals. PDMSA’s HSE Team (or biologist wildlife corridors and records If necessary, procurement of contractor) to implement Biodiversity signs of disturbance (i.e. expert biologist consultant Biodiversity Monitoring Monitoring Program which will monitor movement into other areas) and to implement Biodiversity activities to be conducted migration corridors incidences of mortality Monitoring program monthly, or as needed, during construction Terrestrial Biological Resources: o See mitigation involving buffer See above See above See above Biodiversity Monitoring Annexure 25 –P3- Impacts (such as those mentioned area and worker education above activities to be conducted Construction above to general wildlife) to as they apply to protecting species PDMSA’s HSE Team (or biologist Implementation of Biodiversity If necessary, procurement of monthly, or as needed, Environmental observed species of concern near of concern contractor) to implement Biodiversity Monitoring Program, which expert biologist consultant during construction Management Plan Inkomati River Monitoring Program which will monitor includes tracking the presence to implement Biodiversity PDMSA- impacts to species of concern of species of concern and Monitoring program Environmental Policy evaluating effectiveness of Annexure 25 –P6- mitigation measures to protect Biodiversity species of concern Management Plan Aquatic Resources: Increased o Conduct Canal and other PDMSA to supervise contractor procured Supervision of maintenance If necessary, procurement of Water Monitoring activities Annexure 25 –P3- turbidity in the vicinity of the river connected waterway maintenance for maintenance to ensure activities are activities will confirm the consultant to implement to be conducted monthly, or Construction activities during periods of high conducted during high flow Water Monitoring program from suspension of clay when the flow in the Inkomati River, which implementation of activities as needed, during Environmental irrigation canal is widened. would increase dilution potential during periods of high flow. construction Management Plan downstream of the Canal. Water Monitoring Program will PDMSA- track turbidity levels at mouth Environmental Policy of the Canal Annexure 25 –P6- Biodiversity Management Plan )

Aspect, Potential Actions to Mitigate Impacts Responsible Parties Means of Verification That Training/Resources Schedule for Related Plans Impact/Issue Commitment Has Been Met Required Implementation Aquatic Resources: Impacts to o See mitigation measures above PDMSA’s HSE Team (or contractor) to Water Monitoring Program will If necessary, procurement of Water and Biodiversity Annexure 25 –P3- aquatic resources as a result of related to erosion and implement Water Monitoring Program track changes in water quality consultants to implement Monitoring activities to be Construction changes in water quality (DO, sedimentation. which will monitor changes in water quality both inside and outside of the Water and Biodiversity conducted monthly, or as Environmental conductivity, pH) mainly from Project Area Monitoring programs needed during construction Management Plan increased turbidity Biodiversity Monitoring PDMSA- Program will track changes in Environmental Policy overall presence and condition of aquatic resources Annexure 25 –P6- Biodiversity Management Plan

2. Construction Phase: Construction of Organic Sugar Production Facility Air Quality: Dust emissions from o Dust suppression as needed, i.e. Construction contractors supervised by Air Quality monitoring program If necessary, procurement of Air Quality Monitoring Annexure 25 –P3- land clearing/ preparation of plant watering disturbed areas during PDMSA’s HSE Team(to conduct visual consultant to implement Air Program to be carried out Construction area, grading of access roads, dry and windy conditions inspections) Quality Monitoring over the entire construction Environmental excavation and increased vehicle program phase with daily readings of Management Plan traffic on unpaved roads dust emissions PDMSA- Environmental Policy Soil: Erosion and sedimentation o See mitigation measures above See Above See Above See Above See Above Annexure 25 –P3- from the construction of the various for erosion and sedimentation Construction industrial facilities. under “Development of the Environmental sugarcane plantation” as they Management Plan apply to the construction of the processing facility as well PDMSA- Environmental Policy

Annexure 25 –P6- Biodiversity Management Plan

3. Operations Phase: Operation of Sugarcane Plantation Air Quality: Combustion o Ensure use of well maintained, PDMSA responsible for procuring high Air Quality monitoring program If necessary, procurement of Initial selection of high Annexure 25 –P3- emissions (including GHG; CO2, high efficiency diesel motors for quality equipment and overseeing that consultant to implement Air efficiency motors to be Construction CH4 and the portable irrigation pumps and operation contractors use and maintain Quality Monitoring made during project design Environmental N2O) from machinery mobile drainage pumps equipment according to manufacturer’s program as a result of the alternatives Management Plan used for cultivating and harvesting specifications and maximize efficiency of analysis (non-road mobile diesel engines), o Ensure maximum efficiency of tractor passes Training of operation PDMSA- from mobile drainage pumps and tractor passes per hectare during contractors on maintenance Air Quality Monitoring Environmental Policy portable irrigation pumps (internal cultivation and crop maintenance; of motors and pumps, Program to be implemented combustion engines) identifying problems with quarterly during operation equipment and measures for maximizing efficiency of Training on equipment tractor passes maintenance and tractor passes to be issued prior to Initial investment required the operation phase for high efficiency equipment Soil: Soil contamination from spills o Use of improved equipment, such PDMSA is responsible for procuring high Periodic visual inspections to Training of operation Training to be conducted Annexure 25 –P3- or leaks of lubricants, fuels and as chain drags between bulldozers quality equipment and overseeing that ensure adequate spill control contractors on (i) best prior to the start of operation Construction other chemicals, mainly pesticides and the use of root rakes, floating operation contractors use and maintain measures are in place and practice use & maintenance and be refreshed as needed Environmental and herbicides that will be used blades and careful / equipment according to manufacturer’s elements of the SPCC Plan are of equipment to reduce soil based on results of the Management Plan during the operation of the knowledgeable equipment specifications generally being implemented contamination from spills; inspections plantation. operators (ii) management of PDMSA- hazardous materials and Environmental Policy o Spill control will be exercised by Spill Prevention and inspecting equipment, hiring Countermeasures (SPCC) trained and dedicated feelers and Plan; (iii) aerial spraying of pesticides/herbicides handlers and herbicides and pesticides to by implementing a Spill measures minimize application on described measures to be sensitive habitats and ensure implemented by PDMSA and its best practice handling of contractors to prevent and if these chemicals necessary, contain and control inadvertent spill of hazardous material such as fuels, lubricants and pesticides chemicals, containment walls and other measures. In addition, a training module will be developed to educate employees on the SPCC Plan; Terrestrial Biological Resources: o Maintain a 50-100 meter buffer PDMSA to ensure buffer is maintained Periodic visual inspections to Training of operation Training to be conducted Annexure 25 –P3- Diminished use of habitat by area along the Inkomati River to during operation; biological resource ensure buffer is being properly contractors as to the buffer prior to planting and Construction reducing hiding places and safe allow undisturbed areas for management enforced by LAW and maintained during planting and area that should be harvesting activities that Environmental havens for large predators and prey wildlife. overseen by conservation institutions (e.g. harvesting activities. maintained and the may disturb the buffer Management Plan from the repeated harvesting STINASU, SCF, NCD) importance of this buffer activities of the cane crop. The o Maintaining corridors to allow for Implementation of Biodiversity Biodiversity Monitoring PDMSA- planting and harvest activities movement of large mammals. PDMSA’s HSE Team (or biologist Monitoring Program, which If necessary, procurement of activities to be conducted Environmental Policy themselves will disturb the contractor) to implement Biodiversity includes visual inspection of expert biologist consultant quarterly, or as needed, mammal and bird fauna. The large Monitoring Program which will monitor wildlife corridors and records to implement Biodiversity during operation Annexure 25 –P6- mammal fauna will likely move migration corridors signs of disturbance (i.e. Monitoring program Biodiversity and retreat into the surrounding movement into other areas) and Management Plan areas. incidences of mortality Terrestrial Biological Resources o Implement a Rodent Management Agricultural Project team lead Regular recordkeeping of Training of agricultural team Monthly monitoring, Annexure 25 –P3- l: Introduction and/or increase in Plan including active rodent number and location of rodents in rodent control and quarterly consultation with Construction rodent populations related to trapping and coordination with trapped concerns regarding rodent local health authorities Environmental sugarcane population local health care providers to infestation for the sugarcane regarding incidence of Management Plan establish procedures to address crop and nearby rice rodent borne disease in the any incidence of rodent-borne cultivation. Malangane community PDMSA- disease. Environmental Policy

Annexure 25 –P6- Biodiversity Management Plan 4. Operation Phase: Operation of Organic Sugar Production Facility Soil: Soil contamination from spills o See first two (2) mitigation See Above See Above See Above See Above Annexure 25 –P3- or leaks of lubricants and fuels and measures above for soil Construction other chemicals that will be used contamination under “Operation Environmental during the operation of the plant. of the sugarcane plantation” as Management Plan

they apply as well to the operation PDMSA- of the processing facility. Environmental Policy

Air Quality: Combustion o Use of new bagasse and trash- PDMSA responsible for installing engineer Air Quality Monitoring If necessary, procurement of Initial selection of high Installation of emissions (including GHG; CO2, fired COGENERATION plant controls to reduce combustion emissions Program consultant to implement Air efficiency equipment to be Electrostatic Precipitator CH4 and N2O) from bagasse and with high energy efficiency and maximize efficiency of conversion Quality Monitoring program made during project design trash- fired COGENERATION boilers; process. They are also responsible for Tracking energy use through as a result of the alternatives plant at o Regular maintenance of the researching and implementing electric bills and periodic Training of operation analysis boilers and all equipment; visual inspections of work contractors on maintenance areas; the factory (boiler stack) and from o Installation of emission reduction carbon emission offsets (to the extent energy used in conversion of boilers and other Air Quality Monitoring Wet Scrubber on road diesel engines of trucks systems such as wet scrubbers on possible) process to equipment Program to be implemented transporting cane, raw sugar to and the boilers. be evaluated separately quarterly during operation High Volume Sampler from the facility. o Location of factory at the center PDMSA’s HSE Team (or air quality Training of transport for Air Quality of the Project Area to minimize contractor) to implement Air Quality Tracking quantity of excess contractors on maintenance Training on equipment and Monitoring traveling distance for trucks Monitoring Program renewable power sold to fossil- of transport vehicles vehicle maintenance to be transporting cane to factory and fuelled plant at Moamba issued prior to the start of Annexure 26 ultimately minimizing diesel Operation contractors supervised by District Initial investment required operation and refreshed as Environmental Control consumption; PDMSA, responsible for maintenance of for high efficiency needed Machinery o Use of bagasse (90 percent) and equipment according to manufacturer’s Documentation of offset equipment Specifications trash (10 percent) as fuel for the specifications and efficient use of energy program and emission reduction Energy efficiency to be COGENERATION plant boilers credits received monitored over the life of to produce onsite power and heat Transport contractors supervised by the Project requirements (renewable fuel); PDMSA, responsible for maintenance of Sporadic emissions testing of o Selling of excess renewable transport vehicles according to transport vehicles to ensure power (at least 9 MW - base load) manufacturer’s specifications adequate maintenance; tracking to external fossil-fuelled plant at maintenance records the Moamba District; o Where feasible, implement carbon emission offsets elsewhere (e.g. developing the Project as a carbon development mechanism (CDM) project and obtaining emission reduction credits). o Ensure use of energy efficient lighting, heating and ventilation at factory site; o Ensure adequate maintenance of all transport vehicles. Noise: Movement of trucks (i.e. o Regular maintenance of all trucks PDMSA responsible for installing engineer Noise Monitoring Driver safety training to all Initial selection of Machine Acoustics transport of raw sugar) along the in accordance with controls to reduce noise emissions Program workers, including engineering controls to be Chamber Transport Corridor will result in manufacturer’s specifications; PDMSA’s HSE Team (or noise contractor) contractors, who are made during project design increased noise levels at nearby to implement Noise Monitoring Program Documentation of driver expected to drive as part of as a result of the alternatives receptors along the corridor (which o Install sound suppressive devices Transport contractors, supervised by training provided and their duties. analysis PPE includes residences, schools and (such as mufflers) on the trucks; PDMSA, responsible for maintenance of attendance records of those houses of worship). transport vehicles according to training events If necessary, procurement of Training to be conducted o Educate truck drivers and ensure manufacturer’s specifications noise consultant to prior to the start of transport Installation of Noise they do not exceed a speed limit PDMSA to implement driver education Database tracking traffic related implement Noise activities and refreshed Monitoring Equipment of 45 km along densely populated program, emphasizing the importance of infractions Monitoring program quarterly areas along the corridor. obeying traffic laws Noise Monitoring activities to be conducted monthly, or as needed during operation Noise: Movement of trucks (i.e. o Regular maintenance of all trucks PDMSA responsible for installing engineer Noise Monitoring Driver safety training to all Initial selection of Machine Acoustics transport of raw sugar) along the in accordance with controls to reduce noise emissions Program workers, including engineering controls to be Chamber Transport Corridor will result in manufacturer’s specifications; contractors, who are made during project design increased noise levels at nearby PDMSA’s HSE Team (or noise contractor) Documentation of driver expected to drive as part of as a result of the alternatives receptors along the corridor (which o Install sound suppressive devices to implement Noise Monitoring Program training provided and their duties. analysis PPE includes residences, schools and (such as mufflers) on the trucks; attendance records of those houses of worship). Transport contractors, supervised by training events If necessary, procurement of Training to be conducted o Educate truck drivers and ensure PDMSA, responsible for maintenance of noise consultant to prior to the start of transport Installation of Noise they do not exceed a speed limit transport vehicles according to Database tracking traffic related implement Noise activities and refreshed Monitoring Equipment of 45 km along densely populated manufacturer’s specifications infractions Monitoring program quarterly areas along the corridor. PDMSA to implement driver education Noise Monitoring activities program, emphasizing the importance of to be conducted monthly, or obeying traffic laws as needed during operation 5. Decommissioning Phase: Closure of Sugarcane Plantation Retrenchment: Reduction in o Implement policies and programs -PDMSA HR team to ensure company Semi-annual monitoring of Accrual funds necessary to Training programs for Conceptual Closure workforce during closure period, to assist retrenched workers. policies regarding terms of employment retrenched workers, to establish provide career counselling, retrenched workers should Plan (To be developed with related indirect effects to Assistance should include career which may affect retrenchment benefits are the outcomes of assistance that finance retraining and be established prior to the and submitted for lender secondary economy counselling, training programs built into employment contracts and was provided economic development closure phase. Based on review) and economic development disclosed to workers upon hire. program. consultation with the opportunities based on level of - Prior to expected retrenchment, PDMSA Records and periodic audits of community, the training skills and type of contract. HR and CR teams to consult with the reference material, including program should seek to fill workforce and their representatives and written records of consultations the most pressing skill gaps. with local communities where workers live with retrenched workers (Malangane and) to provide information and receive feedback on the retrenchment process. - They should ensure that workforce and communities are notified of scope, scale and schedule of anticipated retrenchment in a timely and suitable manner and are consulted about options for potential retraining/economic development/job placement programs and other support to be offered 6. Decommissioning Phase: Closure of Organic Sugar Production Facility No significant impacts associated with the closure of the sugar processing and production facility have been identified Social/Labour: Project- related o Upgrade existing PDMSA PDMSA Community Relations team, in Ongoing monitoring of Training of community Review and upgrade Grievance Mechanism grievances from local communities Grievance Procedure in line with coordination with HR team for labour- mechanism effectiveness, for relations staff on the details (including consultations) of (Stakeholder grievance or other project-affected international standards related grievances example: of operating the Grievance PDMSA’s existing management policy)- To stakeholders o Consult with local communities Mechanism grievance procedure to be made available in and other stakeholders o Number of grievances commence as soon as local language communities in project area of received according to Training for all about the possible, prior to influence) to inform decisions category, per time period Grievance Mechanism, its construction about the range of options to be o Number and % closed basic elements and what to established for receiving and according to category, per do if contacted by a Communicate the Grievance resolving grievances. Consider time period stakeholder with a project Mechanism to internal and cultural expectations and norms o Number of satisfied staff on the compliant external stakeholders by for communication and problem- responses from start of construction and solving related to grievances complainants, per repeatedly throughout life of o Disclose the grievance category, per time period project mechanism widely among local o Identified root causes of and potentially affected resolved grievances Conduct ongoing stakeholders via locally and o Timeframes for closure of monitoring against culturally appropriate channels grievances by category established performance o Repeats of the same indicators and periodic grievance reviews of the overall functioning of the mechanism and areas for improvement Ecosystem Services: The project’s o Continue ongoing collaboration PDMSA’s Environment team is primarily Documentation of engagement, To be Determined To be Determined Continue ongoing changes to local hydrology and with Ministry of Agriculture and responsible for implementing the Water tracking of water-related collaboration with ongoing use of water including local water boards in order to: (i) Management Plan. grievances Ministry of Agriculture water intakes from the Inkomati Disclose the Project’s Water and local water boards river and discharges into the Management Plan and The Community Relations team should be on water management Inkomati River– will impact procedures; (ii) Maintain open involved in all elements related to issues various ecosystem services used by communication with other water stakeholder engagement and information local and downstream users in the Project Area; (iii) disclosure. communities, including water Identify and immediately resolve quality and availability for any unanticipated negative domestic and agricultural uses, impacts to downstream water fisheries and natural flood users as a result of the Project; regulation. and (iv) Ensure compliance with local water use regulations and/or collaborative management strategies established by the Ministry. Social: Population influx and o Establish a Local Content Plan For Local Content Plan: For Local Content Plan: Implementation of Plans to be developed as Local Content Program associated negative social impacts outlining targets and a program to o PDMSA HR team to develop and o Actual number of local Technical Skills Training soon as possible ((To be developed and due to creation of jobs in achieve them, for number of local implement the plan, including labourers employed Program to ensure local submitted for lender connection with the project labourers, as deemed appropriate tracking progress towards hiring and versus the target number. Labour market is qualified Training of HR and review- Prior to Labour based on consultations with the retention targets for local labourers. o Establishment and for employment (see below) procurement staff on Mobilization) community regarding project- o Procurement team to coordinate with continuous updating of implementation of Local related benefits for that HR on development and database on goods and Training of human resources Content Plan and Skills Annexure 25-P5- community) in each stage of implementation of guidelines for local services that are available and procurement officers to Training and Development Community Project lifecycle; procurement. locally guide hiring and Program as applicable, prior Engagement & CSR For Skills Training and o Monitoring of percent procurement protocols to initiation of construction Plan o Establish, as part of the Local Development Program: value and volume of activities and continuing Content Plan, guidelines to o PDMSA’s CR team to establish locally produced goods Development of throughout project lifecycle PDMSA- OHS Policy encourage the procurement of relationships between the Project and and services procured partnerships with local as appropriate. local goods and services local agricultural educational For Skills Training and agricultural educational PDMSA- Social organizations. Development Program: organizations Monthly monitoring and Accountability Policy o In partnership with local o PDMSA’s HR team to develop o Number of graduates of reporting of actual agricultural education training programs to help boost the training courses per performance vs. established organizations, establish Skills capacity of agricultural workers. session performance indicators. Training and Development o Percent of skills training Program to increase the number program graduates Yearly monitoring of of skilled agricultural workers in retained by PDMSA agricultural workers who are the local Labour market. o Number of participants trained to ascertain how and graduates of their skills or agricultural programs that adopt new practices have changed. technologies or agricultural methods Social: Local capacity is o Establish an Internal Leadership The PDMSA HR team is responsible for Number of Mozambican Implementation of an Training should commence Internal Leadership insufficient to staff Project Training and Development ensuring that the appropriate training tools employees who have received Internal Leadership Training during the operation phase. Training and managerial and technical positions. Program to increase capacity of are in place and that the local staff has appropriate training for their and Development Program Local staff should be given Development Program Without a program to develop local Mozambican staff and train local access to resources and programs to develop respective and target positions to aid the transition from the opportunity to shadow as CSR Plan capacity and leadership ability, the staff in administrative, managerial their job skills and leadership ability. expatriate workers to local expatriate staff and formal Project will remain dependent on and technical positions in order to Percent of those who have staff. structures should be set up Local Content Program expatriate workers. replace expatriate positions within received training (per where local staff can ask ((To be developed and 10 years of Project operations. subcategory) who have been If necessary, training of questions to and receive submitted for lender hired on full-time in an human resources officers or feedback from expatriate review- Prior to Labour administrative, managerial or employees who will develop staff. Mobilization) technical role and implement the training and leadership development Number of expatriate staff and program. their percentage within all administrative, managerial and technical project staff Social: Project workers and o Evaluate the availability and The PDMSA Human Resources (HR) team Location and quality of worker Resources should be Annexure 25-P2 Labour contractors will put new demands quality of existing housing in will be responsible for ensuring that housing, including compliance available to ensure workers Housing Plan on the local housing market in Malangane, to determine whether behavioural guidelines are in place for with health and safety have access to health-risk Malangane and may generate social sufficient adequate housing exists Project workers guidelines, preventive measures, such Annexure 25-P4 Worker conflict and tensions with local to accommodate Project-related tenancy information, training as mosquito nets and Health & Safety community members, as well as influx and to identify any critical The PDMSA Health and Safety team is completion contraception, including management Plan potentially leading to changes to concerns and issues to manage in responsible for ensuring that appropriate rates on Worker Code of condoms. local land use due to new housing association with the housing of health and safety provisions are in place for Conduct, health monitoring and Annexure 25-P1- construction. incoming workers. worker housing. The team should draft additional parameters to be If necessary, a training PDMSA Internal o Based on evaluation findings, health and safety guidelines that will be defined in Worker Housing and program should be held to Regulation establish a Worker Housing and used to monitor the conditions in worker Integration Plan and sensitize workers to the Integration Plan including housing. Community Health and Safety dangers of substance abuse. PDMSAS Social procedures and actions to Plan Accountability Policy facilitate the integration of new The Health and Safety team together with If necessary, a training staff into Malangane and to dis- the Community Relations team is program should be incentivize new land colonization, responsible for the Community Health and established on health and especially in areas which may Safety Plan. safety protocols. The generate social conflict. program should be updated o Specify within the project’s on a semi-annual basis. Labour Management Plan a company policy on worker housing, including a Worker Code of Conduct for behaviour within company-owned housing o Establish a Community Health and Safety Plan to minimize, monitor and manage health impacts to the local community caused by the influx of what will likely be a mostly male workforce. Social: Expected population influx o Establish local and regional The PDMSA will aid in coordinating the Joint tracking (with local Accrual funds may be Consultations should be held NA related to Project activities will planning initiatives in the Project voluntary activities related to planning authorities) of enrolment / necessary to finance the prior to the beginning of likely put a strain on existing social Area in association with the initiatives, including providing advanced utilization rates of local and proposed initiatives and construction to establish and public services in the area. community and local authorities. notification of issues related to workforce regional social and public program established. priority initiatives and The initiatives should focus on and community interaction. services services requiring potential improving public service collaboration. provision in the project area to Indicators to measure offset the additional burden to successful service provision (to During construction and these services caused by in- be established) operation, planning sessions migration. should be arranged semi- annually to determine and refresh initiatives. Social: Affected communities and o Develop a Public Disclosure and The PDMSA CR team is responsible for Dates, type, nature and Training for CR staff on The disclosure and Annexure 27-MoU other stakeholders need to be Consultation Plan that establishes communicating and engaging with key frequency of consultations and implementing the consultation/engagement Commitment with the informed about and provided the guidelines for consulting and stakeholder groups about Project activities interactions with local Public Disclosure and process should be a Communities opportunity to offer views and engaging the local community, and impacts. They should ensure that community members and other Consultation Plan constantly evolving process - Local Content opinions on the management of both during project planning and Project communication is accessible and stakeholders (tracked by type / throughout the Project Program ((To be impacts and risks associated with throughout the life of the project. understandable to different groups of the individual) lifecycle and should be developed and the Project. Building trust by The Plan should ensure that affected community and that different periodically updated to submitted for lender providing opportunities for affected groups are notified and segments of the community are represented Responses offered or account for changing review- Prior to Labour stakeholders to be informed and consulted on Project risks, in the consultation process. commitments made in response stakeholders and Project Mobilization) express their concerns and impacts and other issues that may to stakeholder questions and information. -Annexure 25-P5- suggestions and by taking their affected them. During the Project concerns Community input into account, is an important lifecycle, affected groups should Engagement & CSR component of managing social, be informed about changes to the Plan reputational and operational risks. Project scope and schedule. -PDMSA- OHS Policy o Within the Public Disclosure and -PDMSA- Social Consultation Plan, ensure Accountability Policy consideration of the special needs and unique characteristics the community in, as well as other vulnerable groups in the project area of influence, to ensure they have adequate opportunity to express their opinions and views. o With respect to, Stakeholder Engagement should ensure cultural appropriateness and lead to Broad Community Support. Social: Violations of Labour rights, o Establish a Labour Management PDMSA’s HR team will have primary -Monitoring of company and If necessary, training on Worker policies and Annexure 25-P1- or inappropriate worker conduct in Plan, encompassing the project’s responsibility for implementing the Labour contractor compliance with the national employment and procedures should be PDMSA – Internal local communities, can cause human resource policies, Management Plan. company policies and local Labour laws. established prior to the Regulation- Approved social, legal and operational risks procedures and systems to uphold laws; beginning of the by Ministry of Labour to the project, if not effectively worker rights in accordance with The HR team should collaborate with the -Numbers of Labour related Health and safety training to construction phase. The Government of managed. In addition, major applicable national laws, Health and Safety team to develop and grievances filed each quarter; promote safe working policies should reflect Mozambique Labour violations (such as communicate with and engage implement the Occupational Health and types of issues raised and by conditions. company and national employment of child or forced workers and ensure they are Safety Program. whom; and percent resolved by standards and should be Annexure 25-P4- labour) among key suppliers may adequately trained and equipped type; updated throughout the Worker Health & Safety cause reputational risks to PDMSA. to perform their jobs in a safe The HR team should collaborate with the -Occupational Health and Project lifecycle. Management Plan manner. Community Relations team to implement Safety monitoring against the grievance mechanism. indicators to be established Annexure14- HSE o The Plan should include an through the development of the clause –EPC Contractor Occupational Health and Safety OHS Program; Program covering all such related -Quarterly audits of working risks to workers. A Worker Code conditions and to verify there of Conduct that sets guidelines are no cases of child Labour or and requirements for interactions forced Labour at the Project between workers and the site. community should be included in the Plan.

o A grievance mechanism should be in place that allows the project to address allegations of non- compliance with established policies. Social: Accidents and incidents o Establish Emergency The PDMSA Health and Safety (H&S) Quarterly audits to Establishment and training The Emergency Emergency may occur within the Project site Preparedness and Response Plan team is responsible for identifying and verify that all active workers of Emergency Coordinators Preparedness and Response Preparedness and and/or may affect neighbouring to cover the risks and hazards that establishing roles for emergency response and contractors have received and teams on emergency Plan and Community Health Response Plan((To be communities. may result in emergency participants. The H&S team should keep a Emergency Preparedness and response protocols and developed and situations and the required constantly updated log of emergency Response training and know the Safety Plan should be submitted for lender response to these emergencies. situations that occur and update the Plan to protocols during an emergency Training and simulations established in consultation review- Prior to Labour reflect the current Project lifecycle. situation; with local communities and with local communities and Mobilization) o Develop an Occupational Health local authorities on government authorities and Safety Program to minimize Development and implementation of the Number of trainings and emergency response during the ESIA progress. Annexure 25-P4- and manage health and safety Community Health and Safety Plan should simulations offered for procedures and measures Worker Health & Safety risks to workers on site. be coordinated among the H&S Team, the communities and local The Plan should be in place Plan Environment Team and the Project’s CR government staff and number of at the inception of o Establish a Community Health team. participants construction activities and PDMSA- Occupational and Safety Plan to outline completing each training; updated throughout the Health & Safety policy additional measures related Project lifecycle. specifically to dealing with OHS and Community Health Annexure14- HSE and Safety monitoring clause –EPC Contractor emergencies or incidents that indicators (to be developed as affect local communities. part of OHS and CHS o Identify and train personnel to programs); lead emergency situations and Ongoing maintenance ensure provision of appropriate / auditing of emergency emergency preparedness and response. equipment response equipment and supplies.

o Share relevant information with and train local communities and government authorities as appropriate (including involving them in simulations of emergency situations which may affect them), to ensure their capacity to assist or cooperate with response efforts as needed.

Waste: Hazardous materials, o Establish a Hazardous Materials The PDMSA Environment and Health and -Quarterly audits against Training for workers and Establish plan prior to the Annexure 25 –P3- including petroleum products, Management Plan outlining Safety teams are responsible for indicators to be established in contractors who may handle start of construction; Construction will be used, stored and handled requirements and procedures to the Hazardous Materials or come into contact with by the Project. Without proper safely manage, store and utilize establishing training, signage and storage Management Plan, to verify that hazardous materials and implement throughout the Environmental controls, hazardous materials hazardous material, including procedures for hazardous material. all hazardous materials are emergency actions to follow project lifecycle Management Plan can impact the safety of the agricultural and pest-control being properly handled and in the event of spillage, workforce and surrounding chemicals and inputs. The Plan The Community Relations team should stored; release or accidents. The PDMSA- communities through spills, should comply with specific disclose and consult with local communities -Records of all workers and training may occur in Environmental Policy accidental releases and/or requirements as outlined in IFC’s and authorities on what hazardous materials contractors that have received coordination with explosions. are being used in Project area, the risks the hazardous materials training Emergency Preparedness HSE Guidelines. associated with the materials and plus ongoing refresher courses; and Response training. o Establish transportation emergency response measures in the event -Root cause analyses and guidelines for the transport and of a spill. corrective actions taken in the storage of hazardous material, event of an incident and ongoing environmental including transporting material on monitoring as needed following routes and during times to a release of hazardous materials minimize public exposure. into the environment o Ensure that all hazardous materials are clearly identifiable and labelled.

o Coordinate the Plan with the Emergency Preparedness and Response Plan and the Community Health and Safety Plan, particular with respect to disclosure of hazardous materials related risks and disclosure / training on emergency response measures in the event of an accidental release, spill or explosion.

Transportation: The Project o Conduct a Traffic Risk The Traffic Risk Assessment should be Quarterly audits to check that If necessary, driver training The Transportation Health Traffic Risk Assessment requires the transportation of Assessment, including a carried out by competent professionals with Project drivers meet necessary on national traffic and Safety Plan should be in & Safety Plan (to be people, supplies, products and description of the scope of experience in traffic issues. The CR team licensing requirements and are regulations should be held place prior to the developed and wastes (including hazardous Project-related traffic and should be engaged during the assessment aware of the traffic regulations on an annual basis. commencement of submitted for lender materials) to, from and within identification of all areas sensitive process, to conduct consultations with local transportation activities and review before start of the Project area. Transportation authorities and other key stakeholders who If necessary, driver training should be reviewed and construction) will make use of public road can provide local perspectives on traffic- on proper vehicle updated annually. infrastructure, which passes to traffic risks and the current related risks and necessary management Semi-annual audits to check the maintenance should be held PDMSA- Occupational through various communities. state of road repair. approaches. maintenance of Project and to help ensure vehicles are Health & Safety Policy Traffic-related accidents may in contractor vehicles. in proper working condition. turn pose a risk to the health, The Road Maintenance and Monitoring Annexure14- HSE safety and quality of life of those o Based on the Traffic Risk Plan should be developed and implemented Road maintenance monitoring, clause –EPC Contractor communities. Assessment, develop and jointly with local transit authorities. as per parameters to be implement a Road Maintenance established within the Road and Monitoring Plan to be The PDMSA Health and Safety and Maintenance and Monitoring implemented in coordination with Logistics teams are responsible for Plan. local authorities to ensure that any developing and implementing the deterioration in the quality of the Transportation Health and Safety Plan, Road caused by the Project is including ensuring proper licensing of drivers and full knowledge of national identified and immediately traffic regulations. repaired

o Develop a Transportation Health and Safety Plan establishing the policies and procedures to manage driver conduct, training and health and safety measures. The Plan should include requirements and management measures to ensure Project- related transit is conducted safety, including speed limits, vehicle maintenance and requirements related to night time driving.

o A roster of drivers should be available and maximum shift lengths established, to prevent driver fatigue.