Photo by Giorgi Kekenadze

LUKHUNI HPP CASCADE PROJECT

ENVIRONMENT AND SOCIAL IMPACT ASSESSMENT REPORT STEKEHOLDER ENGAGEMENT PLAN

Prepared by SRF Gamma

Tbilisi, 2012

TITLE PAGE

Project Title: Lukhuni Hydropower Cascade Project

Document Title: Environmental and Social Impact Assessment ‐ Stakeholder Engagement Plan

Prepared by: SRF Gamma

Date Prepared: February, 2012

Project Manager: Vakhtang Gvakharia, President SRF GAMMA

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Contents Glossary

1 Introduction ...... 1 2 Project Description ...... 2 3 Stakeholder Engagement ‐ National and International Regulations and Requirements ...... 5 3.1. Stakeholder Engagement ‐ National Requirements for Public Participation ...... 6 3.2. Stakeholder Engagement ‐ EBRD Policy/IFC Performance Standard ...... 7 3.3. International Conventions for Public Participation ...... 7 4 Project Stakeholders ...... 7 5 Consultation Activities ...... 8 6 Disclosure of documentation ...... 9 7 Public notification ...... 10 8 Resources and Responsibilities ...... 10 9 Grievance Mechanism ...... 11 10 Monitoring and Reporting ...... 13 11 Contact Details for the Public ...... 13

ANNEX 1. LIST OF STAKEHOLDERS ANNEX 2. PUBLIC GRIEVANCE LEAFLET

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Glossary

EBRD European Bank for Reconstruction and Development EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment ESAP Environmental and Social Action Plan MoE Ministry of Environment Protection SEP Stakeholder Engagement Plan NTS Non Technical Summary NGO Non‐governmental organization

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1 Introduction

Rusmetali Ltd plans to construct a 30.3 MW cascade of small hydro power plant cascade (Lukhuni 1, Lukhuni 2 and Lukhuni 3) in the gorge of the Lukhuni River.

Figure 1.1 Location of the project

The project design of the cascade is developed by Stucky Ltd.

Construction and operation of the Lukhuni HPP cascade is in full compliance with EC European Energy Policy adopted in 2007 and the UN framework convention on Climate Change (enacted by Kyoto Protocol in 2005), which appeals to all states to concentrate efforts towards increasing of energy consumption efficiency through increased utilization of renewable energy sources and decrease of environmental degradation.

Construction of the HPPs and provision of the grid with additional power will facilitate economic grow in the region. On construction and operation phases will be established number of work places favoring to employment of local population and improvement of their economic conditions. Execution of the project will help the region to preserve existed jobs and businesses (including service sphere), what on its side will promote improvement of life conditions of laborers. Besides, local budget will receive taxes paid for water use, as well as taxes paid by service provides delivering their services to the HPPs.

On the broader scale, the HPP cascade will contribute to reduction of power import and increase power export to the neighboring countries.

Under the Georgian legislation implementation of the project under consideration requires authorization from the Ministry of Environmental Protection of . The authorisation (impact permit) is issued based on consideration of the documents picturing expected impact on the biophysical and socio‐economical environment with indication of mitigation measures to reduce adverse effect and

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Page | 2 description of cumulative and residual impacts expected on construction and operation stages of the project. With consideration of potential involvement of International Financial Institutions in the project assessment of impact on natural and social environments has been carried out with consideration of the both – national and international requirements, such as those set in the EBRD’s environmental and social policy (ESP). With consideration of that documents developed during the ESIA process include Environmental and Social Impact Assessment (ESIA) and a Stakeholder Engagement Plan (SEP).

This document presented the Stakeholder Engagement Plan for the Lukhuni HPP project and details Rusmetal’s consultation activities to date and its future plans for the Project disclosure and stakeholder consultation in respect of the new development.

This SEP is designed to ensure that Rusmetal identifies all stakeholders with an interest in the Project, and can engage these stakeholders during the development and life of the Project. This SEP therefore outlines the company’s previous consultation activities and future plans to engage with stakeholders during pre‐construction, construction and operational phases of the Project.

Stakeholder engagement includes: 1. The provision of relevant, timely and accessible information to stakeholders in a culturally appropriate and understandable format; and 2. Consultation with stakeholders on their opinions, concerns, preferences and perceived gains and risks with respect to the Project planning and implementation, including the design and proposed management and mitigation measures to reduce potential impacts and to enhance possible benefits. 3. A grievance mechanism to guide Rusmetal’s response and resolution process for stakeholder concerns or grievances.

This SEP therefore describes the: • National and good international practice requirements for public consultation and disclosure that the Rusmetal will conform to; • Project stakeholders that have been identified; • Strategy, format and timetable for consultation and information disclosure; • Ruemetal’s resources and management structure for developing and implementing the SEP; • Grievance mechanism(s) for stakeholders, and: • Means of reporting on consultation and disclosure activities.

2 Project Description Rusmetal Ltd is developing Lukhuni HPP cascade consisting of three HPPs: Lukhuni 1 (10.8MW); Lukhuni 2 (12mW) and Lukhuni 3 (7.5MW).

HPP1 – Two intakes will be built. One on the Lukhunistskali, another on the Lashaturi, both located at 1485 m above datum. Water from the Lashaturi intake will be delivered through tunnel to the main free flow tunnel. The tunnel from the Lukhunistskali headworks to the power penstock forebay will be 10.5 km long with diameter – 2.5‐3.0 m. Two penstocks (diameter 600mm, length 1.4km) will deliver water from the forebay to two Pelton turbines. The power station will be arranged within the above‐floodplain terrace at 1150 m above datum. Design water flow of the HPP is 4.01m3/sec, design head ‐ 335 m, installed capacity – 10.8 MW, average annual power generation – 66.07 mln kW. Along with the mentioned facilities 10/35kV substation and 16.8km long 35kV overhead transmission line connecting the HPP1 substation to the HPP2 transmission line will be built.

HPP 2 ‐ Headworks will be located on the Lukhunistskali at 1150 m above datum. The scheme includes: diversion tunnel (length‐ 5.3 km, diameter – 3.0 m), penstock forebay, two penstocks (length 700m,

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Page | 3 diameter 600 mm) delivering water to two Pelton turbines and power station built within above‐ floodplain terrace (890 m above datum). Design water flow of the HPP is 7,0m3/sec, design head ‐ 286m, installed capacity – 12.0 MW, average annual power generation – 73.58 mln kW. Along with the mentioned facilities 10/35kV substation and 2291m long overhead transmission line connecting to the 35 kV substation of will be arranged.

Figure 2.1. Location of the main components of the scheme

HPP3 ‐ Headworks will be located on the Lukhunistskali at 885 m above datum and provide design flow to the free low derivation tunnel. Length of the circular section tunnel is 6.7 km, diameter – 3.0 m. The tunnel will connect to the penstock forebay. Two penstocks (length 830m, diameter 700m) will deliver water to two Pelton turbines. The power house will be built within the above‐floodplain terrace at 765 m above datum. Design water flow of the HPP is 9.6 m3/sec, design head ‐ 120 m, installed capacity ‐ 7,5

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MW, average annual power generation – 46.03 mln kW. The scheme also comprises 10/35kV substation and 1.9 m long 35kV overhead transmission line connecting to 35 kV substation of Sori. All substations will have metal fence. Electric power generated by the Lukuni HPP cascade will be distributed though Georgian power grid. The line will run through unpopulated areas. In total 90‐100 tower will be required. Basement of each tower will require some 50‐60 m2 area, which translates into 6,000 m2 to be acquired for permanent use under the transmission line component of the project.

Preparation phase includes arrangement of permanent/temporary access roads, power supply, water, compressed air and temporary facilities for the sites of the hydraulic works. There will be one main camp (0.8ha). The camp will be arranged in Uravi village, on the right bank of the Lukhunistskali, next to the office building of the former arsenic beneficiation plant. These facilities can be used for the construction camp after rehabilitation and improvement (adequate contract shall be made with Uravi JSC to use the territory and facilities). Besides, construction grounds will be organized at each project site, including: 1) headworks and the tunnel’s entrances, 2) access gallery to upper tunnel, 3) forebay, exit portal and penstocks; 3) powerhouse and tailrace canal.

Inert materials for the constructions will be delivered from licensed borrow pits present in valley. Besides local stocks of building materials ‐ sand and gravel – which accumulate in the floodplain of Lukhunistskali River, on the section between the village of Uravi and Abara can be used. There the river has significant slope and solids (sand, gravel) transported from the upstream.

Construction bases and sites will be powered from the existed grid and diesel‐generators. Diesel generators will be used to power both faces of the derivation tunnel and headworks site (on Lukuni River and its tributaries).

Water for drinking and domestic use will be tapped from the natural springs found nearby the construction grounds (the region and in particular the construction camp site is rich in high quality groundwater). Potable water supply will be kept in tanks intended for food products, and technical water – in ferrous metal tanks. A compact biological treatment unit will be provided at Uravi construction camp to treat domestic/sewage wastewater produced there.

Wastewater will be discharged into the Lukhunistakali river. No waste water will be discharged without treatment. The waste water after treatment will meet the following limits: Particulates ‐ 400 mg/l; BOD ‐ 6 mg/l; Ammonia nitrogen – 0.4 mg/l; Chloride – up to 350 mg/l; Polyphosphate – 0.2 mg/l. For treatment of industrial wastewater is considered УСВ‐М‐20 treatment unit (oil trap). Quarterly monitoring of water quality at the point of discharge will be performed.

Volume of spoil generating during tunneling will be 130‐140 thousand m3. Volume of waste rocks generated during construction of the power houses is estimated at some 35‐40 thousand m3. Spoil will be temporarily stores at tunnel adits. Temporary dumping areas will be arranged for and at: • HPP1 derivation tunnel and the entrance of the HPP2 tunnel – spoil will be dumped at so called “Mepischala” territory in the upstream of the Lukhuni. For that 2.6 ha land parcel is identified there. • HPP2 tunnel and the inlet portal of the HPP3 – spoil will be dumped over 1.9 ha area of the arsenic ore beneficiation plant • Outlet portal of the HPP3 tunnel ‐ spoil will be dumped over 1.3 ha adjacent area.

Total area used for dumping sites will comprise 5.8 ha. Topsoil will be stripped off the sites before dumping; stripped material shall be stockpiled separately to be used for recultivation of the dump sites post‐construction.

Before the start up of construction existing roads will be rehabilitated and access roads to the headworks – built. Rehabilitated shall be 17 km road section between the villages of Tsesi and Uravi, besides major

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Page | 5 part of 14 km long road between Uravi Village and the headworks also requires thorough rehabilitation, some its sections are to be widened. The existed roads shall be extended to reach the headworks. In particular, more 150‐200 m road shall be laid to the headworks of the HPP1, 800‐900 m road to the HPP2 headworks and 350‐400 m to the HPP3 headworks.

Estimated duration for each HPP will comprise 3 years.

The project is being implemented in Likheti community, municipality. The settlements nearest to the project are vil.Uravi, vil. and vil Likheti. The nearest settlements are:

Facility HPP Settlement Number of households Intake facilities HPP1 n/a n/a HPP2 n/a n/a HPP3 Uravi 158 Power station HPP1 n/a n/a HPP2 Uravi 158 HPP3 Abari 48 Likheti 184

Staff ‐ According to the Feasibility Study total of 150 people will be employed during construction. During operations, 13‐15 staff will be employed plus an additional security staff. Policy of the company is to employ local labour force.

3 Stakeholder Engagement ­ National and International Regulations and Requirements In compliance with best international practice, public consultation was invited at the scoping stage and during the ESIA public disclosure period. Rusmetal will provide information throughout the project life.

At the scoping stage: • on the Project itself and potential alternatives • on the proposed scope for the ESIA • the proposed stakeholder engagement plan and programme

Once a draft ESIA is available: • on the impact assessment • on proposed environmental and social management measures.

Georgian requirements related to public consultation for a project of this nature mandate that public hearings be conducted once the draft ESIA is available.

Public consultation activities that have been identified in this document and will be undertaken to support the planned development will conform to: • Georgian regulations; • Guidelines established by International Financial Institutions, specifically the European Bank for Reconstruction and Development (EBRD) policy and IFC Performance Standard 1 requirements; and • International Conventions for Public Participation, in particular the Aarhus Convention.

Further details of Georgian regulations and specific EBRD/IFC requirements are given in the following sections.

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3.1. Stakeholder Engagement ­ National Requirements for Public Participation Georgian legislation provides a general legal framework governing the public disclosure of information on environmental issues but it lacks any specific requirements related to the design and organisation of the stakeholder consultation and engagement process.

The Constitution of Georgia guarantees public access to information and states the right of an individual to obtain full, unbiased and timely information regarding his/her working and living environment.

Public participation in project development is regulated under the Law on Environmental Impact Permit. This Law also provides a list of activities subject to the ESIA procedure. According to paragraphs 6 and 7 of the Law, project owner prepares ESIA report and is responsible for public engagement, which includes announcing public disclosure of the document in the central and local printed media. The law states that public participation and provision of access to information are obligatory procedures of the environmental permitting process. This is conducted in the form of a public discussion of the proposed activity with participation by the investor, the Ministry of Environment Protection and local administrative authorities.

The permit application/issuance procedure, including ESIA coordination and establishment of the timeframes for information disclosure and discussion under Georgian Law, includes the following steps:

1. Publication of information about the planned development in national and regional newspapers: the advertisement must contain information related to the title of the project, venue, date and time of public disclosure meeting(s), addresses of the offices where information about the project is available. The deadline for the feedback.

2. Within one week from publishing the information in the newspaper, the developer must submit an ESIA report (both as a paper copy and in electronic format) to the administrative bodies. Within 45 days after publishing the information, the developer has to review comments obtained from the public. Not earlier than within 50 days and not later than 60 days after publishing the information, the developer must organize the public consultation process. At least one meeting must be conducted in the administrative centre of the area where the activity is planned. The developer is required to provide minutes signed by the relevant authorities present at the meeting within five days.

3. All comments received are to be reviewed and where possible considered in the final version of the ESIA report. Where it is not possible to address comments within the Final ESIA, the developer must explain the reasons for that in writing to the author(s) of the comments. These letters, together with the minutes of the meeting and the final ESIA report, are then submitted to the Ministry of Environment Protection (MoE) (or in case when a Construction Permit is required, to the relevant competent authority) for consideration. The documents must include a location map, the volume and types of any expected emissions, a technical summary with the description of the planned development and a statement on the confidentiality of the project (if appropriate).

No public participation procedure is required during the construction and operation phases. Public consultation occurs once a draft of the ESIA has been prepared. There are no additional requirements for disseminating information, e.g. by means of leaflets, posters and other visual displays, radio/television etc. Neither are there requirements/practices for identifying possible stakeholders (including vulnerable groups) and ensuring their participation.

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3.2. Stakeholder Engagement ­ EBRD Policy/IFC Performance Standard The Project will comply with IFC and EBRD’s requirements for stakeholder engagement as outlined in EBRD’s Environmental and Social Policy, 2008, Performance Requirement 10 (PR10): Information Disclosure and Stakeholder Engagement and IFC Performance Standard 1 (PS1). The major requirements of both lenders relate to involvement of potentially affected communities in the ESIA process at the earliest stage possible.

The Stakeholder Engagement Plan has been developed In order to meet lenders’ requirements. The main objective of the plan is to identify people or communities that are or could be affected by the project and other interested parties as well as ensure their engagement on environmental and social issues during development and life of the project. Engagement is to be achieved through a process of information disclosure and consultation. In particular, EBRD require that the ESIA must be made publicly available for comment in a format which is accessible to the majority of people potentially affected by the Project. EBRD further requires that the ESIA and a Non‐Technical Summary shall remain in the public domain for the life of the project, or at least until project completion. For this project a 60 day consultation period is required before a financing decision is made.

The SEP is living document and will be periodically amended.

3.3. International Conventions for Public Participation Similar requirements for access to information and public involvement in decision making are also specified within the following international conventions: • Aarhus Convention. The UN Economic Commission for Europe (UNECE) Convention on • Access to Information, Public Participation in Decision‐Making and Access to Justice in Environmental Matters (the Aarhus Convention) guarantees the rights of access to information, public participation in decision‐making, and access to justice in environmental matters, in order to protect people’s rights to a healthy environment. Georgia has ratified the Aarhus Convention, and therefore it is also a legal requirement of the Government of Georgia. • Agenda 21. (UN, 1992b) Article 27(9) states that the UN system should "provide access for non‐ governmental organizations to accurate and timely data and information to promote the effectiveness of their programs and activities and their roles in support of sustainable development". • Rio Declaration on Environment and Development (1992). Annex 1 Principle 10 ‐ “Each individual shall have appropriate access to information on hazardous materials and activities in their communities […] States shall facilitate and encourage public awareness and participation by making information widely available”. • UN General Assembly Resolution A/RES/S‐19/2 (1997). Paragraph 108 ‐ “Access to information and broad public participation in decision‐making are fundamental to sustainable development”. • Dublin Declaration on Access to Environmental Information (2000) ‐ UNEP Infoterra • Directive 2003/4/EC (repeals Directive 90/313) on Public Access to Environmental • Information. It incorporates the provisions and requirements of the Aarhus Convention on public access to environmental information.

4 Project Stakeholders Project stakeholders are individuals or groups who: • are affected or likely to be affected directly or indirectly by the project (affected parties) or; • may have an interest in the project (interested parties). They include individuals or groups that may be affected by the project (or themselves affect the project) or perceive themselves to

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be affected by the Project; • have the potential to influence project outcomes or company operations.

In addition, ‘legitimate stakeholder representatives’ may be identified for some of the stakeholder groups. Legitimate stakeholder representatives can include, for example ‘…elected officials, non‐ elected community leaders, leaders of informal or traditional community institutions, and elders within the affected community’.

Taking into consideration the location and scope of activities to be implemented under the planned development, a list of the stakeholders has been compiled. When identifying these potential stakeholders the Project’s geographic sphere of influence was taken into account.

A broad list of the major stakeholders includes the following parties that are potentially affected, directly or indirectly: • Local community within the Project’s Area of influence – population of the residential area adjacent to the project sites and residential areas along the transmission line. Vulnerable groups within the affected communities will be specifically identified and consulted through dedicated means, as appropriate; • NGOs and any other public initiative groups; • Municipal government; • Ministries and departments; • Businesses and commercial sector; • Contractor (when identified); and • Other government institutions. (A full list with further details is given in Annex 1.)

5 Consultation Activities Community was involved in public EIA process from pre‐project stage. At this stage of the project a range of meetings with decision makers, regional governmental authorities and community was held. Information about the project was published on internet (http://www.rusmetali.com; http://www.menr.gov.ge). Community was consulted during the site visit at the scoping stage of the project. The settlements (Uravi, Abari and Likheti) were visited. Community informed about the project and potential impacts and benefits related to its implementation. Along with that governmental official, including local/regional officials, and environmental protection authorities were visited and consulted. At the scoping stage hard copies of Non‐technical summary, project summary and leaflets were made available at the following locations:

• Amrolauri Municipality, Gamgeoba Office – 1 Tamar Mepe str, Ambrolauri; • Rusmetali ltd Office – 63 Irakli Abashidze str., ; and 174 Maris Arkhi, 3700, , • Office of Scientific Research Firm Gamma – 17a David Guramishvili avenue, Tbilisi

Information about the planned project together date and place of public discussion was advertised in the national (24 Saati, February 8, 2010) and local ( newspaper Ambrolauris Matsne, February 2010) press. Public discussion was scheduled and held on 31 March, 2010, in Ambrolauri City, in Gamgeoba Office of Ambrolauri Municipality. Deadline for comment’s submission was set as 18:00 on March 26, 2010.

In accordance to the procedure set in environmental legislation of Georgia environmental permit was issued by the Ministry of Environment Protection.

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At construction and operation stages of the project Rusmetal will keep community informed and involved in the process. One public meeting with the stakeholders is scheduled for March 2012.

In addition to disclosure and consultations, during construction the company will also: • Inform affected communities about any preparatory and construction activities that may influence them. Information will be provided at least a week in advance of such activities; • Update affected communities on the progress of construction; • Implement a Grievance Procedure (see Section 9 below).

Provision of information to affected communities will include use of the Rusmetal project website. Information to include: • A description of the construction works with indication of scheduled start and finish dates for each type of the works; • A drawing indicating the areas affected by the works and including information on: − The type and duration of anticipated impacts; − Mitigation measures for each type of impact; − Studies and documentation related to or affecting residents of adjacent − Progress photos of the worksite.

Besides, as access to internet in the villages (Uravi, Likheti and Abari) is limited leaflets are intended to be used. The leaflets will be posted in public places (shops, pharmacies, etc.) to ensure that information in brought to the notice of local residents.

Throughout construction and operation communication will include including regular (at a minimum annual) feedback to local stakeholders on the implementation of agreed environmental and social mitigation measures related to impacts that could affect them.

6 Disclosure of documentation Copies of the full ESIA report, Non‐Technical Summary, Environmental and Social Action Plan, and Stakeholder Engagement Plan will also be made available for review by the general public at the following locations: • Amrolauri Municipality, Gamgeoba Office – 1 Tamar Mepe str, Ambrolauri; • Rusmetali ltd Office – 63 Irakli Abashidze str., Tbilisi; or 174 Maris Arkhi, 3700, Rustavi, • Office of Scientific Research Firm Gamma – 17a David Guramishvili avenue, Tbilisi; • Uravi construction camp

Information is also published on the Rusmetal’s website (http://rusmetali.com). This will allow stakeholders with access to internet to view information about the planned development, its progress and to initiate their involvement in the public consultations. The project website also provides mailing address ([email protected]), which can be used by stakeholders for submitting any feedback.

The public consultation process will be open for review and comment and revised as appropriate throughout the course of the project. This will include making publicly available the findings and analyses of the environmental and social studies as they emerge at critical milestones throughout the ESIA.

The documents will be available in English and Georgian languages.

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7 Public notification The mechanisms for facilitating input from stakeholders may include notifications to local and regional NGOs, press releases in the local (Ambrolauris Matsne) and national media (24 saati, Kviris Palitra), distribution of the ESIA documentation to the local (West Central Regional Division of Environment Protection, 31 Ilia Chavchavadze Street, ) and central offices of the Ministry of Environment Protection (6 Gulkua Street, Tbilisi) and local municipality office (Ambrolauri municipality, 1 Tamar Mepe street, Ambrolauri). A set of the ESIA documents (Non‐technical Summary, Stakeholder Engagement Plan and Environmental and Social Action Plan) will be also available at Uravi camp.

Leaflets can be posted in public places (shops, pharmacies, etc.) to ensure that information in brought to the notice of local residents. Community will be informed about feedback and grievance mechanisms. Leaflets with contact details and response procedure will be handed over.

Throughout construction annual updates using the project web site and flyers will be ensured. Besides, as already mentioned in section 8, meetings with the mayors will be held, in order to update officials on progress.

Local municipality will act as one of the focal point for the feedback from community. Rusmetal’s representative charged with responsibility to deal with community liaison will be in permanent contact with local authorities and community representatives on the ground.

During operation information about any maintenance (location, type of maintenance required, start date and expected duration) will be communicated through the project web site, local municipality and using flyers. Community along the transmission line corridor will be informed about the RoW management schedule in advance.

8 Resources and Responsibilities Rusmetal will take overall responsibility for consultation with all stakeholders in relation to the Project and will use available resources to ensure that all consultation activities are conducted to the appropriate standard. During the project implementation phase, the staff responsible for community liaison will be charged with responsibilities, inter alia, to communicate with the local community, handle grievances, and resolve disputes between parties.

Stakeholder engagement activities will be coordinated: Name: Mr.David Mindeli Address: 63 Irakli Abashidze str., Tbilisi Phone: + (99532) 2 970 118 Email: [email protected]

The community liaison coordinator will be responsible for the disclosure of Project information; public consultation activities and the management of the Public Grievance Procedure (see Section 9, below). A responsibility diagram throughout the lifecycle of the project is shown below (see Figure 8.1.)

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Figure 8.1. Diagram of responsibilities

9 Grievance Mechanism Rusmetal has developed several methods for the public to lodge a grievance/request for information: • The website includes a system that receives and processes comments and complaints from the public; • A Public Grievance Leaflet with accompanying grievance form can be completed (see Annex 2).

Grievance forms will be available at the Uravi camp site and Rusmetal’s offices in Tbilisi and Rustavi. The staff of the Uravi camp will be briefed in grievance mechanism.

When any public grievances are received, these will be managed through a series of steps. In summary, requests for information/complaints will be acknowledged within 5‐10 days and, where possible, the information requested will be provided within 10‐20 days depending on the complexity of information requested/complaints received.

All grievances will be reflected in a grievance log to ensure that each grievance is assigned an individual number and that consistent tracking and corrective actions are carried out. The log will be used to analyse the frequency, as well as for prevailing subjects and any recurrent trend of grievances. The log contains: • Date when the grievance was received; • The reference number; • Content of the grievance; • Identification of parties responsible for the resolution; • Dates when the investigation was initiated and completed; • Findings of the investigation;

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• Information on proposed corrective action sent to the person who lodged the grievance (unless it was anonymous) and the date of the response sent; the date when the grievance was closed out; • Statement of satisfaction of the person who lodged the grievance, or a reason for non‐ resolution of the grievance. • Any outstanding actions for non‐closed grievances.

Figure 9.1. Grievance procedure (The complainant will be informed if it has been decided to extend the complaint investigation period)

All complaint documentation is kept on a file for a period of two years and then archived. Levels and types of complaints will be monitored by Rusmetal. Where a resolution to the grievance cannot be provided within the timescales specified above, Rusmetal informs complainant about that and once investigations have been completed, contacts the person making the grievance to discuss and agree on the resolution. Rusmetal may undertake follow‐up monitoring to check that the problem does not recur.

Persons lodging grievances will have an opportunity to maintain their confidentiality (see Annex 2 for details). Rusmetal will ensure that the name and contact details of the person are not disclosed without their consent and only the team directly working on the investigation of the grievance will be aware of them. In cases when an investigation necessitates passing some of the information on to third parties for the purposes of resolving the situation (e.g. when it is ascertained that the grievance resulted from certain actions by a contractor company), the complainant’s agreement will be sought in a due manner. If it is not possible for the team to fully investigate the grievance without revealing the person’s identity (for example if they are required to give evidence in court), the investigation team will discuss with the complainant how they wish to proceed. The procedure also allows for anonymous complaints to be lodged. In this case the grievance will still be investigated, although Rusmetal will not be able to

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Page | 13 provide feedback to a complainant. The procedure is shown graphically in the flow diagram above.

10 Monitoring and Reporting The Stakeholder Engagement Plan will be periodically revised and updated during construction and operation stages of the project.

Monthly summaries of incidents/grievances and the status of implementation of corrective/preventive actions will be referred to in Rusmetal’s annual reports. Annual reports on stakeholder engagement and resolution of grievances will be submitted to lenders.

Reporting to external parties such as regulatory authorities as required will be the responsibility of the public liaison office.

11 Contact Details for the Public

Rusmetal Ltd Contact: Mr.David Mindeli Address: 63 Irakli Abashidze str., Tbilisi 174 Maris Arkhi, 3700, Rustavi Email address: [email protected] Tel/Fax: + (99532) 2 970 118 Website address: www.rusmetali.com

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ANNEX 1. LIST OF STAKEHOLDERS

Name Contact information Ministry of Economy and Sustainable 12 Chanturia street, Tbilisi, tel: +(99532) 991088; Fax: +(99532) 9218 Development 45; e mail: [email protected]; Web page: www.economy.ge Ministry of Labour, Health and Social Affairs 144 Tsereteli avenue, Tbilisi, tel: (+995 32) 144307; hot line: (+995 32) 94 49 11 (+995 32) 94 34 98; e mail: [email protected] [email protected]; Web page: http://www.moh.gov.ge Ministry of Environmental Protection 6 Gulua street, Tbilisi; tel: (+99532) 727224/34; Fax: (+995 32) 72 72 34; email: [email protected] Web page: http://www.garemo.itdc.ge Ministry of Energy and Natural Resources 6 Gulua street, Tbilisi; tel: (+995 32) 2357800 Fax: (+995 32) 2357828; e mail: [email protected] Web page: http://www.minenergy.gov.ge Local authorities ‐ regional administration 1 Tamar Mepe street, Ambrolauri, tel: 0 790 17 88 01 e mail: [email protected] Municipality of Ambrilauri 1 Tamar Mepe street, Ambrolauri, tel: +995 32 123456/23 45 67; e mail – [email protected] Gamgebeli (Ambrolauri municipality) Levan Jmukhadze; tel 595 70 77 20 (cell) Deputy Gamgebeli Aleko Kurtsikidze; tel: 790 28 5957 Local communities Uravi (local community representative) Zaza Jeladze, tel: 595 555 069 Abari (local community representative) Soso Lobjanidze, tel: 595 000 509 Likheti (community Rtsmunebuli) Iuri Chaladze; tel: 599 252 374 NGOs Georgian Greens/friends of Earth 10 a Nutsubidze street, IV floor, Tbilisi; tel/Fax: (+995 32) 39 95 43 e mail: [email protected]; Web page: http://www.greens.ge Green Alternative 27/29 Paliashvili Street, II floor, 13 flat, Tbilisi, tel: (+995 32) 2292773; 2223874; Fax: (+995 32) 2223874; e mail: [email protected]; Web page: http://greenalt.org Elkana 16 Gazapkhuli str., Tbilisi, tel/Fax: +995 32 536487; e‐mail: [email protected]; Web page: http://www.elkana.org.ge Georgian Women NGO coalition/ Women’s 75, Vaja‐Phavela Ave. Tbilisi 0186 Republic of Georgia. tel.:(995 32) Center 223 32 99; 2536940; 2314656; Fax: (995 32) 2233299 E‐mail: [email protected] ; webpage www.womancenter.org.ge Web page: http://www.wcg.org.ge Ambrolauri ‐ Pati Kemoklidze ‐ tel+995 99 30 39 20 Other CARE International 49b Chavchavadze Avenue, 3rd floor, Tbilisi; tel: (+995322) 29 13 78; 29 19 41; 29 15 31; Fax: (+995322) 29 43 07; e‐mail: [email protected] 2, Aghmashenebeli Str , Ambrolauri International Association “Civitas Georgica” 97 Tsinamdzgvrishvili Steet, Tbilisi, Georgia tel: (995 32) 951991 Fax: (995 32) 911948 e mail: [email protected] Ecovision 7a Bakhtrioni Street; Tbilisi, Georgia, tel: +995 32 36 60 14; +995 74 73 88 71; e mail: [email protected]

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ANNEX 2. PUBLIC GRIEVANCE LEAFLET

The Rusmetal is striving to ensure that the construction and operation of the Lukhuni HPP and transmission line will not cause any problems for those living near to the project site and for other potentially affected stakeholders. To achieve the mentioned goal and ensure preservation of environment we would like to hear about any concerns or grievances that you have in relation to the Project’s activities.

What kind of grievance can I lodge? Anyone can lodge a grievance if they feel that project activities are negatively affecting them, their community or their local environment. Example of grievances could include, for example: • Negative impacts to local residents (such as excessive dust, noise, odour, etc.) • Environmental damage resulting from the project activities • Practices that endanger the health and safety of employees or residents • Failure to meet the labour rights of Rusmetal’s employees working on the project

How can I submit a grievance? Anyone can submit a grievance to the Rusmetal in the following ways: • By phone to +(995 32) 2 970 118 • By e‐mail on [email protected] • In person to the Mr.David Mindeli. 63 Irakli Abashidze str., Tbilisi, Georgia or 174 Maris Arkhi, 3700, Rustavi, Georgia, or Uravi construction camp site

By completing the attached grievance form and posting it to/dropping it at any of the following addresses: • Rusmetal Ltd, 63 Irakli Abashidze str., Tbilisi, Georgia; or 174 Maris Arkhi, 3700, Rustavi, Georgia • Amrolauri Municipality, Gamgeoba Office – 1 Tamar Mepe str, Ambrolauri; • Uravi construction camp

How will Rusmetal deal with my grievance? Rusmetal will go through the following steps to deal with your grievance:

Step 1: Acknowledgement: Rusmetal will contact you to acknowledge and where possible resolve within the following timescales: Requests for information/complaints will be acknowledged within 5‐10 days and, where possible, the information requested will be provided within 10‐20 days depending on the complexity of information requested/complaints received.

This acknowledgment will include your grievance reference number, the person at Rusmetal responsible for tracking your grievance and their contact details, and the expected date for completing the investigation into your grievance (where appropriate).

Step 2: Investigation: Rusmetal will then set up an investigation into your grievance. We may need to contact you during this investigation Rusmetal will aim to complete the investigation within a further twenty working days.

Step 3 Resolution: When we have investigated the grievance we will contact you with our findings and our proposed response. If our investigations find that the grievance does not relate to the Project’s activities, or if Rusmetal is working within the relevant Georgian and International Standards in relation to the grievance we will explain this in writing to you. Otherwise we will propose a response to address the grievance. If you consider our response and its implementation to be satisfactory we will ask you to sign a statement of satisfaction if you are happy to do so. If you are not satisfied with our response we

SCIENTIFIC‐ RESEARCH FIRM GAMMA Page | 16 will have further discussions with you to see if there are other steps which can be taken to resolve the grievance.

Step 4 Follow up: Rusmetal may contact you at a later stage to check that our activities pose no further problems.

Confidentiality: If you wish your grievance to remain confidential, Rusmetal will ensure that your name and contact details are not disclosed without your consent and only the Rusmetal team directly working on the investigation of your grievance will be aware of them. If it is not possible for the team to fully investigate the grievance without revealing your identity (for example if you are required to give evidence in court) the investigation team will discuss with you how you wish to proceed.

Anonymity: If you wish to lodge a grievance anonymously you can do so using the attached form without filling in the name and contact details. The grievance will still be investigated, but it may be more difficult for Rusmetal to conduct the investigation and we will not be able to give you feedback on our investigations.

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Public Grievance Form

Grievance Reference Number [(to be filled in by Rusmetal]): Contact Details Name:

Address:

Tel:

e‐mail:

How would you prefer to be By post By phone By e‐mail contacted? Please tick box Details of your grievance. Please describe the problems, who it happened to, when, where and how many times, as relevant

What is your suggested resolution for the grievance?

How to submit this form By Post to: 63 Irakli Abashidze str., Tbilisi, Georgia or to Rusmetal 174 Maris Arkhi, 3700, Rustavi, Georgia By hand: 63 Irakli Abashidze str., Tbilisi, Georgia or 174 Maris Arkhi, 3700, Rustavi, Georgia By e‐mail: Please email your grievance, suggested resolution and preferred [email protected]

Signature Date

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