Environmental and Social Management Plan - Roy Hill · 2016-05-12 · This document is the Environmental and Social Management Plan (ESMP) for the Roy Hill Project (Project). The

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Environmental and Social Management Plan

Environment

Environmental and Social Management PlanEnvironment

THIS DOCUMENT IS UNCONTROLLED IN HARD COPY FORMATRev Document Number Author Approver / BFO Issue Date Review Date Page


TABLE OF CONTENTS

1 Introduction ................................................................................................................................................7

1.1 Purpose and scope..............................................................................................................................7

2 Definitions and Abbreviations ..................................................................................................................12

2.1 Definitions .........................................................................................................................................12

1.2 Abbreviations ....................................................................................................................................17

1.3 Reference documents .......................................................................................................................19

3 Lenders General Requirements ................................................................................................................22

4 Environmental and Social Laws ................................................................................................................26

4.1 Legal and other obligations...............................................................................................................26

4.1.1 International ................................................................................................................................26

4.1.2 Australian Government legislation ..............................................................................................27

4.1.3 Western Australian State Government legislation ......................................................................28

4.1.4 Project Approvals.........................................................................................................................29

5 Social Context ...........................................................................................................................................31

5.1 Social area of influence .....................................................................................................................31

5.2 Land tenure .......................................................................................................................................31

5.3 Mining ...............................................................................................................................................32

5.4 Pastoral activities ..............................................................................................................................32

5.5 Tourism .............................................................................................................................................33

5.6 Indigenous people.............................................................................................................................33

5.7 Workforce profile..............................................................................................................................33

6 Environmental and Social Impact Assessment and Standards .................................................................35

6.1 Environmental Impact Assessment processes..................................................................................35

6.1.1 Overview of Western Australian Environmental Impact Assessment Process............................35

6.1.2 Environmental Assessment of the Roy Hill Project......................................................................36

6.1.3 Overview of Australian Government Environmental Assessment process .................................36

6.2 Social Impact Assessment process....................................................................................................39

6.2.1 Overview of Social Impact Assessment process ..........................................................................39

6.2.2 State Agreement Act process.......................................................................................................40

6.2.3 Native title....................................................................................................................................41

6.2.4 Material environmental and social permits.................................................................................42

6.3 Stakeholder consultation during assessment ...................................................................................42

6.4 Environmental and Social Standards ................................................................................................43

6.4.1 Equator Principles ........................................................................................................................43

6.4.2 IFC Performance Standards..........................................................................................................43

6.4.3 IFC Environmental, Health, and Safety General Guidelines.........................................................44




6.4.4 JBIC Environmental and Social Guidelines ...................................................................................44

6.4.5 NEXI Environmental and Social Guidelines ..................................................................................44

6.4.6 US-EXIM Environmental and Social Due Diligence Procedures ...................................................44

6.4.7 OECD Recommendations on Common Approaches on Environment and Officially SupportedCredits 45

7 Business Management Framework ..........................................................................................................46

7.1 Vision and Values ..............................................................................................................................46

7.2 Project Management and Controls...................................................................................................48

7.2.1 Project Procedures.......................................................................................................................48

7.2.2 Engineering ..................................................................................................................................48

7.2.3 Project Controls ...........................................................................................................................49

7.2.4 Trend and Change Management .................................................................................................49

7.2.5 Project Reporting .........................................................................................................................49

7.2.6 Contracts and Procurement.........................................................................................................49

7.2.7 Risk Management ........................................................................................................................49

7.2.8 Safety Controls.............................................................................................................................50

7.2.9 Environmental and Social Controls ..............................................................................................50

7.2.10 Quality Assurance and Control ....................................................................................................50

7.3 Project Planning Framework.............................................................................................................50

7.4 Project Construction Framework ......................................................................................................51

7.4.1 Project Execution Model..............................................................................................................51

7.4.2 Project Construction Organisational Structure............................................................................51

7.5 Operations Management Framework...............................................................................................55

7.5.1 Principal's Project Requirements (PPR) .......................................................................................55

7.5.2 Operational Plans.........................................................................................................................55

7.5.3 Operations Management Structure.............................................................................................55

8 Environmental and Social Management...................................................................................................58

8.1 Environmental and Social Management Framework........................................................................58

8.1.1 Health, Safety, Emergency and Security Management Framework ............................................59

8.2 Environmental Management ............................................................................................................61

8.2.1 Environmental policy ...................................................................................................................61

8.2.2 Objectives and targets .................................................................................................................62

8.2.3 Project Design and Construction .................................................................................................65

8.2.4 Project Operations .......................................................................................................................65

8.3 Social Management...........................................................................................................................65

8.3.1 Social Policies ...............................................................................................................................66

8.3.2 Objectives and Targets.................................................................................................................66

8.3.3 Conditions of labour, employment and work..............................................................................67




8.3.4 Occupational health, safety, emergency and security.................................................................68

8.3.5 Community health and safety......................................................................................................72

8.3.6 External Stakeholders ..................................................................................................................72

8.3.7 Regional employment and training..............................................................................................72

8.3.8 Regional Development and local procurement ...........................................................................72

8.3.9 Regional and local accessibility to services and facilities.............................................................73

8.4 Monitoring ........................................................................................................................................73

8.5 Contingency ......................................................................................................................................73

8.6 Reporting...........................................................................................................................................73

8.6.1 Internal.........................................................................................................................................73

8.6.2 External ........................................................................................................................................74

9 Emergency Preparedness and Response..................................................................................................75

9.1 Crisis Emergency and Security Management System .......................................................................75

9.2 Crisis Management Plan....................................................................................................................75

9.3 Emergency Management Plan ..........................................................................................................75

10 Incident Management, Corrective Actions and Preventative Actions .....................................................76

10.1 Incident management.......................................................................................................................76

10.2 Corrective and preventative actions.................................................................................................76

11 Roles and Responsibilities.........................................................................................................................78

11.1 Principal.............................................................................................................................................78

11.1.1 Leadership team ..........................................................................................................................78

11.1.2 General Managers, Project Directors/ Project Managers............................................................78

11.1.3 General Manager External Affairs................................................................................................78

11.1.4 General Manager Health, Safety and Environment.....................................................................79

11.1.5 General Manager Human Resources ...........................................................................................80

11.1.6 Manager Environment .................................................................................................................80

11.1.7 Manager Indigenous Relations ....................................................................................................81

11.1.8 Environmental and External Affairs Superintendents .................................................................81

11.1.9 Health and Safety, Industrial Relations and Human Resources Superintendents.......................82

11.1.10 Roy Hill Environmental and Heritage Personnel..........................................................................83

11.1.11 Roy Hill Health and Safety, Industrial Relations and Human Resources Personnel ....................83

11.2 Project Management Contractor ......................................................................................................84

11.3 EPC Contractor, Design & Construct Contractors, Operational Contractors ....................................84

11.4 All personnel .....................................................................................................................................85

12 Training and Awareness............................................................................................................................86

12.1 Training .............................................................................................................................................86

12.1.1 Inductions.....................................................................................................................................86




12.2 Training register ................................................................................................................................87

12.3 Review and audit...............................................................................................................................88

13 Communication.........................................................................................................................................89

13.1 Internal stakeholders ........................................................................................................................89

13.1.1 Communication and participation ...............................................................................................89

13.1.2 Grievance / conflict mechanism ..................................................................................................90

13.1.3 Reporting......................................................................................................................................90

13.2 External stakeholders........................................................................................................................91

13.2.1 Communication............................................................................................................................91

13.2.2 External Grievance mechanism....................................................................................................92

13.2.3 Reporting......................................................................................................................................92

13.2.4 Indigenous peoples ......................................................................................................................92

14 Audit and Review......................................................................................................................................93

14.1 Internal auditing and review.............................................................................................................93

14.2 Independent review..........................................................................................................................93

14.3 Primary Producer Supply chain review .............................................................................................93

15 Control of Records ....................................................................................................................................95

15.1 Document control system.................................................................................................................95

15.2 Retention times.................................................................................................................................95

15.3 Access to documents ........................................................................................................................95

16 Action Plan................................................................................................................................................96




TABLES

Table 2-1: Definitions ...................................................................................................................................... 12

Table 2-2: Abbreviations.................................................................................................................................. 17

Table 2-3: Roy Hill Reference documents ....................................................................................................... 19

Table 2-4: External Reference documents ...................................................................................................... 21

Table 7-1: Project Objectives........................................................................................................................... 46

Table 7-2: Operational Mining Phases ............................................................................................................ 55

Table 8-1: Roy Hill Objectives and Targets for environmental factors............................................................ 62

Table 8-2: Roy Hill objectives and targets for social factors............................................................................ 66

Table 8-3: Content of Management System Standards for Operations and Construction ............................. 69

Table 8-4: Performance Standards for Operations and Construction............................................................. 70

Table 16-1: Action Plan.................................................................................................................................... 96

FIGURES

Figure 1-1: Environmental and Social Management Framework...................................................................... 9

Figure 1-2: Roy Hill Project Location ............................................................................................................... 11

Figure 5-1: Location of towns, indigenous communities and tourist sites in proximity to the project. ......... 34

Figure 6-1: Environmental impact assessment and management of construction and operation phases ofthe Project ....................................................................................................................................................... 38

Figure 6-2: Social impact assessment and management ................................................................................ 40

Figure 7-1 – Roy Hill’s Business Framework .................................................................................................... 47

Figure 7-2: Project Construction Organisational Delivery Structure (PMC / EPC Delivery Model) ................. 51

Figure 7-3: Roy Hill Project Team Organisational Structure............................................................................ 53

Figure 7-4: Principal Project Requirements content and structure ................................................................ 54

Figure 7-5: Roy Hill organisational operational structure – direct reports to the CEO ................................... 56

Figure 7-6: Roy Hill organisational operational structure – direct reports to the COO .................................. 56

Figure 7-7: Roy Hill organisational Leadership Team structure ...................................................................... 57

Figure 8-1: Environment and social management framework........................................................................ 59

Figure 8-2: Roy Hill HSES Framework .............................................................................................................. 60




APPENDICES

Appendix 1: EPA objectives for relevant environmental factors (EPA, 2013) ................................................. 97

Appendix 2: Material environmental and social permits relating to the Project.......................................... 100

Appendix 3: Equator Principles (June 2013).................................................................................................. 102

Appendix 4: IFC Performance Standards (January 2012) .............................................................................. 104

Appendix 5: IFC Environmental, Health, and Safety General Guidelines (April 2007) .................................. 108

Appendix 6: JBIC Environmental and Social Guidelines ................................................................................ 111

Appendix 7: NEXI Environmental and Social Considerations ........................................................................ 115

Appendix 8: US EX-IM Environmental and Social Due Diligence Procedures and Guidelines....................... 119

Appendix 9: OECD Revised Council Recommendations ................................................................................ 123

Appendix 10: Roy Hill Governance Policy...................................................................................................... 126

Appendix 11: Roy Hill Environmental Policy.................................................................................................. 127

Appendix 12: Roy Hill Health and Safety Policy............................................................................................. 128

Appendix 13: Roy Hill Stakeholder Engagement Policy................................................................................. 129

Appendix 14: Roy Hill Employment Policy..................................................................................................... 130




1 IntroductionThis document is the Environmental and Social Management Plan (ESMP) for the Roy Hill Project (Project).The Project is situated in the Pilbara region of Western Australia, approximately 115 km north of Newman,on the flat plains at the eastern end of the Chichester Range (Figure 1-2).

With a defined mineralisation of more than 1.2 billion tonnes of +55% Fe iron ore, enough to sustain a minelife of more than 20 years, the Project will produce 55 million tonnes per annum (mtpa) of Lump and SinterFines Iron Ore products for export to steel mills1.

The Project comprises the construction and operation of state of the art facilities including:

55 mtpa open pit mine and wet processing plant;

344 km heavy haul railway linking the mine and port;

Port stockyard and a two-berth export facility in Port Hedland;

Integrated Corporate Headquarters and Remote Operations Centre in Perth; and

Supporting infrastructure including a mine site airport and accommodation village.

Roy Hill Holdings Pty Ltd (RHH) is 70% beneficially owned by Hancock Prospecting Pty Ltd (HPPL). Theremaining 30% is beneficially owned by Marubeni (Japan), POSCO (Korea) and China Steel Corporation(Taiwan).

RHH is the parent company to Roy Hill Iron Ore Pty Ltd (RHIO) and Roy Hill Infrastructure Pty Ltd (RHI). Akey aspect of the corporate structure is that RHIO holds mining assets and RHI holds infrastructure assets.This enables the operation of infrastructure to be separated from the operation of the mine.

RHH, RHIO and RHI are jointly referred to as 'Roy Hill' within this document.

Roy Hill is responsible for the construction and operation of Project.

1.1 Purpose and scopeThis Roy Hill ESMP is an over-arching plan that defines key objectives for environmental and socialmanagement during the construction and operational phases of the Project. The ESMP describes andoutlines:

the framework for environmental and social management of Project activities (

1 This Project description achieves the requirements of International Finance Corporation Performance Standards (IFC6.4)




Figure 1-1);

the environmental and social processes and procedures that will be implemented to meet the Roy Hillenvironmental and social objectives and targets and ensure statutory compliance; and

how the relevant Environmental and Social Standards will be addressed.

This update to the ESMP is made to reflect changes to the Project activities in accordance with paragraph1.20(i) of Schedule 3 to the Syndicated Loan Facilities Agreement (SLFA).




Figure 1-1: Environmental and Social Management Framework

The Environmental and Social Management Framework (ESMF) meets the requirements of the followingInternational Environmental and Social Standards:

Principles of ISO 14001:2004 “Environmental management systems - requirements with guidance for use”(ISO14001:2004);

Equator Principles (June 2013) (EP)2;

International Finance Corporation (IFC) Performance Standards (January 2012);

Export Credit Agency (ECA) requirements:

o Japan Bank for International Cooperation (JBIC);

o Nippon Export and Investment Insurance (NEXI);

o Export Import Bank of the United States (US-EXIM); and

o Organisation for Economic Cooperation and Development (OECD);

Australian Standards relating to environmental and social management; and

International Conventions relating to the environment to which Australia is a signatory and which havebeen ratified into Law in Australia (International Conventions).

2 The Project is categorised as Category A under the Equator Principles (EP1).




Roy Hill recognises that some lenders may categorise the Project as Category A under the Equator Principles.This ESMP documents the ESMF for the Project and demonstrates that implementation of the ESMF willmeet covenants in the SLFA relating to environmental and social management, compliance reporting andproject decommissioning and closure in accordance with the Equator Principles.

The ESMP applies to the construction and operation of the Project including all components of the mine,rail and port projects. Compliance with the ESMP is mandatory for all Roy Hill personnel, the ProjectManagement Contractor (PMC), and all Contractors and their sub-contractors.

Note: The Roy Hill ESMP is structured to demonstrate how the Environmental and Social Standards will beaddressed. An 'IFC Performance Standards, IFC Environment, Health, and Safety General Guidelines and EPRequirements Guide' box is included at the beginning of each section of this Plan to annotate which IFCPerformance Standard, IFC Environment, Health, and Safety General Guidelines, Equator Principle and ECArequirement is addressed in that section.




Figure 1-2: Roy Hill Project Location




2 Definitions and Abbreviations

2.1 DefinitionsOther capitalised terms not defined in this section have the same meaning as the definitions in theSyndicated Loan Facilities Agreement.

Table 2-1: Definitions

Term Definition

Aboriginal Heritage Act means the Aboriginal Heritage Act 1972 (WA)

Approving Authoritymeans experts and specialists from the Roy Hill Owner's Team, the PMC and other externalorganisations as appropriate.

Australian Standardsmeans all standards, principles and guidelines relating to environmental and socialmanagement that are required to be complied with by Australian Law and practice

Dangerous Goods Safety Act means the Dangerous Goods Safety Act 2004 (WA)

Environment

means all, or any, of the following:

(a) the air (including, without limitation, any layer of the atmosphere and the air withinnatural or man-made structures whether above or below ground);

(b) water (including, without limitation, marine, coastal, estuarine and inland waters,watercourses, ground and surface water and water in drains and sewers);

(c) land (including without limitation, surface and sub-surface soil and land underwater);

(d) flora, fauna, natural habitats, and ecosystems;

(e) amenity, cultural heritage and archaeology; or

(f) civil society and human beings and any material adverse impact thereon including,without limitation, resettlement, land acquisition or any material adverse impact upon thelivelihood or living standards (excluding general inflationary changes) of those personsaffected by resettlement or land acquisition at the time of or subsequent to but attributableto such resettlement or land acquisition.

Environment and Social Claim

means any claim, proceeding or formal notice by any person other than Roy Hill Holdings PtyLtd (RHH), Roy Hill Iron Ore Pty Ltd (RHIO) or Roy Hill Infrastructure Pty Ltd (RHI) orinvestigation by any public authority, in each case in respect of any Environmental and SocialLaw or Environmental and Social Standard which is initiated against or issued to:

(a) any of RHH, RHIO or RHI in relation to the Project; or

(b) any other person in relation to the implementation of the Project within the ProjectSites of which RHH, RHIO or RHI is aware.

Environmental and SocialImpact Assessment

means the environmental and social impact assessment with respect to the Project, includingany supplements, modifications or amendments, which shall comply with and be carried outin accordance with the Environmental Law and which has been delivered by RHH as an initialcondition precedent to Senior Debt Facilities provided under the Syndicated Loan FacilitiesAgreement.

Environmental and SocialManagement Plan

This document

Environmental and SocialIncident

means an incident or accident relating to the Project which under Environmental and SocialLaw requires any of RHH, RHIO or RHI to undertake, (or to the extent not so required underany Environmental or Social Law which should be taken in accordance with Good MiningPractice), emergency or immediate remedial action and which has the following impacts inany of the categories specified:

(a) in relation to health: death, major disability or health damage;




Term Definition

(b) in relation to society: destruction of or damage to a site or object of cultural orreligious significance, or serious social conflict within the community; or

(c) in relation to the Environment: serious, material or persistent damage to theEnvironment or breaches or violations of Environmental and Social Law, the Environmentaland Social Management Plan or Environmental and Social Standards.

Environmental Law

means any applicable law or regulation of Western Australia or Australia with respect to thedevelopment, construction and operation of the Project within the Project Site and thecarrying out of dredging activities at Port Hedland, and which relate to:

the pollution or protection of the environment;

any emission or substance capable of causing harm to any living organism or theenvironment;

and the emission of greenhouse gases.

Environmental and SocialReport

means each report required to be delivered by or on behalf of RHH in accordance with theSyndicated Loan Facilities Agreement.

Environmental and SocialRequirements

means the Environmental and Social Laws, the Environmental and Social Standards, MaterialEnvironmental Authorisations and the Environmental and Social Management Plan.

Environmental and SocialStandards

means those environmental and social standards applicable in relation to the Project, and asreflected in the Environmental and Social Management Plan, including as set out in each ofthe following:

(a) international conventions relating to the Environment to which Australia is asignatory and which have been ratified into Law in Australia;

(b) the JBIC Environmental and Social Guidelines;

(c) the NEXI Environmental and Social Guidelines;

(d) the US-EXIM Environmental and Social Due Diligence Procedures and Guidelines(June 2013);

(e) the IFC Environmental, Health and Safety Guidelines (April 2007) including withoutlimitation the General EHS guidelines and all applicable Industry Sector Guidelines;

(f) the IFC Performance Standards (January 2012);

(g) the OECD Recommendations on Common Approaches on Environment andOfficially Supported Credits (2012); and

(h) Australian Standards relating to Environmental Management,

provided that in the event of any ambiguity or conflict between any of these standards:

the standards applicable in order to comply with Environmental and Social Law shall apply or(II), if Environmental and Social Law does not apply, the standards applicable in order tocomply with the IFC Performance Standards (January 2012) shall apply; and

an otherwise ambiguous Environmental and Social Standard that relates to a requirementexplicitly covered by Environmental and Social Law, the standards applicable to comply withEnvironmental and Social Law shall apply.

Environmental Authorisation

means any Authorisation which:

(a) is required to be obtained by any of RHH, RHIO or RHI with respect to the Project;or

(b) is otherwise required to be obtained by any of RHH, RHIO or RHI for thedevelopment, construction and operation of the Project,




Term Definition

in each case under Environmental and Social Law, including the Material EnvironmentalAuthorisations.

Environmental Protection Act means Environmental Protection Act 1986 (WA).

Environmental Protectionand Biodiversity andConservation Act

means the Environmental Protection and Biodiversity Conservation Act 1999 (AustralianGovernment).

Good Mining Practice

Means the exercise of that degree of skill, care, prudence, (operational and financial)foresight and operating practice which would reasonably and ordinarily be expected from theoperator of a significant, well established and proven iron ore mine and associated rail andport infrastructure similar to the Project with the assets and operating conditions beingconsistent with those of the Project, and in a manner consistent with applicable law and theWestern Australian Government’s Department of Mines and Petroleum’s guidelines andcodes of practice.

Hancock Prospecting means Hancock Prospecting Pty Ltd ACN 008 676 417

IFC Performance Standardsmeans IFC Performance Standards on Environmental and Social Sustainability dated January2012.

Intercreditor Agentmeans the relevant financial institution acting on behalf of all other Financial Institutions asIntercreditor Agent.

International Conventionsmeans International Conventions relating to the environment to which Australia is a signatoryand which have been ratified into Law in Australia.

JBIC Environmental and SocialGuidelines

means the “Japan Bank for International Cooperation Guidelines for Confirmation ofEnvironmental and Social Considerations” dated April 2012.

Land Administration Act means the Land Administration Act 1997 (WA).

Material EnvironmentalAuthorisations

means the material authorisations relating to Environmental Law.

Mining Act means the Mining Act 1978 (WA).

National Greenhouse andEnergy Reporting Act

means the National Greenhouse and Energy Reporting Act 2007 (Australian Government).

NEXI Guidelinesmeans the “Guidelines on Environmental and Social Considerations in Trade Insurance”published by NEXI dated July 2009.

NGER Scheme

means the legislative regime which requires the reporting of greenhouse gas emissions,energy produced and energy consumed, established by the NGER Act and legislativeinstruments issued pursuant to the NGER Act including:

(a) the National Greenhouse and Energy Reporting Regulations 2008 and the NationalGreenhouse and Energy Reporting (Measurement) Determination 2008;

(b) any guidelines thereto issued by the Minister or Government Agency administeringthe NGER Act; and

(c) any replacement, supplementary or analogous legislative regime or guidelines.

Objective A goal that an organisation sets itself to achieve, which is quantified where practicable.

Planning and DevelopmentAct

means the Planning and Development Act 2005 (WA)

Principalmeans either as Roy Hill Infrastructure Pty Ltd ACN 130 249 633 or Roy Hill Iron Ore Pty LtdACN 123 722 038 or both

Remedial Action Plan

means a plan to undertake such measures as may be necessary to remove, remedy, abate,contain, treat, ameliorate or otherwise render compliant any matter that has given rise to orthe effects of any:




Term Definition

material breaches of Environmental and Social Standards, Material EnvironmentalAuthorisations, the Environmental and Social Management Plan or Environmental and SocialLaws; or

Material Environmental and Social Incident,

which plan must in each case specify, to the extent reasonably appropriate having regard tothe applicable matter, time-bound actions (including a date by which RHH reasonablybelieves that the relevant damage or breach that is the subject of the remediation shall beremedied or cured), targets and success criteria or objectives to be achieved in remedying thedamage or breach (including any appropriate clean up levels and the methods to be adoptedto ascertain such levels such as risk based corrective actions).

Rights in Water and IrrigationAct

means the Rights in Water and Irrigation Act 1914 (WA)

Roy Hill means Roy Hill Holdings Pty Ltd, Roy Hill Iron Ore Pty Ltd, Roy Hill Infrastructure Pty Ltd

Roy Hill Holdings means Roy Hill Holdings Pty Ltd ACN 123 721 077.

Roy Hill Infrastructure means Roy Hill Infrastructure Pty Ltd ACN 130 249 633.

Roy Hill Iron Ore means Roy Hill Iron Ore Pty Ltd ACN 123 722 038

Roy Hill Project Roy Hill mine, port and rail facilities

Social Law

Social laws are broadly defined as any applicable law or regulation of Western Australia orAustralia that apply to the construction and operation of the Project and which relate to:

occupational health and safety;

conditions of labour, employment and work;

human health, safety and security;

indigenous relations and heritage; or

land acquisition.

Supplemental Terms

Means:

in relation to an Amortising Construction Sub-Facility (other than the Equipment Finance Sub-Facility), the terms set out for that Sub-Facility in the relevant part of Schedule 9 to theSyndicated Loan Facilities Agreement, or such other terms as may be agreed between theBorrower and the Sub-Facility Agent of that Sub-Facility;

in relation to a Corporate Sub-Facility or the FX Options Premium Sub-Facility, the terms setout for that Sub-Facility in the relevant part of Schedule 10, or such other terms as may beagreed between the Borrower and the Sub-Facility Agent of that Sub-Facility; and

in relation to the Equipment Finance Sub-Facility:

initially, the terms set out for the Equipment Finance Sub-Facility in the relevant part ofSchedule 9 to the Syndicated Loan Facilities Agreement, or such other terms as may beagreed between the Borrower and the Sub-Facility Agent of that Sub-Facility; and

on and from the date (if any) on which US-EXIM becomes a Senior Lender, the supplementalterms set out for the Equipment Finance Sub-Facility [as appended to the AccessionAgreement pursuant to which US-EXIM became a Senior Lender], or such other terms as maybe agreed between the Borrower and the Sub-Facility Agent of that Sub-Facility.

SWC ProjectSouth West Creek Dredging and Reclamation Project approved under Ministerial Statement859

Syndicated Loan FacilitiesAgreement

The Senior Debt document between RHH, RHIO, RHH, certain financial institutions as lenders,the security trustee and certain financial institutions as sub-facility agents (the SLFA) which




Term Definition

contains the terms under which the Senior Lenders will provide finance to Roy Hill for theconstruction and development of the Project.

TargetA result towards which efforts are directed that is quantified or measured where practicable,in order to achieve an objective, or part thereof.

Traditional Claimant

People who, through membership in a descent group or clan, have responsibility for caringfor particular country and are authorised to speak for country and its heritage. Authorisationto speak for country and heritage may be as a senior traditional claimant, an elder, or in morerecent times, as a registered Native Title claimant.

Transaction Documents means the Senior Finance Documents and the Project Documents as defined in the SLFA.

US-EXIM Environmental andSocial Guidelines

means US-EXIM Environmental Procedures and Guidelines (14 August 2008)

US-EXIM Environmental andSocial Guidelines Breach

is defined in clause 16.1.9(a)(3)(C) (ECA Environmental and Social Standards).

Wildlife Conservation Act means the Wildlife Conservation Act 1950 (WA)

Workforce means anyone employed directly or indirectly, or acting on behalf of the Principal.




2.2 AbbreviationsTable 2-2: Abbreviations

Abbreviation Definition

AA Approving Authority

AS/NZS Australian New Zealand Standard

BoD Basis of Design

CECR Contractor Environmental Compliance Requirements

CEO Chief Executive Officer

COO Chief Operating Officer

DAA Department of Aboriginal Affairs

DER Department of Environment Regulation (WA)

DMP Department of Mines and Petroleum (WA)

DMS Document Management System

DoE Department of the Environment (Australian Government)

DoH Department of Health (WA)

DoW Department of Water (WA)

DSD Department of State Development

ECA Export Credit Agency

EHSG IFC Environmental, Health, and Safety General Guidelines

EIA Environmental Impact Assessment

EP Equator Principle

EP Act Environmental Protection Act 1986 (WA)

EPA Environment Protection Authority (WA)

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth).

EPC Engineering, Procurement and Construction

EPFI Equator Principles Financial Institution

ESMP Environmental and Social Management Plan

ESMS Environmental and Social Management System

FIFO Fly in Fly out

GD Ground Disturbance

GDA94 Geocentric Datum of Australia 1994 (coordinates)

GHG Greenhouse Gas (emissions)

ha Hectares

HPPL Hancock Prospecting Pty Ltd ACN 008 676 417

HSE Health Safety and Environmental

HSECH Health, Safety, Environment, Community and Heritage

HSEHCQ Health, Safety, Environment, Heritage, Community and Quality

HSES Health, Safety, Emergency and Security

HV Heavy vehicle (e.g. haul truck, water truck, digger, excavator, etc.)

IFC International Finance Corporation

ISO International Organisation for Standardisation

JBIC Japan Bank for International Cooperation

kL Kilolitre (measure of volume)

km Kilometre (measure of distance or length)

L Litre (measure of volume)

m Metres (measure of distance or length)




Abbreviation Definition

mg/L Milligrams per Litre

MNES Matters of National Environmental Significance

MS Ministerial Statement

Mt Million Tonnes

mtpa Million Tonnes per Annum (measure of production rate)

NEXI Nippon Export and Investment Insurance

NGERS National Greenhouse Emissions Reporting Scheme

NPI National Pollutant Inventory

OECD Organisation for Economic Co-operation and Development

OEMP Operational Environmental Management Plan

OEPA Office of the Environment Protection AuthorityPHPA Port Hedland Port AuthorityPMC Project Management Contractor

PPE Personnel Protective Equipment

PPR Principal Project Requirements

Project Roy Hill Project

RCA Root Cause Analysis

RHH Roy Hill Holdings Pty Ltd

RHI Roy Hill Infrastructure Pty Ltd

RHIO Roy Hill Iron Ore Pty Ltd

SIA Social Impact Assessment

SLFA Syndicated Loan Facilities Agreement

SLTA Senior Lenders’ Technical Advisor

SRL Special Rail Licence

SSoW Safe System of Work

US-EXIM Export Import Bank of the United States




2.3 Reference documentsTable 2-3: Roy Hill Reference documents

Document title Document number

Roy Hill Aboriginal Heritage Management Guidelines for Contractors 100RH-0000-HE-GUI-2003

Roy Hill Bullying and Harassment Policy Not applicable

Roy Hill Bullying and Harassment Procedure Not applicable

Roy Hill Compliance Audit Schedule 100RH-0000-EN-SCH-2007

Roy Hill Consolidated List of Approvals 100RH-0000-EN-REG-2001

Roy Hill Contractor Environmental Compliance Requirements 100RH-0000-EN-GUI-2001

Roy Hill Contractor environmental report 100RH-0000-EN-FOR-2011

Roy Hill Contractor Health and Safety Guideline 100RH-0000-HS-GUI-2001

Roy Hill Contractor Land Rehabilitation Guidelines 100RH-0000-EN-GUI-2005

Roy Hill Contractor Weed Management Guidelines 100RH-0000-EN-GUI-2003

Roy Hill Cultural Heritage Management Plan RH1-001-00-HE-POL-1029

Roy Hill Cyclone Management Plan - Mine and Rail South 100RH-0000-HS-PLN-2014

Roy Hill Cyclone Management Plan - Port Hedland and Rail North 100RH-0000-HS-PLN-2013

Roy Hill Document Control Procedure 100RH-0000-PM-PRO-2005

Roy Hill Document Execution Procedure 100RH-0000-PM-PRO-2025

Roy Hill Drill and Blast Activities near Aboriginal Heritage Sites procedure 100RH-0000-HE-PRO-2003

Roy Hill Drinking Water Management Plan 100RH-0000-EN-PLN-2001

Roy Hill Emergency Management Plan 100RH-0000-HS-PLN-2004

Roy Hill Emergency Medical Response Plan 100RH-0000-HS-PLN-2026

Roy Hill Emergency Services Interoperability Procedure 100RH-0000-HS-PRO-2017

Roy Hill Employee Relations Guidelines for Contractors 100RH-0000-IR-GUI-2004

Roy Hill Employee Relations Information for Contractors on Roy Hill IronOre Project. Roy Hill CCIWA Tender booklet

Roy Hill Employment Policy 000RH-0000-RH-POL-0003

Roy Hill Environment Policy 000RH-0000-RH-POL-0002

Roy Hill Environmental Basis of Design 100RH-0000-EN-BOD-2001

Roy Hill Environmental Risk Register – 15 August 2012 (excel spreadsheet) RH1-001-00-EN-REG-0027

Roy Hill External Complaints Handling Procedure (Draft) TBA

Roy Hill Fatigue Management Plan 100RH-0000-HS-PLN-2006

Roy Hill Fauna trapping, translocation and monitoring program 100RH-0000-EN-GUI-2010

Roy Hill Fibrous Materials Management Procedure 100RH-0000-EN-PRO-2008

Roy Hill Fitness for Work Plan 100RH-0000-HS-PLN-2003

Roy Hill Governance Policy 000RH-0000-RH-POL-0005

Roy Hill Ground Disturbance Permit Procedure 00RH-0000-HE-PRO-2002

Roy Hill Health and Safety Performance Standards Not applicable

Roy Hill Health and Safety Policy 000RH-0000-RH-POL-0001

Roy Hill Incident Investigation and Reporting Procedure 100RH-0000-HS-PRO-2004

Roy Hill Incident Notification Flowchart 100RH-0000-HS-FLC-2001

Roy Hill Indigenous Heritage Site Breach Protocol 100RH-0000-HE-PRO-2001

Roy Hill Indigenous Relations and Heritage Protocol 100RH-0000-HE-PRO-2004




Document title Document number

Roy Hill Injury Management and Workers Compensation Procedure 100RH-0000-HS-PRO-2003

Roy Hill Integrated Management Standards Not applicable

Roy Hill Land Access Protocol 100RH-0000-LA-PRO-2001

Roy Hill Land Access Request Form 100RH-0000-EN-FOR-2013

Roy Hill Landfill management guideline 100RH-0000-EN-GUI-2007

Roy Hill Legal Requirements, Commitments and Agreements 100RH-0000-EN-REP-2011

Roy Hill Legal Requirements, Commitments and Agreements document 100RH-0000-EN-REP-2011

Roy Hill Lightning Procedure 100RH-0000-HS-PRO-2009

Roy Hill Mangrove monitoring program 100RH-4000-EN-REP-2004

Roy Hill Operational Environmental Management Plan 050RH-0000-EN-PLN-0001

Roy Hill Operations Port and Rail Emergency and Security ManagementPlan 100RH-0000-HS-PLN-2028

Roy Hill PMC Environmental Management Plan 100RH-0000-EN-PLN-2003

Roy Hill Port Dust Management Plan 100RH-4000-EN-PLN-2001

Roy Hill PPE Standard 100RH-0000-HS-STD-2003

Roy Hill Preliminary Rehabilitation and Closure Plan 100RH-1000-EN-REP-2009

Roy Hill Rail Groundwater Operating Strategy 100RH-0000-WW-PER-2001

Roy Hill Recruitment and Personnel Management Plan 100RH-0000-HR-PLN-2001

Roy Hill Significant flora, fauna and weed species identification guide 100RH-0000-EN-GUI-2004

Roy Hill Stakeholder Engagement Policy 000RH-0000-RH-POL-0006

Roy Hill Superintendent Environment Audit and Inspection Schedule 100RH-0000-EN-SCH-2001

Roy Hill Vegetation Monitoring Plan RHI-001-EN-PLN-0967

Roy Hill Vertebrate Fauna Management Plan 100RH-3000-EN-REP-2021

Roy Hill Waste management guideline 100RH-0000-EN-GUI-2002

Roy Hill Wastewater treatment plant sampling and monitoring guideline 100RH-0000-EN-GUI-2008

Roy Hill Water Resource Operating Strategy for Mine Construction WaterSupply 100RH-0000-WW-PER-2001

Roy Hill Water resource operating strategy for port dewatering bores RHIO-001-REP-1970

Roy Hill Weed management guidelines 100RH-0000-EN-GUI-2003

Roy Hill Weed management plan 100RH-3000-EN-REP-2021

Shire of East Pilbara Community Development Plan Not applicable

Town of Port Hedland Community Development Plan Not applicable




Table 2-4: External Reference documents

Document Title Author/Date

“Guidelines on Environmental and Social Considerations in TradeInsurance” published by NEXI dated July 2009.

NEXI, 2009

Common Approaches for Officially Supported Export Credits andEnvironmental and Social Due Diligence

OECD, 2012

Department of State Development (at http://www.dsd.wa.gov.au/) Department of State Development, 2010

Environmental Protection Authority (athttp://www.epa.wa.gov.au/Pages/default.aspx)

EPA, 2012

Export-Import Bank of the United States (at http://www.exim.gov/) EX-IM, 2013

Fair Work Commission (at http://www.fwc.gov.au/) Fair Work Commission, 2013

IFC Environmental, Health and Safety General Guidelines dated April 2007 IFC World Bank Group, 2007

IFC Performance Standards on Environmental and Social Sustainabilitydated January 2012

IFC World Bank Group, 2012

International Finance Corporation 2012 (at http://www.ifc.org/) International Finance Corporation 2012

ISO14001:2004 – Environmental management systems – Requirementswith guidance for use

International Organisation for Standardisation,2004

Japan Bank for International Cooperation “Guidelines for Confirmation ofEnvironmental and Social Considerations” dated April 2012.

JBIC, 2012

Nippon Export and Investment Insurance (at http://nexi.go.jp/en/) NEXI, 2013

OECD Revised Council Recommendations on Common Approaches onEnvironment and Officially Supported Credits dated June 2007

OECD, 2007

Organisation for Economic Co-operation and Development (athttp://www.oecd.org/australia/)

OECD, 2012

Port Hedland Port Authority (at http://www.phpa.com.au/) PHPA, 2011

Revised Council Recommendation on Common Approaches on theEnvironment and Officially Supported Export Credits

OECD, 2007

The Equator Principles, June 2013 (at http://www.equator-principles.com/).

Equator Principle Association, 2013

US-EXIM Environmental and Social Due Diligence Procedures andGuidelines dated June 2013

US-EXIM, 2013




3 Lenders General RequirementsIFC Performance Standards and EP Requirements Guide

This section addresses the specific requirements of:

EP8 (EP8.1, EP8.3) – Covenants

The Project is being financed by a combination of equity from the Sponsors (ultimate owners) of RHH anddebt finance from a syndicate of Senior Lenders comprising Export Credit Agencies (ECAs) and commercialbanks. As a condition of the finance from the Senior Lenders, Roy Hill provides certain covenants andundertakings in relation to the Senior Lenders Environmental and Social Requirements which comprise the:

Environmental and Social Laws. This is defined in the SLFA as:

any applicable law or regulation of Western Australia or Australia with respect to the development,construction and operation of the Project within the Project Site and the carrying out of dredging activitiesat Port Hedland, and which relates to:

(a) the pollution or protection of the environment;

(b) harm to or the protection of human health and safety;

(c) any emission or substance capable of causing harm to any living organism or the Environment;

(d) the emission of greenhouse gases; and

(e) social and resettlement issues, including employee relations,

in force from time to time, solely to the extent that it is applicable to the Project, and including:

(i) the Environmental Protection and Biodiversity Conservation Act 1999 (Cth);

(ii) the Environmental Protection Act 1986 (WA);

(iii) the Clean Energy Act 2011 (Cth);

(iv) the NGER Scheme;

(v) the Occupational Health and Safety Laws;

(vi) the Aboriginal Heritage Act 1972; and

(vii) the Native Title (State Provisions) Act 1999 (WA);

Environmental and Social Standards as defined in this document;

Material Environmental Authorisations (Appendix 2); and

Environmental and Social Management Plan (this document).

The SLFA requires Roy Hill to provide periodic Environmental and Social Reports summarising it’scompliance with the Environmental and Social Requirements. The reporting requirements include:

the results of the regular material environmental monitoring is to be included in Roy Hill’s monthlymanagement report;

prior to and for one (1) year following the Lenders’ Practical Completion Date, within sixty (60) days afterthe end of the six-month period ending on 30 June and (ii) ninety (90) days after the six-month periodending on 31 December, deliver to the Intercreditor Agent a report summarising Roy Hill’s compliance (orany non-compliance and remedial actions taken) with Environmental and Social Requirements during that




six (6) month period, including a register of all material Environmental and Social Incidents and materialEnvironmental and Social Claims that occurred during that six (6) month period;

after the date falling one (1) year after the Lenders’ Practical Completion Date and within ninety (90) daysafter the end of each calendar year thereafter, deliver to the Intercreditor Agent a report summarisingRoy Hill’s compliance (or any non-compliance and remedial actions taken) with the Environmental andSocial Requirements during that year, including a register of all material Environmental and SocialIncidents and material Environmental and Social Claims that occurred during that year;

promptly after its issue, provide a copy of the report as to Roy Hill’s greenhouse gas emissions that isprovided under the NGER Scheme;

provide such other information as is reasonably requested by the Intercreditor Agent in relation to RoyHill’s compliance with the Environmental and Social Requirements, as soon as reasonably practicable afterthe relevant request is made; and

as and when required, provide any additional reporting with respect to the Environment to the extentrequired under any Supplemental Terms (these Supplemental Terms form part of the financedocumentation).

Roy Hill will be subject to the following environmental and social covenants throughout the life of the loan:

(a) Roy Hill will (or will procure that the relevant person will):

(i) obtain, maintain in full force and effect, replace and renew each Environmental Authorisation asand when (A) required by Roy Hill for the implementation of the Project or (B) otherwise requiredfor the implementation of the Project within the Project Site, including the carrying out of anydredging activities at Port Hedland, by Roy Hill or its contractors or sub-contractors with respectto the Project, in all material respects in accordance with the terms of the Transaction Documents;

(ii) procure that all of (A) Roy Hills’ activities in connection with the Project or (B) any other person'sactivities with respect to the Project within the Project Site, including the carrying out of anydredging activities at Port Hedland, comply in all material respects with the Environmental andSocial Requirements;

(iii) engage with other stakeholders and interested parties with respect to the Project as and whererequired by applicable Law or the Environmental and Social Requirements; and

(iv) ensure that in carrying out any required remediation work at the Project Site the subject of thePort Facilities Lease and License it has or, to the extent held by a third party, it is entitled to relyon any Authorisation required to enable it to carry out that work without breaching the AboriginalHeritage Act 1972.

(b) Roy Hill will establish, as and when required in relation to the Project, appropriate procedures to monitorand audit compliance with the Environmental and Social Requirements.

(c) Roy Hill will promptly upon becoming aware thereof, notify the Intercreditor Agent of:

(i) any current or threatened material Environmental and Social Claim;

(ii) any event or circumstances that it believes (acting reasonably) are likely to result in any materialEnvironmental and Social Claim;

(iii) any suspension, revocation, denial or non-renewal of any Environmental Authorisation thatcontinues to be required for the implementation of the Project;




(iv) any material non-compliance by it or (in relation to the Project) the Head Engineering,Procurement, Construction (EPC) Contractor with the Environmental and Social Requirements;

(v) any native title claims or sacred site applications made by any person other than Roy Hill withrespect to sites or areas in respect of the Project, the Project Site or the Project Assets;

(vi) any material Environmental and Social Incident.

(d) Roy Hill must provide the Intercreditor Agent with a copy of any material amendment to anyEnvironmental Authorisation issued to it and a copy of any new Environmental Authorisation issued toit.

(e) Roy Hill will indemnify each Senior Finance Party against any cost, loss or liability incurred by that SeniorFinance Party as a result of any breach of any Environmental and Social Law by Roy Hill in relation to theProject unless it is caused by that Senior Finance Party's wilful misconduct.

(f) Roy Hill must, if it elects to prepare a Remedial Action Plan to rectify a material Environmental and SocialIncident:

(i) notify the Intercreditor Agent of such election and provide such Remedial Action Plan to theIntercreditor Agent as soon as reasonably practicable;

(ii) consult with the Intercreditor Agent and the Senior Lenders’ Technical Advisor (SLTA) in relationto the appropriate steps to be included in a finalised Remedial Action Plan and incorporate anyreasonable requests from the Intercreditor Agent or the SLTA into the Remedial Action Plan;

(iii) implement the Remedial Action Plan as soon as reasonably practicable in the circumstances, andcomply with it in all material respects, whether or not the Remedial Action Plan has beenapproved by the Intercreditor Agent at that stage;

(iv) provide the Intercreditor Agent with periodic updates (no less than monthly) in relation to theprogress made in implementing and completing the actions in the relevant Remedial Action Plan;and

(v) as soon as reasonably practicable following a request from the Intercreditor Agent, provide anapproximate estimate of the costs associated with implementing the measures referred to in theRemedial Action Plan, and thereafter provide notice of any material deviations from suchestimates.

(g) Any Remedial Action Plan submitted under paragraph (f) above will be subject to the approval of theIntercreditor Agent (acting in consultation with the SLTA), unless the relevant Governmental Agency isrequired to assess and approve such Remedial Action Plan and the relevant Government Agencyundertakes such assessment and provide such approval, in which case no separate approval of theIntercreditor Agent shall be required.

(h) If, within thirty (30) Business Days of receipt of the draft Remedial Action Plan pursuant to paragraph(f)(i), the Intercreditor Agent has not approved the draft Remedial Action Plan (with assistance from theSLTA), the Intercreditor Agent and the Borrower will continue to consult in good faith on the appropriatesteps to be included in the Remedial Action Plan.

(i) Roy Hill may only make material amendments to the Environmental and Social Management Plan withthe consent of the Intercreditor Agent, save that no consent of the Intercreditor Agent is required forany amendments that (i) are necessary to reflect changes to the scope of the Project Facilities or Projectactivities or changes in milestones with respect to the implementation of the Project or (ii) are necessary




or desirable to comply with applicable Environmental and Social Laws and applicable Environmental andSocial Standards, provided that the Intercreditor Agent is notified in relation to such amendments in (i)and (ii) above.

Notwithstanding the submission of the Remedial Action Plan to the Intercreditor Agent and the SLTA fortheir review, the Borrower shall bear sole responsibility for the finalised Remedial Action Plan.




4 Environmental and Social LawsIFC Performance Standards and EP Requirements Guide


EP3.0 (EP3.1) – Environmental and Social Assessment

EP3 (3.2) – Environmental and Social Standards

EP10 (10.2) – Reporting and transparency

Environmental laws are broadly defined as any applicable law or regulation of Western Australia orAustralia with respect to the development, construction and operation of the Project within the Project Siteand the carrying out of dredging activities at Port Hedland, and which relate to:

the pollution or protection of the environment;

any emission or substance capable of causing harm to any living organism or the environment; and

the emission of greenhouse gases.

Social laws are broadly defined as any applicable law or regulation of Western Australia or Australia thatapply to the construction and operation of the Project and which relate to:

occupational health and safety

conditions of labour, employment and work

human health, safety and security

indigenous relations and heritage

land acquisition

4.1 Legal and other obligationsRoy Hill is committed to compliance with environmental and social laws and other requirements that applyto the Project. These requirements include, but are not limited to:

federal and state legislation and regulations;

conditions of approvals, licenses and permits;

terms of agreements or contracts with public authorities, private persons or organisations;

industry codes of practice; and

relevant non-regulatory guidelines.

4.1.1 InternationalA number of international agreements apply to the Project including:

Japan-Australia Migratory Bird Agreement (1974);

China-Australia Migratory Bird Agreement (1986);

Republic of Korea-Australia Migratory Bird Agreement (2007);

Convention on the Conservation of Migratory Species of Wild Animals (The Bonn Convention) (1979); and

The London Protocol (2006).




4.1.2 Australian Government legislationCommonwealth legislation relevant to the environmental and social aspects of the Project includes:

Aboriginal and Torres Strait Islander Heritage Protection Act, 1984;

Age Discrimination Act 2004;

Air Space Act 2007 and associated Regulations;

Australian Human Rights Commission Act 1986;

Australian Jobs Act 2013;

Civil Aviation Safety Regulations 1998;

Disability Discrimination Act 1992;

Energy Efficiency Opportunities Act and Regulations 2006;

Environment Protection and Biodiversity Conservation Act (EPBC Act), 1999;

Equal Employment Opportunity (Commonwealth Authorities) Act 1987;

Fair Work Act 2009;

Maritime Transport and Offshore Facilities Security Act 2003; and

National Greenhouse and Energy Reporting Act 2007;

Native Title Act 1993;

Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 and Regulations 1995;

Racial Discrimination Act 1975;

Sea Dumping Act 1981;

Sex Discrimination Act 1984; and

Work Health and Safety Act 2011.

Under the EPBC Act, a proposed action that is likely to have a significant impact on a 'Matter of NationalEnvironmental Significance' must be referred to the Commonwealth Department of Environment (DoE) forassessment.

The Fair Work Commission is the national workplace relations tribunal. It is an independent body withpower to carry out a range of functions relating to:

the safety net of minimum wages and employment conditions;

enterprise bargaining;

industrial action;

dispute resolution;

termination of employment; and

other workplace matters (Fair Work Commission, 2013).

Australia is a signatory to various international conventions which prevent abuse of human rights such asforced and child labour.




4.1.3 Western Australian State Government legislationState Legislation relevant to the environmental and social aspects of the Project include:

Aboriginal Heritage Act 1972;

Agriculture and Related Resources Protection Act 1976;

Building Act 2011;

Bush Fires Act 1954;

Conservation and Land Management Act 1984;

Contaminated Sites Act 2003;

Dangerous Goods and Safety Act 2004;

Energy Safety Act 2006;

Environmental Protection Act 1986;

Equal Opportunity Act 1984;

Explosives and Dangerous Goods Act 1961;

Firearms Act 1973;

Health Act 1911;

Heritage of Western Australia Act 1990;

Industrial Relations Act 1979;

Land Administration Act 1997;

Litter Act 1979;

Local Government Act 1995;

Marine and Harbours Act 1981;

Minimum Conditions of Employment Act 1993;

Mining Act 1978;

Mining Rehabilitation Fund Act 2012;

Mines Safety and Inspection Act 1994;

Native Title (State Provisions) Act 1997;

Occupational Safety and Health Act 1984;

Poisons Act 1964;

Pollution of Waters by Oil and Noxious Substances Act 1987;

Port Authorities Act 1999;

Private railways (Level Crossings) Act 1966;

Rail Safety Act 1998;

Rights in Water and Irrigation Act 1914;

Road Traffic Act 1974;

Soil and Land Conservation Act 1945;

The Long Service Leave Act 1958;




Railway (Roy Hill Infrastructure Pty Ltd) Agreement Act 2010

Town Planning and Development Act 1928;

Wildlife Conservation Act 1950; and

Workers' Compensation and Injury Management Act 1981.

4.1.4 Project ApprovalsA large number of Project Approvals have been achieved for the Project. The Project has been subject toassessment and approval under various legislation. Key assessments and approvals have included:

Environmental Impact Assessment and Ministerial approval under Part IV of the Environmental ProtectionAct 1986 (EP Act) (Section 6);

Environmental Impact Assessment on Matters of National Environmental Significance and Ministerialapproval under the EPBC Act 1999 (Section 6)

Construction and operation of a railway under the Rail Safety Act 1998;

Construction and operation of a railway under the Railway (Roy Hill Infrastructure Pty Ltd) Agreement Act2010.

Dumping of dredge spoil in marine waters (Sea Dumping Permit) under Sea Dumping Act 1981;

Construction and operation of prescribed premises (Works Approvals and Operating Licences) under PartV of the EP Act;

Construction and operation of a mine (Mining Proposal) under Mining Act 1978;

Construction and operation of a mine (Project Development Plan) under Mines Safety and InspectionAct 1994;

Construction of water bores, abstraction of groundwater and surface water and disturbance to beds andbanks of a watercourse under the Rights in Water and Irrigation Act 1914;

Construction and Operation of infrastructure (including accommodation facilities, the airport, and railterminal yard) under the Town Planning and Development Act 1928 and Building Act 2011;

Construction of Port facilities (Port Lease and Licence, Construction Licences) under Port AuthoritiesAct 1999;

Disturbance of heritage sites under the Heritage of Western Australia Act 1990; and

Construction and operation of waste and water treatment facilities and food preparation and otherfacilities under the Health Act 1911.

The above regulatory assessments have required detailed studies to be undertaken to identify potentialproject impacts and outline how these impacts will be managed. In addition Roy Hill’s construction andoperational methodologies have been outlined and demonstrated to be consistent with and meet standardindustry practice and regulatory requirements. To support these approval applications a suite ofmanagement plans and procedures have been submitted to regulatory authorities to demonstrate how RoyHill will achieve environmental, health, heritage, quality, social and safety standards and requirements.




4.1.4.1 Compliance with approval requirementsThe Roy Hill Source Document Register contains all approvals granted for the Project. The Roy Hill SourceDocument Register is updated as and when approvals are received.

Roy Hill is registered with State Law Publisher to receive electronic updates when environmental and sociallaws are amended.

All Roy Hill staff have access to the State Law Publisher and Australasian Legal Information Institutewebsites where copies of relevant environmental and social legislation can be obtained.

The following Roy Hill Legal Obligations Registers have been developed to record and monitor compliancewith Project approvals and agreements:

Obligations Register – Project Stakeholders

Obligations Register – Pastoral

Obligations Register – Mining Tenements

Obligations Register – Pilbara Ports Authority

Obligations Register – Environmental

Obligations Register – State Agreement

Obligations Register – Water Licences

Obligations Register – Health and Safety

Obligations Register – Heritage

Obligations Register – Rail Safety Accreditation

Obligations Register – Section 91 Licences

Obligations Register – Native Title Agreements

Obligations Register – Building and Planning

These registers record conditions of project approvals (including ministerial statements, licences, permits,works approvals and tenement conditions). These registers are updated as new approvals are received andare maintained within a compliance data management system that will manage compliance with theserequirements during the life of the project.

Compliance with these registers is a Principal Project Requirement (PPR) and is communicated toContractors via PPR documents.

An approvals matrix has been developed and has and is communicated to all contractors in the Roy HillLegal Requirements, Commitments and Agreements PPR document which outlines contractor’sresponsibilities to obtain project approvals relevant to their Scope of Work.




5 Social ContextIFC Performance Standards and EP Requirements Guide


IFC5 – Land acquisition and involuntary resettlement

IFC7 (IFC7.1) – Identification of Indigenous People.

5.1 Social area of influenceThe Project is located within the Shire of East Pilbara and Town of Port Hedland.

The Shire of East Pilbara is the largest Shire in the Southern Hemisphere comprising an area of 371,696 km2.The Shire is sparsely populated with approximately 10,500 people residing within the Shire on a permanentbasis.3 The main town sites within the Shire are Newman, Marble Bar and Nullagine. These are also thenearest population centres to the Project and are between 60 and 100 km from the project site.

The Town of Port Hedland encompasses an area of nearly 12,000 km2, and is located approximately1600 km north of Perth in Western Australia. Approximately 15,000 people reside on a permanent basiswithin the Town of Port Hedland.4 The two main residential centres are Port Hedland and South Hedland.

The Port of Port Hedland serves the mineral rich Eastern Pilbara region in Western Australia, with its mainexport commodity being iron ore. The Port also exports salt, manganese, chromite, copper concentratesand livestock. It is Australia's largest port by annual throughput and was the first Port to exceed the 100million tonne (Mt) ceiling in 2004–05. The port recorded 110.6 Mt in 2005–06 and 372.3 Mt in 2013-14,making it the largest bulk minerals export port in the world (PHPA 2011).

5.2 Land tenureWestern Australian legislation allows for different types of land tenure to overlap and co-exist. Thisincludes tenure issued under the Mining Act 1978, Land Administration Act 1997, Port Authorities Act 1999and various State Agreements and Pastoral Leases.

The Roy Hill mine project is located within Mining Leases 46/518 and 46/519 issued under the Mining Act1978. These mining leases are held by RHIO and overlie the Roy Hill pastoral station and lease held by RoyHill Station Pty Ltd.

The rail project is located within Special Rail Licence L4SA, issued under the Mining Act 1978 and inaccordance with the Railway (Roy Hill Infrastructure Pty Ltd) Agreement Act 2010. The rail corridor passesthrough the following pastoral stations:

Roy Hill Station;

Bonney Downs Station;

Hillside Station;

Mulga Downs Station;

Kangan Station;

Wallareenya Station;

Indee Station; and

3 http://www.eastpilbara.wa.gov.au/4 http://www.porthedland.wa.gov.au/town/statistics.html




Boodarie Station.

The Roy Hill port project is located within the Port Lease and Licence issued under the Port Authorities Act1999 and agreed between RHI and Pilbara Ports Authority (PPA) (previously Port Hedland Port Authority).The Port project overlies Boodarie Pastoral Station and lease held by BHP Billiton Pty Ltd.

Various other temporary tenures have been granted to Roy Hill to allow for road construction, laydownareas, borrow pits and other supporting infrastructure associated with the mine, port and rail projects.

No re-settlement of any persons or communities has taken place or will take place in the future as part ofthe Project. Where the project overlies existing pastoral leases, land access agreements have beenexecuted and provide for the payment of compensation. Native Title Agreements have been entered intowith three Native Title Claimant Groups: the Kariyarra, Palyku and Nyiyaparli Peoples. The Agreementsinclude commitments, compensation and royalties payable to each of the three Traditional ClaimantGroups. No physical or economic displacement of people or communities has resulted from the Roy Hillacquisition of its mining, rail or port tenure and nor will any result from the construction and operation ofthe Project.

5.3 MiningExploration and mining titles (tenements) in Western Australia are granted in accordance with the MiningAct 1978. The Department of Mines and Petroleum (DMP) administers this Act.

Mineral exploration and mining activities are administered under the Mining Act 1978 for onshore areas,and for offshore areas to a limit of (nominally) three nautical miles from the coast. There are a number oftypes of tenements, including prospecting licences, exploration, retention and miscellaneous licences, andmining and general purpose leases.

The Pilbara is the leading mining sector region in Western Australia, producing over 20% of the world’s ironore requirements.

Exploration and mining and associated tenure has been secured over a large percentage of the Pilbararegion.

Mineral exploration has and continues to occur along the mineralized portions of the Chichester Range.Demand for iron ore is expected to continue to grow as a result of demand from South-East Asia and China.To cater for this demand the mining industry has been expanding mine capacities, opening new mines andupgrading existing regional infrastructure, with new port and rail facilities currently under development(Department of State Development, 2010).

No previous mining activity has occurred within the Project area, however mineral exploration by RHIO andits corporate predecessors has been underway since 1993.

5.4 Pastoral activitiesThe Pilbara contributes only a small part of the overall agricultural production in Western Australia.Regional conditions are generally unfavourable for crop production and therefore low density pastoralactivities, mainly beef production account for the majority of agricultural output. Pastoral leases now coverabout one third of the Pilbara and co-exist with mining activities and conservation areas.




5.5 TourismThe Pilbara Region offers a diverse range of parks, reserves and recreational areas. Karijini National Parkprovides for a range of recreational pursuits and is perhaps the region’s greatest natural attraction. KarijiniNational Park (Figure 5-1) is centred in the Hamersley Ranges of the Pilbara and situated approximately100 km west of the mine area, covering an area of some 6,274 km2 it is the second largest National Park inWestern Australia.

The Fortescue Marsh (Figure 5-1) is not currently vested as a conservation reserve. The Department ofParks and Wildlife intends to obtain reserve status over portions of the Fortescue Marsh at the expirationof pastoral leases in July 2015. This may increase tourist interest in the area.

5.6 Indigenous peopleThe Project has established Native Title Agreements with three Claimant Groups:

Kariyarra (WAG 6287/98)

Nyiyaparli (WAD 6280/98); and

Palyku (WAG6168/98).

The Native Title process and the content of the Native Title Agreements is outlined in Section 6.2.3.

5.7 Workforce profileThe construction workforce is expected to comprise approximately 8,000 people (of differing trades andskills) in total during the life of construction with a peak workforce of approximately 3,700 personnel at anyone time. Steady state operations will comprise a workforce of approximately 2,000 personnel. Roy Hillhas a preference to provide employment to Australian based personnel through its selection of staff andcontractors.

The nearest population centres are Marble Bar, Nullagine and Newman, all of which are in excess of 60 kmfrom the mine site. Given the distance of these towns from the mine the workforce will be fly in, fly out(FIFO) based on a range of rosters, including an eight days on /six days off and 14 day on/10 day off/14 dayon/11 day off roster during Roy Hill operations. During construction of the project standard constructionrosters will apply. Employees will be accommodated on-site for the duration of their FIFO roster at the RoyHill Accommodation Village.

The workforce at Port Hedland will be a mixture of FIFO personnel and Port Hedland based employees andtheir families.




Figure 5-1: Location of towns, indigenous communities and tourist sites in proximity to the project.




6 Environmental and Social Impact Assessment and StandardsIFC Performance Standards and EP Requirements Guide

This section specifically addresses the specific requirements of:

EP2 (EP2.1, 2.2, 2.3) – Environmental and social assessment

EP3 (EP3.1) – Environmental and social standards

EP4 (EP4.2) –Environmental and Social Management System and Equator Principles Management Plan

EP5 (EP5.1, 5.2, 5.3, 5.4) - Stakeholder engagement

EP7 (EP7.1, 7.2) – Independent review

EP10 (10.1) – Reporting and transparency

IFC1(IFC1.1, 1.3) – Assessment and Management of Environmental and Social Risks and Impacts

IFC3 (IFC3.1, 3.2, 3.3, 3.4, 3.5) – Resource efficiency and pollution prevention

IFC4(IFC4.1) – Community, Health, Safety and Security

IFC 5 (IFC 5.1, 5.2, 5.3) – Land acquisition and involuntary resettlement

IFC6 (IFC6.1, 6.2, 6.3, 6.4, 6.5) – Biodiversity Conservation and Sustainable Management of LivingNatural Resources

IFC8 (IFC8.1, 8.2, 8.3, 8.4 and 8.6) – Cultural heritage

EHSG3 (EHSG3.1, 3.2) Community Health and Safety

EHSG4 (EHSG1.3) Construction and Decommissioning

6.1 Environmental Impact Assessment processes6.1.1 Overview of Western Australian Environmental Impact Assessment ProcessIn Western Australia, the Environmental Protection Authority (EPA) is an independent advisory bodyestablished under the Environmental Protection Act 1986 (EP Act). The legislative process for assessmentand approval of significant proposals (projects) includes an independent review and Environmental ImpactAssessment (EIA) of proposals with the potential to have significant environmental effect if implemented.

The EPA makes recommendations to the Western Australian Minister for Environment on whether aproposal should be implemented and the conditions and procedures considered necessary to ensure theenvironmental and social impacts are acceptable within a set of environmental and social objectives(Appendix 1).

The EIA process is risk-based, and the EPA identifies the key environmental and social factors relating to aproposal that the proponent must quantify. The proponent is required to outline how potential impactswill be mitigated and managed to meet the EPAs objectives. Detailed studies and risk assessments arerequired to be undertaken by independent experts as part of the EIA process and must identify potentialenvironmental and social impacts relating to proposals.

The EPA draws upon the expertise of a number of government departments, including specialistenvironmental organisations, in its assessment of a proposal in order to reach its conclusions and makerecommendations to the Minister for Environment. The EPA requires proponents to undertake appropriateconsultation with the community and stakeholders before an assessment is made. Full details of thecurrent assessment process are described in the Environmental Impact Assessment AdministrativeProcedures 2012, available on the EPA website (EPA 2012).




Opportunities are provided through the EIA process for submissions and comment from other regulatorybodies and the public. The EPA report and recommendations is advertised and any person that disagreeswith the content of, or recommendations within, the report can lodge an appeal with the Minister forEnvironment. Any appeals lodged are investigated by an Appeals Convenor who reports to the Minister inan appeal report that is made public. The Minister for Environment determines the outcome of theappeals.

The Minister for Environment then makes a final determination on whether or not a proposal can beimplemented, and the conditions and procedures that should be applied to its implementation followingconsultation and agreement with relevant decision-making authorities.

Such environmental authorisations include conditions that have statutory force and must be complied with.The conditions require that the proposal be implemented as described in the environmental reviewdocument and relevant supporting management plans. In this manner, commitments made by theproponent throughout the assessment process also must be implemented.

6.1.2 Environmental Assessment of the Roy Hill ProjectRoy Hill referred the Port, Mine (Stage 1 and Stage 2) and Rail projects to the EPA for assessment inNovember 2010, June 2009, October 2009 and July 2010 respectively. The EPA submitted its Report andRecommendations to the Minister for Environment and approval was granted for the Port, Mine and Railprojects in March 2010, December 2009, March 2010 and November 2010 respectively under MinisterialStatements (MS) 824 and 829 for the mine, MS 847 for the rail and MS 858 for the Port. Roy Hill isresponsible for ensuring implementation of the mine, port and rail projects in accordance with MSconditions.

Dredging works required for the construction of the Roy Hill shipping berths were conducted as a part ofthe South West Creek Dredging and Reclamation Project (SWC Project) approved by the Minister forEnvironment under MS 859 on 15 March 2011. PPA is the proponent for the SWC Project and is thereforeresponsible for ensuring implementation of the Project in accordance with MS 859 conditions. Roy Hillconducted the dredging works on behalf of PPA in accordance with the requirements of MS 859 and otherrelevant approvals. The dredging works were completed in May 2013, future maintenance dredging will berequired to be undertaken by Roy Hill during the life of the project.

The EPA objective for each relevant environmental and social factor managed under this ESMP is providedin Appendix 1. The environmental authorisations of the referrals are discussed in Section 6.2.4 andprovided in Appendix 2.

Roy Hill is required to report its compliance to the EPA on an annual basis to demonstrate compliance withapproval conditions.

The following EIA documentation is accessible and available on-line at the EPA website[http://www.epa.wa.gov.au]:

Environmental Review documentation (Port, Mine, Rail);

EPA assessment reports (EPA Reports 1342, 1345, 1370, 1377, 1439); and

Ministerial Statements (824, 829, 847, 858, 902).

A schematic illustrating the environmental impact assessment and management relating to theconstruction and operation phases of the Project is provided in Figure 6-1.

6.1.3 Overview of Australian Government Environmental Assessment processWhile the states and territories have responsibility for environmental matters at a state and local level, theEnvironmental Protection and Biodiversity Conservation Act 1999 (EPBC Act) is the key AustralianGovernment Environmental Law for protecting Matters of National Environmental Significance (MNES).




The EPBC Act requires an assessment as to whether a proposed action is likely to have a significant effecton a MNES.

The most relevant MNES is that which aims to protect threatened species and ecological communities. TheEPBC Act lists flora and fauna species that are either extinct, extinct in the wild, critically endangered,endangered, vulnerable, or conservation dependent. Ecological communities are listed that are criticallyendangered, endangered or vulnerable. An assessment requires determining the presence (eitherconfirmed or likely) of listed threatened species and communities in the Project area and the likelihood ofsignificant impacts that may be posed by the proposed action.

If the Minister determines that a proposal may have a significant impact on MNES it will be determined a“controlled action” and subject to assessment by DoE. There are multiple levels of assessment under theEPBC Act depending on the degree of impact and each step in the assessment is available on the DoEwebsite [http://www.environment.gov.au/].

All components of the Project (Port, Mine and Rail) were referred under the provisions of the EPBC Act(refer to Appendix 2). The DoE (formerly Department of Sustainability, Environment, Water, Populationand Communities (DSEWPaC)) determined that the mine and port are not controlled actions and did notrequire assessment under the EPBC Act. The railway was determined to be a controlled action as it has thepotential to impact on MNES and was assessed under the EPBC Act. The impact assessmentdocumentation and Ministerial Approval (2010/5424 and 2010/5867) are accessible and available on-line atthe DoE website [http://www.environment.gov.au/].




Figure 6-1: Environmental impact assessment and management of construction and operation phases of the Project




6.2 Social Impact Assessment process6.2.1 Overview of Social Impact Assessment processThe potential social impacts of the Project were assessed through the following processes:

EIA conducted by the EPA (refer Section 6.1) and approval granted by the Western Australian Minister forEnvironment under MS 824, 829, 847, 858 and 859;

Submission of detailed proposals required under clauses 7, 8, 9 and 10 of the Railway (Roy HillInfrastructure Pty Ltd) Agreement Act 2010 (State Agreement Act) outlining matters including to:

o Community Development;

o Accommodation, water and energy supply;

o Local Labour, services and suppliers;

o Local Content, local business, indigenous companies;

o Engagement and Training of employees, induction and training;

o Project regulatory approvals;

o Native Title;

o Health and Safety and Emergency procedures; and

o Community and public safety.

Assessment and approval of impacts to cultural heritage sites under Section 18 of the Aboriginal HeritageAct 1972;

Assessment and approval of a Project Development Plan by the DMP that outlines how the port and mineprojects will be constructed and operated to comply with the Mine Safety and Inspection Act 1994; and

Assessment and approval of Rail Accreditation Plans by the Office of Rail Safety that outlines how the railproject will be constructed and operated to comply with the Rail Safety Act 2010.

In addition the social impacts of the Project are managed in accordance with various legislation outlined insection 4.1.

A schematic illustrating the social impact assessment and management relating to the Project is provided inFigure 6-2.




Figure 6-2: Social impact assessment and management

6.2.2 State Agreement Act processState Agreements are contracts between the Government of Western Australia and proponents of majorresources projects developed in liaison with relevant Government agencies that are ratified by a projectspecific Act of the State Parliament. They specify the rights, obligations, terms and conditions fordevelopment of the project and establish a framework for ongoing relations and cooperation between theState and the project proponent.

State Agreements are used by the Western Australian Government to approve the construction of majordevelopments, related downstream processing projects and associated infrastructure investments. Majorresource projects require long term certainty, extensive or complex land tenure and are often located inremote areas of the State requiring significant infrastructure development.

The Rail component of the Roy Hill Project is subject to the State Agreement Act. The State Agreement Actrequired Roy Hill to prepare Community Development Plans that outline:

training and guaranteed employment for indigenous and non-indigenous persons living in the Pilbararegion;

regional development and local procurement of goods and services;

contribution to community services and facilities; and

a regionally based workforce.

Community Development Plans for the Town of Port Hedland and the Shire of East Pilbara relating to theconstruction and operation of the Project were prepared and approved by the Minister for StateDevelopment.




6.2.3 Native titleNative title is the recognition by Australian law that Aboriginal and Torres Strait Islander people have rightsand interests to land if they can establish that they have maintained a connection with their countrysubstantially uninterrupted from the time British asserted sovereignty over the area to the present day.

Aboriginal and Torres Strait Islander people can apply to have their native title rights recognised under theNative Title Act 2007 (NT Act) by lodging an application for a determination of native title (a claimantapplication) in the Federal Court. These applications are assessed by the Native Title Register and providedthey meet the requirements set out in the NT Act the claim is registered on the Register of Native TitleClaims. The registration of a claim gives the Native Title Claimant/s certain rights and interests includingrights to:

live on the area;

access the area for traditional purposes;

visit and protect important places and sites;

hunt, fish and gather food or traditional resources;

teach law and custom on country; and

negotiate on the use of the land.

The right to negotiate on the use of the land is not a right to stop or veto future development or projectsgoing ahead, it is a right to be consulted on how the project is implemented. The most practical way forproject developers to recognise native title rights is to enter into an Agreement with the Native TitleClaimant Group. Roy Hill has Native Title Agreements with three traditional claimant groups; the Kariyarra;Palyku and Nyiyaparli People. Under the Agreements Roy Hill consults regularly with the traditionalclaimants regarding current and proposed operations. The relevant sections of the Agreements thatdescribe the consultation processes include:

Native Title Agreement between Roy Hill Infrastructure Pty Ltd and Kariyarra People

o Part D: Consents. Clause 11: relates to Native Title Approvals including future tenure and ancillarytenure.; and

o Part E: Cultural Heritage. Clause 12-22: relates to Heritage Approvals and Heritage survey process.

Native Title Agreement between Roy Hill Infrastructure Pty Ltd and Palyku People.

o Part D: Consents. Clause 10: relates to Native Title Approvals including future tenure and ancillarytenure; and

o Part E: Cultural Heritage. Clause 11-21: relates to Heritage Approvals and Heritage survey process.

Roy Hill Project Agreement between Roy Hill Iron Ore Pty Ltd and Nyiyaparli People

o Part B: Consent and Compensation under Project Agreements. Clause 7 relates to Native TitleApprovals including future tenure and ancillary tenure; and

o Part C: Cultural Heritage. Clause 9-15 relates to Heritage Approvals and Heritage survey process.




6.2.4 Material environmental and social permitsThe key government agencies responsible for assessing the environmental and social impacts of the Projectand granting approval for implementation of the project include the EPA, DoE (formerly DSEWPaC),Department of Aboriginal Affairs (DAA) (formerly the Department of Indigenous Affairs),the Native TitleTribunal, the Department of Mines and Petroleum (DMP) and the Department of State Development (DSD).

Material Authorisations (key State and Commonwealth approvals) secured to date for the Project areoutlined in Appendix 2.

The management of aspects and impacts relevant to the Project are outlined in Section 8.

6.3 Stakeholder consultation during assessmentA comprehensive Stakeholder and Community Consultation Strategy was developed and a StakeholderConsultation Program implemented in parallel with the formal EIA and SIA processes outlined in Section 6.

Roy Hill consulted with indigenous groups, landholders, mining companies, pastoral lease holders,government agencies, local government authorities, PHPA, non-government agencies and communitygroups. Consultation undertaken for the Project and Roy Hill’s response to the issues raised is outlined inthe Project’s Environmental Review documentation, which is available on the EPA website.

The objective of the Stakeholder and Community Consultation Strategy was to establish open andtransparent consultation and communication to build relationships with stakeholders, gather informationto guide future decisions, resolve issues at an early stage and ensure that stakeholder feedback wasconsidered during Project design and construction. The consultation program included:

meetings with government and non-government agencies to discuss and identify potential Projectimpacts and management measures required;

written invitation to stakeholders to comment on the proposed Project and provision of informationthrough brochures and a dedicated website; and

consultation with indigenous groups and landholders to reach agreement and identify and resolveimmediate and ongoing issues.

The Stakeholder Consultation Strategy is an ongoing component of the Project Environmental and SocialManagement Framework (refer to section 8.1 and Figure 8-1). Regular consultation with stakeholders willcontinue into the future to ensure that issues and concerns are addressed and to develop long term,mutually beneficial relationships in relation to indigenous and community employment, management ofcumulative local and regional impacts, community participation and project decommissioning and closure.

The Stakeholder and Community Consultation Plan (000RH-0000-EN-PLN-0003) has been developeddocument how the Strategy will be implemented during project operations.




6.4 Environmental and Social StandardsThe Roy Hill Environmental and Social Framework is aligned to the International Standards Organisation(ISO) Standard 14001:2004 Environmental Management System. The components of ISO14001:2004 andhow these will be implemented during the life of the Project is outlined in Section 8.

The Project will be assessed against a number of Environmental and Social Standards as a part of theproject financing process, including:

international conventions relating to the Environment to which Australia is a signatory and which havebeen ratified into Law in Australia (section 4.1);

Equator Principles (June 2013)

the IFC Performance Standards (January 2012);

the IFC Environmental, Health and Safety Guidelines (April 2007) including without limitation the GeneralEHS guidelines and all applicable Industry Sector Guidelines

the Japan Bank for International Cooperation (JBIC) Environmental and Social Guidelines;

the Nippon Export and Investment Insurance (NEXI) Environmental and Social Guidelines;

the Export Import Bank of the United States (US-EXIM) Environmental and Social Due DiligenceProcedures and Guidelines (June 2013);

the OECD Recommendations on Common Approaches on Environment and Officially Supported Credits(2012); and

This section recognises these standards and outlines how the Australian Environmental and SocialFramework and the Roy Hill project Environmental and Social Management Framework meet therequirements of these standards.

6.4.1 Equator PrinciplesThe Equator Principles (EP) are a risk management framework adopted by financial institutions, fordetermining, assessing and managing environmental and social risk in projects and are primarily intendedto provide a minimum standard for due diligence to support responsible risk-decision-making (EquatorPrinciple Association 2011).

Equator Principle Financial Institutions (EPFIs) commit to implementing the EP’s in their internalenvironmental and social policies, procedures and standards for financing projects and will not provideProject Finance or Project-Related Corporate Loans to projects where the client will not, or is unable tocomply with EPs (Equator Principle Association 2011).

Appendix 3 outlines the objectives and specific requirements relevant to each EP and details how theProject will achieve compliance with these requirements.

6.4.2 IFC Performance StandardsThe IFC is the largest global development institution focussed on private sector in developing countries(International Finance Corporation 2012). The IFCs Sustainability Framework articulates the Corporation’sstrategic commitment to sustainable development, and is an integral part of IFCs approach to riskmanagement (International Finance Corporation 2012). The Sustainability Framework comprises IFC'sPolicy and Performance Standards on Environmental and Social Sustainability (International FinanceCorporation 2012). The Performance Standards provide guidance on how to identify risks and impacts, andare designed to help avoid, mitigate, and manage risks and impacts as a way of doing business in asustainable way, including stakeholder engagement and disclosure obligations of the client in relation toproject-level activities (International Finance Corporation 2012).




In order to enable an investment to be made with the IFC, Roy Hill is required to meet the eight IFCPerformance Standards.

Appendix 4 outlines the objectives and specific requirements relevant to each IFC Performance Standardand details how the Project will achieve compliance with these requirements.

6.4.3 IFC Environmental, Health, and Safety General GuidelinesThe IFC Environmental, Health, and Safety General Guidelines is a technical reference documents providinggeneral and industry-specific examples of Good International Industry Practice. These Environmental,Health, and Safety General Guidelines are applied when one or more members of the World Bank Groupare involved in a project, as required by their respective policies and standards. The Environmental, Health,and Safety General Guidelines contain the performance levels and measures that are generally consideredto be achievable in new facilities by existing technology at reasonable costs (International FinanceCorporation 2007).

Appendix 5 outlines the objectives and specific requirements relevant to the IFC Environmental, Health,and Safety General Guidelines and details how the Project will achieve compliance with these requirements

6.4.4 JBIC Environmental and Social GuidelinesJBIC is a policy based financial institution of Japan which promotes overseas development and securing ofresources which are important for Japan and the promotion of overseas business with the purpose ofpreserving the global environment.

When considering projects for lending, the JBIC applies the Guidelines for Confirmation of Environmentaland Social Considerations. The Guidelines are aimed at contributing to the social and economically sounddevelopment of the international community through consideration of environmental and social aspects ofall projects (JBIC 2012).

6.4.5 NEXI Environmental and Social GuidelinesNEXI is the official export credit agency of Japan. When considering a project application, NEXI assesses theenvironmental and social aspects of the project against the Guidelines on Environmental and SocialConsiderations in Trade Insurance (NEXI Guidelines). The NEXI Guidelines include procedures to screenprojects and categorise projects based on predicted impact on the environment. Category A and B projectsare subject to environmental review (NEXI 2013). Environmental reviews are assessed against a projectsector specific environmental checklist.

6.4.6 US-EXIM Environmental and Social Due Diligence ProceduresThe US-EXIM is the official export credit agency of the United States.

When considering a project for finance, US-EXIM takes into account the potential beneficial and adverseenvironmental effects. US-EXIM recently reviewed its Environmental Procedures and Guidelines to bringthe guidelines into full compliance with the most recent OECD ‘Common Approaches for OfficiallySupported Export Credits and Environmental and Social Due Diligence,’ in addition to the Equator Principles(US-EXIM 2013).




6.4.7 OECD Recommendations on Common Approaches on Environment and OfficiallySupported Credits

The OECD’s mission is to promote policies that will improve the economic and social wellbeing of peoplearound the world. To enable this, the OECD has developed the ‘Revised Council Recommendation onCommon Approaches on the Environment and Officially Supported Export Credits,’ (the Recommendation)This Recommendation aims to promote coherence amongst OECD member policies regarding exportcredits, environmental, climate change, social and human rights policies and commitments underinternational agreements and conventions, in order to contribute towards sustainable development. TheRecommendation also develops common procedures and processes for environmental and social reviewand good practice and consistent review and assessment processes for projects which benefit from expertcredit (OECD 2012).

An overview of how the JBIC, NEXI, US-EXIM and OECD Guidelines align with the Equator Principles and IFCPerformance Standards and what section of this plan addresses these standards is detailed in Appendix 6,Appendix 7, Appendix 8 and Appendix 9 respectively.




7 Business Management FrameworkIFC Performance Standards and EP Requirements Guide

This section specifically addresses the specific requirements of:

IFC1(IFC1.5) – Assessment and Management of Environmental and Social Risks and Impacts

IFC6 (IFC6.5) - Biodiversity Conservation and Sustainable Management of Living Natural Resources

EHSG2 (EHSG2.1) Occupational Health and Safety

Roy Hill's Business Management Framework comprises a series of interrelated management systems,procedures and plans to ensure the Project is delivered in accordance with Project requirements and isoperated to achieve the export of 55 Mtpa of iron ore.

The Roy Hill Project Development Plan sets out the key parameters for the construction and thedevelopment of the Project, such as the Project’s works completion schedule and construction budget.

The Project is being developed and operated on the basis that sustainability initiatives are sound businessdecisions that reduce project and operational costs. Sustainability starts with the design of the Project andremains a benefit to the workforce, the stakeholders and the business operations. Key project objectivesare critical to ensuring ongoing project sustainability.

Project objectives to be delivered during project execution are outlined in Table 7-1.

Table 7-1: Project Objectives

Objective Description

Safety and Employee Relations Roy Hill is committed to implementing a safe system of work commensurate withachieving acceptable safety performance.

Budget

Award contracts and deliver the Project within budget, by implementing rigorous changemanagement systems to negate unsupportable growth and/or changes and claims arisingfrom otherwise "controllable" issues. Take a 'whole-of-business' approach to optionanalysis, taking into consideration operating cost, operability, maintainability, safety,heritage and the environmental.

ScheduleAchieve defined commissioning and ramp-up milestones, by implementing strategies totarget schedule goals, without compromising safety, environmental, quality andstakeholder requirements.

Performance and QualityAchieve nameplate capacity across all equipment and the total project system, with zerorework, by delivering facilities that meet specified performance, quality and regulatorystandards and targets. Use standardisation where applicable and implement leading edgetechnologies for automated operation of project systems.

CommunityActively promote and participate in open communication and consultation, with all Projectparticipants, being sensitive to the potential impact of the Project and workforcebehaviours on the community. Seek community endorsement that the Project is a positiveinfluence on their lives with tangible community benefits.

EnvironmentAchieve compliance with environmental requirements and commitments, implementcontrol plans and seek community and stakeholder endorsement of the Project in regardto the environment.

7.1 Vision and ValuesRoy Hill’s Business Framework provides the systems and structure to achieve the strategic businessobjectives which focus on five key areas:

Licence to operate

Operational effectiveness

Processes and systems

Project delivery




Roy Hill community

Roy Hill has a vision to be a high performing iron ore business where people contribute and realise their fullpotential. Roy Hill is committed to:

Streamline processes to drive high performance.

Work with people who are best in their field.

Build a culture of commitment and contribution.

Develop a ‘thinking organisation’ to continue our legacy.

Be an organisation which delivers what it says it will deliver.

The Governance Policy (Appendix 10) identifies key corporate principles to achieve this vision whilstdelivering sustained, low cost production of ire ore which is consistent in quality and grade

Figure 7-1 depicts Roy Hill’s Business Framework.

Figure 7-1 – Roy Hill’s Business Framework




Roy Hill has established four core values to assist in defining how the company and employees approachthe work of Roy Hill. These core values underpin the behaviours that employees and business are expectedto demonstrate when undertaking work and are focused in four areas:

Lead

o To passionately commit to achieving Roy Hills objectives.

o To take accountability for our actions.

Care

o To care for the health, safety and assets of the Roy Hill community.

o To collaborate within and across teams.

o To respect individual differences by being open and fair.

Think

o To combine cross-industry methods, technology and judgment to create innovative prudentsolutions.

o To value learning and share knowledge with each other.

Perform

o To manage risk and produce sustainable value.

o To use our capabilities and agility to overcome challenges and achieve great outcomes.

7.2 Project Management and Controls7.2.1 Project ProceduresThe Project has project-specific management control plans, based on proven systems. The managementcontrol plans have supporting procedures and workflows that define how Project actions will beundertaken and who has responsibility and accountability for key tasks and activities.

Management control plans have been developed for each core function area. Their correspondingprocedures are supported by standard forms and templates.

Contractors engaged to deliver project construction and operational activities are responsible andaccountable to undertake and deliver their scope of works in accordance with their established and provenprocedures. As part of their scope they will be required to submit a formal Project Management Plan,which is reviewed and approved by the Project Approving Authority (AA).

Environmental and social matters are addressed through implementation of Contractor ProjectManagement Plans.

7.2.2 EngineeringProject engineering is undertaken by contractors in accordance with the Projects functional requirements.Appropriate tollgate reviews including Hazard Identification Study (HAZID), Hazard and Operability Study(HAZOP), design reviews, reliability, operability, maintainability, constructability and commissioning arerequired to be carried out.

Management of environmental and social impacts are considered and is addressed as appropriate throughthese engineering tollgate reviews.




7.2.3 Project ControlsRoy Hill has in place the key systems to deliver the Project including:

a cost management system to manage and report capital costs;

a tool for project scheduling;

manual interface procedures established between cost management system and the corporate financesystem;

a document control system;

environmental and social management systems;

a safety management system; and

contractor project control plan process.

7.2.4 Trend and Change ManagementThe Roy Hill change management procedure ensures all changes are reported in a change register and areassessed in terms of impact on; project cost, schedule, approvals and environmental and social values.Based on published authority limits and where deemed appropriate, a contract change notice procedure isimplemented.

7.2.5 Project ReportingA Project-wide reporting procedure addresses forecast project costs, performance against commitmentsand any other known project issues relevant at the time.

7.2.6 Contracts and ProcurementA systematic approach to award of Contracts and procurement of goods and services is undertaken andincludes an evaluation of technical, environmental, approval and commercial requirements, a reconciliationwith budget and a formal written recommendation for approval to support the contract award orprocurement decision.

7.2.7 Risk ManagementRoy Hill's Risk Management Framework forms the basis of Roy Hill’s approach to risk management acrossthe business, including Project Delivery, Operational Readiness and corporate functions. The frameworkestablishes clear parameters for the monitoring and assurance of risk management activities bycontractors, as well as within the Roy Hill business.

The overall objective of the Risk Management Framework is to instil the appropriate behaviours andprocesses within the business and to drive consistent and effective application of risk management at anenterprise, project and operational level. Specifically, this is achieved by:

Discussing the principles that form the basis of the behaviour expected from all staff and contractors inorder to achieve a risk-aware culture linked to Roy Hill’s business strategy (objectives and goals);

Describing the leadership and governance mechanisms to support this risk-aware culture (responsibilitiesand accountabilities);

Outlining key tools or enablers to be used in the Risk Management Framework (procedures, assessmentcriteria, risk registers and risk management plans); and

Providing guidelines regarding the continuous review and improvement of Roy Hill’s Risk ManagementFramework (review, governance and assurance).




Key Environmental and Social risks have been captured in the Corporate Risk Management Register and riskowners assigned accordingly. It is the responsibility of the designated risk owner to ensure that the riskcontrols and other mitigation measures that have been identified are implemented and that the register isupdated to reflect these controls. All corporate, project delivery and operational risks are captured withina dedicated risk management data base which is accessible to all key personnel.

7.2.8 Safety ControlsRoy Hill has adopted a systematic approach to the management of Health, Safety, Emergency and Security(HSES). Underpinning this approach is the Roy Hill HSES management system that encompasses theelements of a Safe System of Work (SSoW).

The SSoW defines how work is structured so that it may be executed safely. Four core elements make upthe Roy Hill SSoW being:

Planning;

People;

Equipment; and

Response to Change.

7.2.9 Environmental and Social ControlsRoy Hill has implemented an Environmental and Social Management Framework aligned to ISO14001:2004,which includes:

Roy Hill Corporate Policies

Environmental and Social Management Plan (this document);

Environmental and social objectives and targets;

Environmental and social management plans, procedures and guidelines; and

Environmental and social legal obligation registers.

7.2.10 Quality Assurance and ControlQuality assurance plans specify the quality assurance requirements of the project to ensure successfulcompliance with PPRs. Contractors remain responsible for performance of their scope of work or servicesand are audited against their quality assurance plan.

7.3 Project Planning FrameworkA Bankable Feasibility Study was conducted during 2009/2010. A robust study methodology wasimplemented focusing on a structured approach to develop the project. The approach resulted in adetailed and optimized definition of the Project scope. A standardized approach was adopted across theProject for the following activities, driven by an integrated management team, which included the Owner'sTeam and the Engineering Consultant for the following activities:

Development of the Basis of Design;

Pricing of equipment, commodities and labour;

Preparation of capital and operating cost estimates;

Preparation of Project Schedules; and

Logistics and transport pricing.

In addition a number of detailed engineering, transport and technical studies were undertaken comprisingdesign option assessments. The assessment of alternative project options included an analysis of impactsto environmental and social values including costs and benefits.




7.4 Project Construction Framework7.4.1 Project Execution ModelThe Project construction schedule forecasts a first ore on ship date of 30 September 2015 and will require apeak site workforce of approximately 3,700 personnel. Steady state operations will comprise a workforceof approximately 2,000 personnel. The Project will be delivered through an Engineering, Procurement andConstruction (EPC) and Project Management Contractor (PMC) contract delivery model.

7.4.2 Project Construction Organisational StructureThe Project will be constructed predominantly under the EPC and PMC delivery model with early contractorinvolvement in the design, planning and delivery process. Figure 7-2 illustrates the Project ConstructionOrganisational Delivery Structure under the EPC and PMC delivery model.

Figure 7-2: Project Construction Organisational Delivery Structure (PMC / EPC Delivery Model)

7.4.2.1 Roy Hill Owners Project Construction TeamThe organisation model is based upon a single management structure with three major areas under the RoyHill Chief Executive Officer (CEO) – Project, Corporate Services and Operations.

The Projects Team is responsible for delivery of construction of the Project and is managed by a ProjectDirector who reports directly to the CEO.

The Project Director is supported by the Manager Safety & Risk / Registered Mine, Senior Manager ProjectControls, Manager Construction Port, Manager Construction Mine and Rail, Direcor Commissioning, DeputyProject Director, Director Commercial and Project Director Delivery (Figure 7-3).

The General Managers of External Affairs and Human Resources are part of the Corporate Services Teamand report directly to the CEO. The General Manager Health, Safety and Environment (HSE) is part of theOperational Team and reports to the Chief Operating Officer (COO).

The General Managers of External Affairs, HSE and Human Resources provide technical advice and supportto the Project Team during construction.




The General Managers External Affairs, HSE and Human Resources with support from the Managers ofEnvironment, Heritage and Industrial Relations are responsible for ensuring environmental and social legalrequirements and standards are communicated, implemented and complied with throughout all phases ofconstruction.

The Project Director and members of the Project team are responsible for the design, procurement,construction, commissioning and handover (to operations) of the project. This includes ensuring thatenvironment and social project requirements are considered and implemented into these phases of projectconstruction.

The organisational structure of the Owner's Project Team has been amended to suit the Project status asconstruction progresses. The current organisational structure of the Owner’s Project Team is shown inFigure 7-3. The organisational structure for the Operations Teams are shown in Figure 7-5, Figure 7-6 andFigure 7-7.

The PMC has been engaged by Roy Hill to manage Contractor work packages on behalf of the ProjectsTeam in line with a contracting and procurement strategy.

7.4.2.2 Approving Authority and Principal Project RequirementsThe key role of the Approving Authority (AA) is to ensure that construction contractors are delivering inaccordance with the agreed scope, specification, and quality and risk profile. The agreed scope,specification, quality and risk profile are contained in the PPR documentation. Contractors arecontractually required to adhere to PPRs. The contents and structure of the PPRs are shown in

Figure 7-4. The PPR suite of documents includes environmental and social plans, procedures and guidelines.

The AA is made up of experts and specialists from the Roy Hill Owner's Team, the PMC and other externalorganisations as appropriate.

7.4.2.3 PMC ContractorThe PMC has been engaged to manage the EPC Contractor, infrastructure contractors and subcontractors,and procurement contracts throughout the construction phase of the Project.

The PMC has an audit and governance role and is responsible for assuring that all Contractors construct theProject in accordance with PPRs, including those relating to environment and social management.

7.4.2.4 EPC and Infrastructure ContractorsAn EPC Contractor has been engaged for construction of the mine process plant, rail and port facilities.

A number of other infrastructure contractors have been engaged to deliver fixed priced contract packagesfor supporting infrastructure including mine, port and rail construction camps, mine site airstrip, power formine and port operations, water supply bores and workshops, offices and storage facilities.

The EPC and Infrastructure Contractors are required to adhere to all PPR requirements, including thoserelating to environment and social management.




Figure 7-3: Roy Hill Project Team Organisational Structure




Figure 7-4: Principal Project Requirements content and structure




7.5 Operations Management FrameworkRoy Hill will utilise traditional mining methods and equipment to achieve a peak mining rate of 346 Mtpa(dry) of which a peak product of 55 Mtpa will be exported to overseas markets. The remaining materialdeemed not to be ore, will be either disposed to the tailings storage facility, used to backfill mine pit voidsor be disposed to permanent waste rock dumps.

The ore product rate is not expected to peak until the fourth year. Operational mining phases are shown inTable 7-2 below.

Table 7-2: Operational Mining Phases

Timeframe Operational Mining Phase

April 2014 Mining Contractor commences clear and grub activities for initial mining areas

July 2014 Mining Contractor commences drill and blast activities

April 2014 Mining Contractor and owner fleet commence mining activities (including stockpiling ofore)

July – September 2015 Commissioning of process plant

September 2015 – March 2018 Process plant ramp-up

Mining activities for the entire Life of Mine will be conducted by the owner Roy Hill. In conjunction withowner operator mining activities, a mining contractor will be engaged during the first four years of mine lifeto undertake initial pre-strip and ore stockpiling. This will enable ramp up of the owner mining fleet andrecruitment of owner mining operating workforce.

Prior to mining, clearing of vegetation, topsoil and subsoil will be undertaken. Initially, this material will bestored nearby in stockpiles ready for use at a later date during mine pit backfilling and rehabilitation. Oncesufficient pit areas have been backfilled and shaped, all newly stripped material will be taken direct tothese completed areas and re-spread as part of the progressive rehabilitation process.

7.5.1 Principal's Project Requirements (PPR)PPRs will define Roy Hill requirements for Project Operations. All operational contractors will becontractually obligated to adhere to PPRs. The contents and structure of the PPRs are shown in

Figure 7-4. The PPR suite of documents includes environmental and social plans, procedures and guidelines.

7.5.2 Operational PlansA suite of Operational Plans and procedures have been developed and will inform the Roy Hill Owner’sTeam of project operational management requirements including environment and social management.

7.5.3 Operations Management StructureThe organisation model is based upon a single management structure with three major areas under theCEO – Project, Corporate Services and Operations Teams.

The management structure for Operations Teams of the Roy Hill organisation, is set out in Figure 7-5 andFigure 7-6.

The General Managers External Affairs and Human Resources are part of the Corporate Services Team andreport directly to the CEO and provide support to the Operational Team (Figure 7-5).




The COO, heads up the Operations Team and reports directly to the CEO. The General Manager HSE reportsto the COO and provides support to Operations Team (Figure 7-6).

The Roy Hill Leadership Team comprises ten personnel reporting to the CEO. The Leadership Team isresponsible for assisting the CEO to make key corporate decisions. The Leadership Team has considerableproject start-up/ramp-up experience, project delivery and operational experience. The Leadership Teamcontains key management, project management and operations positions (Figure 7-7).

The General Managers External Affairs, HSE and Human Resources with support from the ManagerEnvironment, Manager Indigenous Relations, Manager Employee Relations, Manager Safety and PrincipalAdvisor Community Development are responsible for ensuring environmental and social requirements andstandards are communicated, implemented and complied with throughout the construction andoperational phases of the project.

Figure 7-5: Roy Hill organisational operational structure – direct reports to the CEO

Figure 7-6: Roy Hill organisational operational structure – direct reports to the COO




Figure 7-7: Roy Hill organisational Leadership Team structure




8 Environmental and Social ManagementIFC Performance Standards and EP Requirements Guide


EP2 (EP2.2, 2.3) – Environmental and Social Assessment

EP3 (EP3.1, 3.2) – Applicable Environmental and Social Standards

EP4 (EP4.1, 4.2) – Environmental and Social management system and Equator Principles action plan.

EP 9 (EP9.1 and 9.2) – Independent monitoring and reporting

EP10 (EP10.2) – Reporting and transparency

IFC1 (IFC1.1, 1.2, 1.4, 1.6, 1.7) – Assessment and Management of Environmental and Social Risks andImpacts

IFC 2 (IFC 2.1, 2.2, 2.3, 2.4, 2.5) – Labour and working conditions

IFC3 (3.1, 3.2, 3.3, 3.4, 3.5) – Resource Efficiency and Pollution Prevention

IFC4 (IFC4.1, 4.2) – Community, Health, Safety and Security

IFC6 (IFC6.1, 6.2, 6.3, 6.4, 6.5) – Biodiversity Conservation and Sustainable Management of LivingNatural Resources

IFC7 (IFC7.1, 7.2, 7.3, 7.4, 7.5, 7.6) – Indigenous Peoples

IFC8 (IFC8.1, 8.2, 8.3, 8.4, 8.6, 8.7, 8.8) – Cultural Heritage

EHSG1 (EHSG1.1, 1.2, 1.3, 1.4, 1.5, 1.6, 1.7, 1.8) Environmental Guidelines

EHSG2 (EHSG2.1, 2.3, 2.4, 2.5, 2.6) Occupational Health and Safety Guidelines

EHSG3 (EHSG3.1, 3.2, 3.3, 3.4, 3.5, 3.6) Community Health and Safety Guidelines

EHSG4 (EHSG4.1, 4.2, 4.3) Construction and Decommissioning Guidelines

8.1 Environmental and Social Management FrameworkEnvironmental and social management for the design, construction and operation of the Project isimplemented in accordance with ISO14001:2004 and the Environmental and Social ManagementFramework (Figure 8-1) which comprise the following:

Overarching policy;

Identification of aspects and impacts;

Legal requirements;

Objectives and targets;

Roles and responsibilities;

Communications;

Operational controls;

Emergency response;

Monitoring;

Audit; and

Management review.




Environmental and social risks and impacts are managed through:

Avoidance of the project activity where practicable to eliminate the risk or impact;

Mitigation and management identification and implementation of measures and actions to eliminate orreduce risks or impacts

Monitor and review the effectiveness of mitigation and management measures and actions and identifyand implement contingency actions;

Review of risks and impacts and mitigation, management and monitoring measures on a periodic basiswith a view to achieving continual improvement in environmental and social management.

Figure 8-1: Environment and social management framework

8.1.1 Health, Safety, Emergency and Security Management FrameworkThe Roy Hill HSES Management System Framework (Figure 8-2) forms the basis for the development and application of HSES across the Roy Hill project. The RoyHill HSES hierarchy of documentation provides the framework for ensuring appropriate HSES systems andcontrols are established, implemented, maintained and improved. This framework has been developed toallow flexibility in the approach to achieve contemporary industry HSES standards in construction andoperations.




The core principles that have been applied in the development of this approach are:

Consistency and quality of HSES performance that provides individual areas (and contractors) with theability to manage HSES effectively;

To be administratively effective; and

Ability to be applied across the various regulatory frameworks and areas that apply to Roy Hill activities,for example, marine, mining and rail.

Figure 8-2: Roy Hill HSES Framework

Roy Hill recognises that health and safety must be central to all construction and operational activities. RoyHill is committed to achieving high levels of health and safety performance with the objective of being “ABetter Place to Work”.

In broad terms, and in accordance with the Health and Safety Policy, Roy Hill requires employees andcontractors to:

Ensure that risk based objectives, targets and actions are established, reviewed and integrated into theplanning and decision making processes.

Challenge unsafe behaviours/attitude at any level in the organisation whenever encountered – never walkpast any unsafe act or condition or accept poor behaviour without addressing the issue.

Establish standards, registers and procedures that recognise and control the major hazards and workplacerisks.

Always ask if unsure whether knowledge, experience and competency is sufficient to perform theactivity/task.

Consult on and resolve health and safety issues at the earliest point in time.

Establish a belief that attitudes are the driver of behaviours as they serve to motivate and direct whatpeople say and do.

Commit adequate and appropriate resources to enable us to achieve these goals.

Monitor and improving systems towards achieving the goal of “A Better Place to Work” for employees,contractors, visitors and public.




The Roy Hill HSES Framework has three major sections:

The mandatory components applicable to operations include the Roy Hill Health and Safety Policy (000RH-0000-RH-POL-0001), 16 Integrated Management Standards, 19 Performance Standards and themandatory operational procedures. For construction, the Health and Safety Policy, 16 IntegratedManagement Standards and 19 Performance Standards, together with Guidelines and Procedures formthe PPRs. The PPRs have been mandated as the minimum HSES requirements for construction. Together,these form the Roy Hill HSES Corporate Management System.

The individual area/operations/contractors HSES Management Plans and Systems that are establishedand implemented to deliver the requirements established in the Roy Hill HSES Corporate ManagementSystem. Where applicable, this tier of documents must meet the requirements of the Roy Hill HSESCorporate Management System that have been mandated across the project.

The SSoW that are used in the field to deliver the required controls into the activities being conducted.

8.2 Environmental ManagementEnvironmental objectives and targets will be achieved through the implementation of this document andthe following:

Roy Hill Environmental Policy (000RH-0000-EN-POL-0002),

Project Contractor Environmental Compliance Requirements (CECR) (100RH-0000-EN-GUI-2001);

Environmental Basis of Design (100RH-0000-EN-BOD-2001) (EBoD) and

Operational Environmental Management Plans.

8.2.1 Environmental policyThe Health and Safety Policy and Environmental Policy identifies key corporate principles to good Health,Safety, Environment, Community and Heritage performance.

The Environment Policy is a principle Project environmental management document. The objectives,targets and practices outlined in this ESMP are consistent with the commitments set out in theEnvironment Policy. The Environment Policy is communicated to all personnel via the induction process,displayed on notice boards and available on the Roy Hill intranet.

The Environment Policy has been developed to meet the requirements of ISO14001:2004 and is provided asAppendix 11.




8.2.2 Objectives and targetsThe Roy Hill objectives and targets for each environmental factor relevant to the Project are detailed inTable 8-1.

Table 8-1: Roy Hill Objectives and Targets for environmental factors

Factor Roy Hill Objectives Targets

Flora andvegetation

Minimise adverse impacts on the abundance,species diversity, geographic distribution andproductivity of vegetation communities.

Maintain ecological integrity and seed viability asfar as practicable in stripped topsoil and clearedvegetation for use in progressive rehabilitation.

Compliance with State and CommonwealthEnvironmental legislation relating to nativevegetation.

Compliance with Project regulatory approvalrequirements relating to native vegetation.

Maintain topsoil as a resource for reuse. Develop and maintain stable constructed

landforms.

Fauna

Minimise the temporary and permanent reductionor fragmentation of existing fauna habitat.

Minimise direct impacts on fauna including throughvehicle collision, entrapment in construction works,or extraordinary exposure to predators.

Minimise disturbance to and mortality of protectedor conservation significant fauna within the Projectsite.

Compliance with State and CommonwealthEnvironmental legislation relating to nativefauna.

Compliance with Project regulatory approvalrequirements relating to listed andconservation significant fauna.

Compliance with Project regulatory approvalrequirements relating to native vegetation.

Avoid impacts to priority fauna habitatwhere practicable.

Minimise mortality of listed fauna ofconservation significance where practicable.

Benthiccommunities andhabitat

Minimise impacts to the marine environment. Minimise actual or potential impacts on mangroves,

cyanobacterial mats and benthic primary producinghabitat.

Minimise impact to marine fauna

Compliance with State and CommonwealthEnvironmental legislation relating to themarine environment including Benthiccommunities and habitats and marinefauna.

Compliance with Project regulatory approvalrequirements relating to the marineenvironment including Benthic communitiesand habitats and marine fauna.

No unauthorised release of any emissions tothe marine environment during constructionworks.

Groundwater

Minimise impact to the quantity and quality ofgroundwater in order to minimise environmentalimpacts on the surrounding environment.

Ensure changes to groundwater quality and flows(hydrogeology) do not adversely impact on theFortescue Marsh.

Promote sustainable use of groundwater resourcesthroughout construction and operation andregeneration of the aquifer post-operations.

Compliance with State and CommonwealthEnvironmental legislation relating togroundwater resources.

Compliance with Project regulatory approvalrequirements relating to groundwaterabstraction and quality.

Groundwater drawdown aligns with thedrawdown model.

Surface waterand tidalprocesses

Minimise impacts to the quantity and quality ofsurface water in order to minimise environmentalimpacts downstream environments.

Compliance with State and CommonwealthEnvironmental legislation relating to surfacewater.

Compliance with Project regulatory approvalrequirements relating to surface water andtidal processes.

No unauthorised release of any pollutant tosurface water.

Minimise release of sediments to surfacewater.





Aboriginalheritage

To minimise impact to cultural sites identifiedthrough extensive consultation with indigenousgroups.

To meet obligations under Native Title Agreements.

Compliance with State and CommonwealthEnvironmental legislation relating toaboriginal heritage.

Compliance with regulatory approvalrequirements relating to AboriginalHeritage.

No unauthorised impacts to identifiedAboriginal heritage sites.

Dust Minimise the generation of dust.

Compliance with State and CommonwealthEnvironmental legislation relating to airemissions, including dust.

Compliance with Project regulatory approvalrequirements relating to Dust.

Minimise impact to nearby sensitivereceptors.

Weeds andpathogens

Identify populations of declared weeds withinProject areas.

Minimise the spread and proliferation of declaredweeds.

Contribute towards eradication of declared weedswithin Project areas.

Compliance with State and CommonwealthEnvironmental legislation relating todeclared weeds.

Compliance with regulatory approvalrequirements relating to declared weeds.

Minimise introduction of declared weedspecies into Project site from Projectactivities

Weed infestations within Project areas arenot spread beyond current extent as far aspracticable.

Existing declared weed infestations withinproject site.

Acid sulphatesoils

Identify Acid Sulphate Soil risk areas across theProject.

Manage Acid Sulphate Soils in accordance with theRoy Hill Acid Sulphate Soils Management Plan(100RH-4000-EN-PLN-2005).

Compliance with State and CommonwealthEnvironmental legislation relating to acidsulphate soils.

Compliance with regulatory approvalrequirements relating to acid sulphate soils.

Identify all acid sulphate soils prior tocommencement of work.

Minimise potential emissions of acidicleachate from Project work areas.

Greenhouse gas

Minimise generation of greenhouse gas emissionsthrough supply demand chain choices wherepracticable.

Reduce cumulative carbon footprint over the life ofthe Project as far as practicable.

Compliance with State and CommonwealthEnvironmental legislation relating togreenhouse gas emissions, including theNational Greenhouse and Energy ReportingAct 2007.

Identify opportunities for energy efficienciesand reductions in potential greenhouse gasemissions through construction,procurement and/or design decisions wherepractical and economically viable.

Noise andvibration

Protect the amenity of fauna and nearby residentsfrom noise impacts resulting from activitiesassociated with the Project.

Compliance with Environmental Protection(Noise) Regulations 1997 and other relevantlegislation.

Compliance with regulatory approvalrequirements relating to noise.

Minimise impact to nearby sensitivereceptors.

Closure andrehabilitation

Undertake rehabilitation to ensure the site is(physically) safe to humans and animals, (geo-technically) stable, (geo-chemically) non-polluting,and capable of sustaining the agreed post-miningland use.

Develop and update a Mine Closure Plan inaccordance with Section 84AA of the Mining Act

Compliance with State and CommonwealthEnvironmental legislation relating to closureand rehabilitation.

Compliance with regulatory approvalrequirements relating to closure andrehabilitation.





Implement Mine Closure Plan during and postmining operations.

All disturbed areas not required for ongoingoperations are progressively rehabilitatedprior to completion of construction.

Mine pit voids are progressively backfilledand rehabilitated to achieve rehabilitationcompletion criteria outlined in Mine ClosurePlan.

Construction landforms are safe, stable andself-sustaining at closure.

The objectives and targets for the factors identified in Table 8-1 will be achieved through implementation ofthe CECR, EBoD and OEMPs.

The CECR, EBoD and OEMPs will detail the management strategies to be implemented to ensure the Projectis managed to meet the Roy Hill objectives and targets, Environmental Standards and Project approvalrequirements.




8.2.3 Project Design and ConstructionThe EBoD is a PPR document and comprises environmental design requirements from project approvals,regulatory guidelines and industry standards. The EBoD provides Contractors with information on theenvironmental design requirements for prescribed premises and other Project facilities.

The CECR is a PPR document and provides guidance to the Contractor on the environmental requirementsduring construction of the Project and applies to all Project Contractors and construction sites.

The CECR incorporates environmental legislative and approval requirements, in addition to measuresconsidered to be sound industry practice. The document provides direction to Contractors in relation to:

Obligations;

Planning;

Auditing;

Monitoring;

Reviewing;

Reporting; and

Managing environmental performance.

8.2.4 Project OperationsOEMP has been developed for the mine, port and rail components of the Project. The OEMP sets out theenvironmental objectives and management and mitigation measures to be implemented throughoutProject operations, in order to minimise environmental impacts. The OEMP also documents monitoringand reporting procedures and contingency actions to implement in the event of unexpected events.

8.3 Social ManagementSocial Management will be delivered during the construction and operation of the Project through theimplementation of:

Roy Hill Governance Policy;

Roy Hill Health and Safety Policy;

Stakeholder Engagement Policy;

Employment Policy;

Stakeholder and Community Consultation Plan (000RH-0000-EN-PLN-0003);

Cultural Heritage Management Plan (RH1-001-00-HE-POL-1029);

Roy Hill Employee Relations Guidelines for Contractors (100RH-0000-IR-GUI-2004); and

HSES Management Framework.




8.3.1 Social PoliciesRoy Hill’s Health and Safety Policy (Appendix 12) is a principle Project environmental and socialmanagement document. Objectives, targets and practices set out in this ESMP will be consistent with thecommitments set out in the Policy. The Policy is communicated to all personnel via the induction process,displayed on notice boards and available on the Roy Hill intranet.

The Roy Hill Stakeholder Engagement Policy (000RH-0000-RH-POL-0006) sets out key corporate goals forcommunication with all external stakeholders and is provided in Appendix 13.

The Roy Hill Employment Policy (000RH-0000-RH-POL-0003) outlines key corporate practices forappropriate employment, employee development and remuneration and is provided in Appendix 14.

8.3.2 Objectives and TargetsThe objectives and targets for social factors relevant to the Project are outlined in Table 8-2 below.

Table 8-2: Roy Hill objectives and targets for social factors.

Factor Roy Hill Objective Target

Conditions of labour,employment and workingconditions

To promote fair treatment, non-discrimination and equalopportunity of workers.

To establish, maintain and improveworkplace relationships.

To promote compliance withemployment and labour legislation.

Compliance with federal and state legislatureincluding the Equal Employment OpportunityAct and Roy Hill Policies such as the Roy HillBullying and Harassment Policy.

Roy Hill has committed to comply with allfederal and state employment and labourlegislative requirements. The cornerstoneemployment and labour legislation is set out inthe Fair Work Act 2009.

Occupational health andsafety

Ensure the health and safety of thePrincipal and Contractors ismaintained through implementationof appropriate managementmeasures.

Ensure all contractors andemployees are provided withadequate and appropriate safetyinformation and training.

Compliance with Contractor Healthand Safety Guidelines (100RH-0000-HS-GUI-2001).

Compliance with the Occupational Safety andHealth Act 1984 and Regulations (1996).

Compliance with Contractor Health and SafetyGuidelines (100RH-0000-HS-GUI-2001) andHealth and Safety Management Standards(100RH-0000-HS-STD-2001).

Zero workplace fatalities.

Community health, safetyand security

Ensure no impacts to the health andsafety of the community as a resultof the Project.

Ensure all contractors andemployees are provided withadequate and appropriate trainingrelevant to community health,safety and security.

Compliance with Health Act 1911 (WA) andEnvironmental Protection Act 1986 (WA).

No significant impacts to community healthoccur as a result of the Project.

Community safety and security is notcompromised as a result of the Project.

External stakeholders

To inform stakeholders wheresignificant impacts exist.

To establish and maintain ongoingrelationships with stakeholders andIndigenous peoples throughout thelife of the Project.

To ensure ongoing Project progressreporting to stakeholders.

To ensure that construction andoperation of the Project fosters fullrespect for human rights, dignity,aspirations, culture, and natural

Compliance with Shire of East Pilbara and Townof Port Hedland Community Development Planswhere practicable.

Compliance with the Aboriginal Heritage Act1972 and Native Title Act 1993.

Compliance with Native Title Agreements. Compliance with Indigenous Heritage and

Relations Protocol (100RH-0000-HE-PRO-2004).




Factor Roy Hill Objective Target

resource-based livelihoods ofIndigenous people.

To undertake regular andtransparent consultation with NativeTitle Claimants throughout Projectactivities.

Regional employment andtraining

Promote sustainable communitydevelopment benefits.

Training and employment forindigenous and non-indigenouspersons living in the region.

Develop and implement Indigenous training andeducation programs.

Facilitate local employment opportunities in theProject.

Increase employment opportunities forIndigenous People.

Regional development andlocal procurement

Development of a sustainableregional community maximisingregional and local employment.

Regional development and localprocurement of goods and services.

Contract local companies, professional services,manufacturers and contractors as required inaccordance with the State Agreement Act.

Foster development of local community throughemployment opportunities and use of locallabour and services.

Regional and localaccessibility to services andfacilities

To maintain regional and localaccess to facilities.

To ensure regional and local servicesare not adversely impacted.

Access to port and public roads is maintained. Regional and local services are not adversely

impacted.

8.3.3 Conditions of labour, employment and workDuring construction and operation of the Project all contractors are required to abide by the Roy HillProject terms and conditions as set out in the Roy Hill Employee Relations Guidelines for Contractors(100RH-0000-IR-GUI-2004), which has been developed to ensure compliance with the Fair Work Act 2009.This document details a range of employment conditions including:

Hours of work and shift rosters;

Pay rates;

Designated rest and meal breaks;

Requirements for in-term industrial agreements;

Grievance resolution procedures;

Leave entitlements which comply with the National Employment Standards, which set out the Fair WorkAct 2009 (Cth) requirements. This includes the following types of leave: parental; annual; personal andcarer’s, compassionate, community service, long service and public holidays; and

Notice of termination and redundancy provisions.

Contractors are required to submit industrial relations management plans that address key issues and thesemust be approved by PMC prior to the contractor commencing work on the Project. Compliance is verifiedthrough audits.




During the Operations phase of the Project, Roy Hill will directly employ a significant percentage of theworkforce. These employees will be recruited and appointed in line with Roy Hill’s recruitment procedures,which are designed to ensure that competent persons are employed. All employees will be provided withthe following documents:

Letter of Offer (Common Law Contract);

Schedule of Terms and Conditions; and

Roy Hill Policies and Procedures.

Roy Hill employees who may be covered by a Fair Work Act Award (such as the Mining Industry Award2010) will be parties to a Roy Hill enterprise agreement, which has been registered and approved by theFair Work Commission. This ensures that all employees are employed on terms and conditions which arecompliant with the Fair Work Act 2009.

Roy Hill will engage contractors to provide workers to support various aspects of its operation. As per theapproach to the construction phase, all contractors will be required to submit industrial relationsmanagement plans which ensure that key issues, such as compliance with the Fair Work Act 2009, aresatisfactory to Roy Hill prior to the contractor commencing work in the operation.

8.3.4 Occupational health, safety, emergency and securityDuring construction and operation of the Project the objectives and targets outlined in Table 8-2 for health,safety, emergency and security will be achieved through the implementation of HSES Management Systemand Performance Standards.

8.3.4.1 Integrated Management StandardsThe Roy Hill Integrated Management Standards specify the minimum acceptable requirements forconstruction (PPRs) and operations. The objectives of these standards are to:

Support the delivery of relevant Roy Hill policies, regulatory requirements and requirement that supporta Plan-Do-Check-Act approach to HSES.

Provide a risk based management system framework, consistent with:

o OHSAS 18001 and National Standards (AS/NZS 4801 Occupational Health and Safety ManagementSystems).

o Regulatory requirements.

Provide auditable criteria, against which HSES management systems and performance can be managed.

Drive improvements in the performance of HSES across the business.

An overview of the content of the Integrated Management Standards is provided in Table 8-3. The Roy HillContractor Health and Safety Guideline (100RH-0000-HS-GUI-2001) provides guidance to the Contractor onthe health and safety requirements during construction of the Project and applies to all Project Contractorsand construction sites. Operational Management System Standards will be developed for the Project.




Table 8-3: Content of Management System Standards for Operations and Construction

Operations1 Construction (PPRs)

STD-0001 Product Quality Management Standard MS01: Policy

STD-0002 Planning Goals and Targets Management Standard MS02: Leadership and Accountability

STD-0003 Legal Requirements and Other CommitmentsStandard

MS03: Compliance Management

STD-0004 Business Continuity Management Standard MS04: Risk and Hazard Management

STD-0005 Leadership Commitment and Accountability Standard MS05: Security and Emergency Management

STD-0006 Risk Management Standard MS06: Incident Reporting, Investigation and InjuryManagement

STD-0007 Change Management Standard MS07: Fitness for Work, Health and Hygiene Management

STD-0008 Communication Consultation and ParticipationStandard

MS08: Training Awareness and Competence

STD-0009 Supplier and Contractor Management Standard MS09: Communication and Consultation

STD-0010 Training Competency and Awareness Standard MS10: Document Control

STD-0011 Systems Documentation and Document ControlStandard

MS11: Performance Assessment and Auditing

STD-0012 Incident Reporting and Investigation Standard MS12: Audit and Inspection Schedule. Non-conformance andAction Management

STD-0013 Crisis Emergency and Security Management StandardMS13: Reporting

STD-0014 Action and Task Management Standard MS15: Records and Record Management

STD-0015 Monitoring Audit and Review Standard

STD-0016 Asset Management Standard1HSES Management System Standards differ slightly between operations and construction to cater for the HSES nuances that exist betweenoperations and construction.

8.3.4.2 Health and Safety Performance StandardsPerformance standards specify the minimum requirements for the management of hazards that relate toRoy Hill activities. The performance standards address potential fatality events associated with iron orerelated projects and operations. These standards establish the mandatory performance criteria for thecritical controls required to deliver safe and efficient operations and construction. The expectation andperformance of these controls is specified in each performance standards. The Performance Standardsidentified for operations and construction is provided in Table 8-4.




Table 8-4: Performance Standards for Operations and Construction

Operations1 Construction (PPRs)

PS01: Vehicle Operation PS01: Air Quality Control

PS02: Fall from Heights Prevention PS02: Contractor Management

PS03: Lifting Operations PS03: Cranes and Lifting Equipment

PS04: Guarding and Barricading PS04: Electrical Safety

PS05: Working with Electricity PS05: Elevated Work Platforms

PS06: Isolation of Equipment PS06: Explosives

PS07: Hazardous Materials and Dangerous GoodsManagement PS07: Hazardous Material and Waste Management

PS08: Extreme Operating Conditions PS08: Permit to Work Systems

PS09: Fire and Explosion PS09: Plant, Vehicles and Equipment

PS10: Working with Stored Energy PS10: Railway Operations

PS11: Ground Control PS11: Risk and Change Management

PS12: Working with Explosives PS12: Water Use and Water Quality Control

PS13: Biological Hazards PS13: Working and Travelling Alone

PS14: Fitness for Work

PS15: Radiation

PS16: Safety Processes

PS17: Rail Controls

PS18: Marine Controls

PS19: In Pit Automation1 HSES Performance standards differ slightly between operations and construction to cater for the HSES nuances that exist between operations andconstruction.

8.3.4.3 Corporate HSES Procedures (Mandatory Component)While it is Roy Hill’s objective to maximise the goal-setting nature of the HSES processes, there are adiscrete number of procedures and processes that need to be applied in a consistent and common mannerto ensure:

A common understanding of mandatory roles and accountabilities;

Interfaces between areas/ contractors are appropriately controlled; and

Operational efficiencies where personnel are utilised across different areas i.e. Mine, Port, Rail, etc.




Documented procedures detail the management strategies to be implemented to ensure the Project ismanaged to meet the Roy Hill objectives and targets, relevant legislation and standards for the followingfactors:

Risk management;

Change management;

Incident investigation;

HSES reporting;

Lock-out Tag-out (LOTO);

Contractor Management;

Traffic Management;

Explosive Transport, handling and Storage;

Hazardous Materials Management;

Potable Water Management;

Prohibited & Restricted Equipment; and

Crisis and Emergency management.

8.3.4.4 SecuritySecurity personnel are engaged on the Project to protect people and infrastructure and maintain records ofpersonnel movements.

Security companies and their personnel are registered and licenced with the Western Australian Policedepartment in Western Australia and must hold the following:

Security Agents Licence – For companies; and

Security Officer Licence – For individuals.

Roy Hill selects and lists a number of companies to prequalify prior to selecting companies to tender on thebasis of their responses to the following:

Financial capability;

Experience;

Capability;

Reputation; and

Human Resources, Safety and Industrial Relations management plans.

Roy Hill selection of security personnel is then based on a specific assessment questionnaire and pricing

The Roy Hill scope for security does not include any policing matters and any potential actions that breakthe law are referred to the WA police or Federal Police (in the matter of the airport security controls) toaction.




8.3.5 Community health and safetyThe environmental and social impact assessment determined that the construction and operation of theProject is unlikely to have a significant impact on the health and safety of sensitive receptors including nearbycommunities.

During construction and operation of the Project the objectives and targets outlined in Table 8-2 forcommunity health and safety will be achieved through the implementation of the Roy Hill Social EngagementPolicy, Stakeholder and Community Consultation Plan, , Community Development Plans and Native TitleAgreements.

These documents outline the strategies to be implemented by Roy Hill and its Contractors to meet Roy Hillobjectives and targets and legal and other requirements.

8.3.6 External StakeholdersDuring construction and operation of the Project the objectives and targets outlined in Table 8-2 forengagement with external stakeholders will be achieved through the implementation of the and Roy HillStakeholder and Community Consultation Plan, Aboriginal Heritage Management Guidelines for Contractors(100RH-0000-HE-GUI-2003) and Indigenous Relations and Heritage Protocol (100RH-0000-HE-PRO-2004).These documents outline the management strategies to be implemented by Contractors on the project tomeet Roy Hill objectives and targets and legal and other requirements for the following factors:

Indigenous relations;

Heritage and Culture;

Aboriginal Heritage Management Requirements; and

Breach of Protocols/Principles.

Contractors are required to prepare management plans that address key issues and must be approved byPMC.

8.3.7 Regional employment and trainingDuring construction and operation of the Project the objectives and targets outlined in Table 8-2 for regionalemployment and training will be achieved through the implementation of the Stakeholder EngagementPolicy, Roy Hill Stakeholder and Community Consultation Plan, Community Development Plans and NativeTitle Agreements.

These documents outline the management strategies to be implemented by Contractors on the project tomeet Roy Hill objectives and targets and legal and other requirements for the following factors:

Local and indigenous employment

Local and indigenous training opportunities

Contractors are required to prepare an Indigenous Employment, Training and Business Opportunities Planwhich must be approved by PMC.

8.3.8 Regional Development and local procurementDuring construction and operation of the Project the objectives and targets outlined in Table 8-2 for regionaldevelopment and local procurement will be achieved through the implementation of the Roy Hill StakeholderEngagement Policy, Stakeholder and Community Consultation Plan, Community Development Plans andNative Title Agreements. These documents detail the management strategies to be implemented byContractors on the project to meet Roy Hill objectives and targets and legal and other requirements for thefollowing factors:




Local contracting opportunities; and

Support for community initiatives.

8.3.9 Regional and local accessibility to services and facilitiesDuring construction and operation of the Project the objectives and targets outlined in Table 8-2 for accessto services and facilities will be achieved through the implementation of the Roy Hill Stakeholder EngagementPolicy, Stakeholder and Community Consultation Plan, Community Development Plans and Native TitleAgreement. Roy Hill will participate in local government forums and committees to ensure that potentialissues are identified and promptly addressed.

8.4 MonitoringMonitoring and measurement of impacts on environmental and social factors will be achieved through theimplementation of monitoring and review programs and procedures outlined in the various ManagementPlans described in sections 8.2 and 8.3. Periodic monitoring of implementation of environmental and socialmanagement measures will identify non-conformances and areas for improvement and facilitate thedevelopment of implementation of contingency actions. This will ensure that the Roy Hill objectives,targets and Project approval requirements are being met. Monitoring will include periodic risk based auditsrelevant and appropriate to each environmental or social factor.

8.5 ContingencyContingency actions have been developed for each environmental and social factor, in the event thatmonitoring indicates that environmental or social objectives, targets and Project approval requirements forenvironmental or social management are not being met. Contingency measures will ensure continualimprovement of environmental and social management for all factors.

Contingency measures for each environmental and social factor are identified in the relevant managementplans and procedures.

8.6 Reporting8.6.1 InternalRoy Hill is obliged under legislation to submit reports to various State and Commonwealth regulatoryagencies. Roy Hill requires Contractors and Roy Hill personnel to report data on a monthly basis so thatregulatory reporting requirements can be met.

During construction Contractors report environmental information on a monthly basis to the PMC in theContractor Environmental Report. This report is reviewed by the PMC for accuracy and completeness andprovided to Roy Hill on a monthly basis.

In addition, during construction Contractors provide a monthly report to Roy Hill management detailingprogress in regards to:

Health and safety;

Environment, Heritage and Government Approvals;

Design, materials, engineering and construction quality;

Industrial Relations; and

Progress of the Project in relation to engineering, procurement and construction.

During operations, Roy Hill contractors and Roy Hill employees will report required environmentalinformation on a monthly basis to Roy Hill in the Contractor Environmental Report.




Operational contractors will provide monthly reports to Roy Hill management outlining achievementsagainst key performance indicators and contractual requirements. Roy Hill Operations teams will provide amonthly report to senior management outlining progress against key performance indicators relating tohealth and safety, environment and quality objectives.

8.6.2 ExternalRoy Hill is obliged through Environmental and Social Standards to provide management reports to theSenior Lenders and to various State and Commonwealth regulatory agencies. All external reports areprepared by Roy Hill to required reporting standards and demonstrate compliance with relevantenvironmental and social standards and legal requirements.

External reporting will be completed and provided to:

State and Commonwealth Environmental Regulatory Authorities outlining compliance with approvals,licences and legislation;

Minister for State Development outlining local content;

Department of Mines and Petroleum regarding environmental, health and safety measures, mine andexploration progress and relevant geological information;

Work Place Gender Equality Agency with regards to gender and equal employment information; and

The Senior Lenders to the SLFA as outlined in section 3 (Lenders General Requirements).




9 Emergency Preparedness and ResponseIFC Performance Standards and EP Requirements Guide

This section addresses the requirements of:

IFC1 (IFC1.1, 1.6) – Assessment and management of environmental and social risks

EHSG2 (EHSG3.3, 3.7) Community Health and Safety

9.1 Crisis Emergency and Security Management SystemIt is the intent of Roy Hill to streamline systems of emergency management and where ever possible have asingle document for each area of operation being Port, Rail, Mine, to minimise risk and injuries. An exampleof this is the adoption of the Australasian Inter-service Incident Management System (AIIMS) which islocally, state, federally and internationally recognised as the system of management for emergencies.

Potential emergency situations are identified in accordance with the HSES risk management standard andprocedure and are recorded in the Corporate Risk Management Register.

The procedures take into account environmental and social incidents arising or likely to arise as aconsequence of operating conditions, accidents, and potential situations that may cause incidents oremergency situations.

Emergency preparedness and response procedures are incorporated into the CECR, OEMP and HSESManagement System Standards.

9.2 Crisis Management PlanThe Roy Hill Crisis Management Plan (100RH-0000-HS-PLN-2027) has been developed to allow CrisisManagement Team members to manage crisis and emergency situations effectively and professionally.The Plan provides an outline of the systems implemented by the organisation during at crisis or emergencyincident and how they operate within the corporate structure.

9.3 Emergency Management PlanThe Roy Hill Emergency Management Plan (100RH-0000-HS-PLN-2004) defines the processes for emergencyresponse for incidents occurring within Project sites and includes structural roles and responsibilities foreach team member.

The Roy Hill Incident Investigation and Reporting Procedure (100RH-0000-HS-PRO-2004) is used to definethe processes for reporting and investigating all incidents (or potential incidents), with a view to reducingthe likelihood of those incidents recurring (refer Section 14).

The Roy Hill Cyclone Management Plan - Port Hedland and Rail North (100RH-0000-HS-PLN-2013) and RoyHill Cyclone Management Plan - Mine and Rail South (100RH-0000-HS-PLN-2014) are used to minimisedamage to property and injury to personnel from a cyclone, as far as practicable.

The above management plans are reviewed annually and updated if required.




10 Incident Management, Corrective Actions and Preventative ActionsIFC Performance Standards and EP Requirements Guide


IFC1 (IFC1.1, 1.6) – Assessment and management of environmental and social risks

ISO14001:2004

All Contractors and Roy Hill personnel are responsible for reporting, investigation and mitigation ofincidents that occur within their respective work sites and areas of responsibility.

10.1 Incident managementA formalised incident management process has been developed and implemented. Incident management,reporting and investigation documents are readily available on Roy Hill’s Incident Management System topersons working for Roy Hill. Roy Hill has developed an Incident Reporting and Investigation Standard(000RH-0000-RH-STD-0012). The Roy Hill Incident Investigation and Reporting Procedures (100RH-0000-HS-PRO-2004) and Roy Hill Incident Notification Flowchart (100RH-0000-HS-FLC-2001) are issued tocontractors and define the processes for reporting and investigating incidents (or potential incidents), witha view to reducing the likelihood of those incidents recurring.

Incidents that have occurred are reported through the Incident Notification Form (hard copy form and/orProject electronic Incident Management System) and once submitted, are documented within theelectronic incident management system. Once the data is entered, automatic e-mail notifications are sentout to inform Roy Hill Management and other relevant personnel about the incident and actions required.

The Roy Hill Environment and Heritage Teams review close-out of environmental and heritage incidents toensure that adequate investigation is undertaken and preventative and corrective actions are identified,and implemented.

The Roy Hill Health and Safety Team reviews close-out of health and safety related incidents to ensure thatadequate preventative and corrective actions are identified, and implemented.

The Roy Hill Industrial Relations team is responsible for reviewing the close out of industrial and employeerelations incidents.

Project Construction and Operational Managers are responsible for reviewing the close out of qualityrelated incidents.

10.2 Corrective and preventative actionsCorrective and preventative actions are recorded in Roy Hill’s electronic Incident Management Systemwhich tracks the reporting, investigation and close out of incidents.

Incident investigations are conducted to determine the root cause and to identify and implement correctiveand preventative actions to minimise the potential for re-occurrence of the incident.




A Formal Root Cause Analysis (RCA) is required for incidents with consequence of significant and aboveusing Roy Hill’s Risk Matrix. The formal RCA process is outlined in the Roy Hill Incident Investigation andReporting Procedure (100RH-0000-HS-PRO-2004) and includes:

establishing the timeline of events leading up to and following the incident; and

identifying:

o the conditions and facts relating to those events;

o the causal factors;

o the root causes;

o more widespread systemic or generic causes; and

o corrective actions and risk control measures.




11 Roles and ResponsibilitiesIFC Performance Standards and EP Requirements Guide


IFC1 (IFC1.5) – Assessment and management of environmental and social risks

11.1 Principal11.1.1 Leadership teamIndividual members of the Roy Hill leadership team, particularly the CEO and COO have responsibility to:

support the development, implementation and maintenance of the Roy Hill ESMP;

support annual reviews of the health and safety, environmental and social policies;

promote environmental and social awareness; and

support management reviews of the Roy Hill ESMP;

ensure that adequate resources are provided to enable Roy Hill to comply with environmental and sociallaws, approvals and standards.

11.1.2 General Managers, Project Directors/ Project ManagersRoy Hill Project Directors and Project Managers have responsibility to:

support implementation of the Roy Hill ESMP in consultation with relevant personnel for their area ofresponsibility (i.e. a facility or activity);

ensure procedures are prepared to implement the elements of the Project environmental and socialmanagement framework for their area of responsibility;

delegate selected responsibilities to team leaders (e.g. superintendents, contractor);

authorise corrective, preventative and contingency actions and resolve issues pertaining to non-conformances/compliances;

take appropriate action in the event of inadequate environmental or social performance or unacceptablerisk;

allocate adequate and appropriate resources to ensure environmental and social obligations are met; and

ensure suppliers and contractors comply with environmental and social obligations, and clarify wherenecessary.

11.1.3 General Manager External AffairsRoy Hill General Manager External Affairs has responsibility to:

ensure that the Roy Hill ESMP is effectively implemented, maintained, reviewed and updated during thedesign, construction and operation phase of the Project;

support annual reviews of social policies;

promote environmental and social awareness;

ensure that adequate resources are provided to enable Roy Hill to comply with legislation, regulationsand other social obligations;

allocate sufficient (human, physical and financial) resources to manage the Project’s environment, social,legal and other obligations;




delegate selected responsibilities to Management Team members;

maintain and control internal communication procedures and ensure that records and files aremaintained;

liaise with Project Directors/Managers and/or Contractors on contingency actions which address socialissues;

report to the CEO and Leadership Team on the performance of the Roy Hill ESMP and improvementopportunities;

be available during any critical construction/operation activities and provide support to the Project Teamto enable them to meet their social obligations;

ensure community complaints and non-conformances are recorded in Roy Hill’s electronic incidentmanagement system and appropriately considered and remedied where possible;

liaise with the general public and key stakeholders (e.g. government departments) as required;

ensure the necessary approvals are obtained to comply with legislation and regulations;

ensure training and awareness is incorporated in inductions and are kept up to date; and

oversee social monitoring and reporting requirements as required by government approvals (e.g. licenses,permits, tenement conditions).

11.1.4 General Manager Health, Safety and EnvironmentThe General Manager HSE has responsibility to:

ensure the Roy Hill Health and Safety and Environment Policiesare effectively implemented, reviewed andupdated during the design, construction and operation phases of the Project;

support management reviews of the Roy Hill ESMP and ensure that adequate resources are provided toenable Roy Hill to comply with legislation, regulations and other environmental and social obligations;

ensure the Roy Hill ESMP is effectively implemented, maintained, reviewed and updated during thedesign, construction and operation phase of the Project;

allocate sufficient (human, physical and financial) resources to manage the Project’s environmental andhealth and safety legal and other obligations;

delegate selected responsibilities to health and safety team members;

maintain and control internal communication procedures and ensure that health and safety records andfiles are maintained;

liaise with Project Directors/Managers and/or Contractors on contingency actions which address healthand safety issues;

report to the COO on the performance of the Roy Hill ESMP and improvement opportunities;

be available during any critical construction / operation activities and provide support to the Project Teamto enable them to meet their health and safety obligations;

ensure environmental and health and safety issues and non-conformances are recorded in Roy HillIncident Management System (refer to Section 10) and appropriately considered and remedied wherepossible;

ensure that the necessary health and safety approvals are obtained to comply with legislation andregulations;

ensure environmental and health and safety training and awareness is incorporated in inductions and arekept up to date; and




oversee monitoring and reporting of environmental and health and safety requirements as required bygovernment approvals, legislation and Australian standards.

11.1.5 General Manager Human ResourcesRoy Hill General Manager Human Resources has responsibility to:

ensure that the Roy Hill ESMP is effectively implemented, maintained, reviewed and updated during thedesign, construction and operation phase of the Project;

support annual reviews of the HSECH, environmental and social policies;

promote industrial relations and social awareness;

support management reviews of the Roy Hill ESMP and ensure that adequate resources are provided toenable Roy Hill to comply with legislation, regulations and other social obligations;

allocate sufficient (human, physical and financial) resources to manage the Project’s, human resourcesand industrial relations legal and other obligations;

delegate selected responsibilities to team members;

maintain and control internal communication procedures and ensure that records and files aremaintained;

liaise with Project Directors/Managers and/or Contractors on contingency actions which address humanresources and industrial relations issues;

report to CEO and Leadership Team on the performance of the Roy Hill ESMP and improvementopportunities;

be available during any critical construction/operation activities and provide support to the Project Teamto enable them to meet their human resources and industrial relations obligations;

ensure community complaints, industrial relations issues and non-conformances are recorded in Roy Hill’selectronic incident management system and appropriately considered and remedied where possible;

ensure training and awareness is incorporated in inductions and are kept up to date; and

oversee human resources and industrial relations monitoring and reporting requirements as required bygovernment approvals (e.g. licenses, permits, tenement conditions).

11.1.6 Manager EnvironmentThe Manager Environment has responsibility to:

ensure the Roy Hill Environment Policy is effectively implemented, reviewed and updated during thedesign, construction and operation phases of the Project;


allocate sufficient (human, physical and financial) resources to manage the Project’s environment, legaland other obligations;

delegate selected responsibilities to environmental team members;

maintain and control internal communication procedures and ensure that environmental records and filesare maintained;

liaise with Project Directors/Managers and/or Contractors on contingency actions which addressenvironmental issues;




report to the CEO and Leadership Team through the General Manager External Affairs on the performanceof the Roy Hill ESMP and improvement opportunities;

be available during any critical construction / operation activities and provide support to the Project Teamto enable them to meet their environmental obligations;

ensure community complaints and non-conformances are recorded in Roy Hill Incident ManagementSystem (refer to Section 10) and appropriately considered and remedied where possible;


obtain the necessary environmental approvals to ensure compliance with legislation and regulations;

ensure environmental training and awareness is incorporated in inductions and are kept up to date; and

ensure that environmental monitoring and reporting requirements as required by government regulatoryauthorities (e.g. licenses, permits, tenement conditions) are submitted within required timeframes.

11.1.7 Manager Indigenous RelationsThe Manager Heritage has responsibility to:

ensure the Roy Hill Stakeholder Engagement Policies are effectively implemented, reviewed and updatedduring the design, construction and operation phases of the Project;


allocate sufficient (human, physical and financial) resources to manage the Project’s heritage, legal andother obligations;

delegate selected responsibilities to team members;

maintain and control internal communication procedures and ensure that heritage records and files aremaintained;

liaise with Project Directors/Managers and/or Contractors on contingency actions which address heritageissues;

report to the CEO and Leadership Team on the performance of the Roy Hill ESMP and improvementopportunities;

be available during any critical construction / operation activities and provide support to the Project Teamto enable them to meet their heritage obligations;

ensure community complaints and non-conformances are recorded in Roy Hill Incident ManagementSystem (refer to Section 10) and appropriately considered and remedied where possible;


obtain the necessary heritage approvals to ensure compliance with legislation and regulations;

ensure heritage training and cultural awareness are incorporated in inductions and kept up to date; and

oversee heritage monitoring and reporting requirements as required by government approvals (e.g.licenses, permits, tenement conditions).

11.1.8 Environmental and External Affairs SuperintendentsThe Superintendents have responsibility to:

facilitate design, implementation and operation of environmental monitoring programs, includingfostering relationship with consultancy organisations;




review construction phase environmental documentation and facilitate the process to improve policiesand procedures for the operational phase;

establish and continuously improve the Roy Hill ESMP, in line with ISO14001 requirements, including allrelated documentation (e.g. policies, guidelines, procedures, registers);

assist the Manager Environment and/or General Manager External Affairs to ensure that the Roy Hill ESMPis effectively implemented;

facilitate audits / inspections and review and feedback to the Leadership Team;

facilitate provision of environmental advice and support across Roy Hill to address environmental issuesand facilitate compliance with environmental approvals and obligations;

provide direction, guidance and mentoring of environmental advisors and delegate selectedresponsibilities;

support corporate level liaison with government regulators on permitting, licensing and compliance issuesand communicate with the general public on environmental matters; and

oversee the development of environmental plans, applications and/or (annual) reports to governmentauthorities.

11.1.9 Health and Safety, Industrial Relations and Human Resources SuperintendentsThe Superintendents have responsibility to:

facilitate design, implementation and operation of relevant social monitoring programs, includingfostering relationship with consultancy organisations;

review construction phase social documentation and facilitate the process to improve policies andprocedures for the operational phase;

establish and continuously improve the Roy Hill ESMP, in line with ISO14001:2004 requirements, includingall related documentation (e.g. policies, guidelines, procedures, registers);

assist the relevant Manager to ensure that the Roy Hill ESMP is effectively implemented;

facilitate audits / inspections and review and feedback to the Leadership Team;

facilitate provision of relevant social and health and safety advice and support across Roy Hill;

provide direction, guidance and mentoring of relevant project and operations personnel and delegateselected responsibilities;

provide input into the development of management plans, applications and/or (annual) reports togovernment authorities.

Support line management in the implementation of HSES procedures and processes.




11.1.10 Roy Hill Environmental and Heritage PersonnelEnvironmental and heritage personnel have responsibility to:

complete environmental and heritage management documentation as required;

comply with legal and contractual requirements;

understand and implement the Roy Hill ESMP;

participate in awareness training, as required via the Roy Hill ESMP;

implement the relevant management actions and environmental and heritage obligations into itsdocumentation and procedures and routinely inspect its implementation progress;

arrange or conduct training/induction for all personnel prior to commencement of activities;

implement the Project Director/Manager’s directions on environmental and heritageobligations;

provide relevant information to assist Roy Hill in meeting its legislative and other government reportingrequirements (e.g. Department of Environmental Regulation (DER) Licence, National GreenhouseEmission Reporting Scheme (NGERS), National Pollutant Inventory (NPI); and

report environmental incidents and performance as directed.

As part of this Roy Hill ESMP, personnel are to ensure compliance with all conditions of licences, permits,consents, approvals and other legal requirements relating to the Project as recorded in the Roy HillEnvironment, Legal and Other Obligations Register (100RH-0000-EN-REG-2001). This register is provided toContractors and reviewed by the Roy Hill Environmental Team every six months or whenever changes inlegislation and regulations occur.

11.1.11 Roy Hill Health and Safety, Industrial Relations and Human Resources PersonnelRoy Hill Health and Safety, Industrial Relations and Human Resources personnel have responsibility to:

complete relevant social management documentation as required;



participate in awareness training, as required via the Roy Hill ESMP;

implement the relevant management actions and relevant health and safety, industrial relations andhuman resources obligations into its documentation and procedures and routinely inspect itsimplementation progress;

arrange or conduct training/induction for all personnel prior to commencement of activities;

implement the Project Director/Manager’s directions on health and safety, industrial relations and humanresources obligations;

report health and safety, industrial relations and human resources incidents and performance as directed;and

support line management in the implementation of HSES procedures and processes.




11.2 Project Management ContractorThe PMC, as a minimum, provides the following environmental and social management services during theconstruction phase of the Project:

conduct assurance reviews that Contractor activities are performed in compliance with the Roy Hill PPR;

report immediately to Roy Hill Environmental Manager in the event of any loss or release of anypotentially polluting matter or any other action by Roy Hill or Contractors during construction activitiesthat has caused or is likely to cause environmental impacts and outline the recovery and / or remediationprogram to be used to minimise environmental impacts. Reporting will be compliant with the reportingrequirements outlined in the internal reporting procedures and the approved Roy Hill ESMP;

report health, safety, environmental and social incidents in accordance with the Incident Investigationand Reporting Procedure

report environmental and social statistics and data in accordance with statutory requirements as definedin the Contractor Environmental Compliance Requirements document;

monitor and audit Contractors in the field; and

ensure that Contractors are undertaking the scope of work within environmental and social guidelines.

11.3 EPC Contractor, Design & Construct Contractors, Operational ContractorsPersonnel of Project Contractors have responsibility to:

submit management documentation, as required by the contract and scope of work;

provide adequately skilled resources;



participate in awareness training, as required either by the Contractor’s EMS/ESMP or via the Roy HillESMP;

implement the relevant management actions and environmental and social obligations into itsdocumentation and procedures and routinely inspect its implementation progress;

arrange or conduct training/induction for all contractor personnel prior to commencement of activities;

implement the Project Director/Manager’s directions on environmental and social obligations;

provide relevant information to assist Roy Hill in meeting its legislative and other government reportingrequirements (e.g. DER Licence, National Greenhouse Emission Reporting Scheme (NGERS) and NationalPollutant Inventory (NPI); and

report incidents and performance as directed.

Each Contractor is required to provide management plans demonstrating their intent and ability to managetheir environmental and social aspects and impacts applicable for their contact scope. Contractors arerequired to identify how they will achieve the requirements of the Roy Hill ESMP by defining theirmanagement strategies and setting environmental and social objectives and targets.

As part of this Roy Hill ESMP, Contractors are required to ensure compliance with all conditions of licences,permits, consents, approvals and other legal requirements relating to the Project.




11.4 All personnelAll personnel associated with the Project are required to:

comply with relevant Acts, Regulations, codes of practice and standards;

comply with the Roy Hill Environment Policy, Roy Hill Health and Safety Policy, procedures andenvironmental and social obligations;

promptly report to management any hazards, non-conformances, environmental, health and safety andsocial incidents and/or breaches;

participate in awareness training as directed by the Roy Hill Leadership Team; and

conduct construction and operational activities in an environmentally responsible manner.




12 Training and AwarenessIFC Performance Standards and EP Requirements Guide


ISO14001:2004

IFC1 (IFC1.1) – Assessment and Management of Environmental and Social Risks


12.1 TrainingRoy Hill has established a set of Training requirements that underpin the Training Competency andAwareness Standard . This ensures training and competency requirements are identified, managed andmonitored through a variety of sources including, but not limited to:

Applicable legislation, codes of practice, standards and other requirements;

Company policies, standards, procedures, guidelines and work instructions; and

Industry guidelines and best practice.

Additionally training needs will also be assessed based on:

High risk work licenses shall require verification of competency; and

Risk commensurate to the Roy Hill Project scope of works.

All personnel working on the Project will hold the necessary approvals, permits, certificates, tickets, andlicences relevant to their duties and required by law.

12.1.1 InductionsAn induction program has been established and is implemented prior to all staff attending the site. Thescope of the induction programme includes:

An over-arching Project induction

Site induction specific to each area (Port, Mine and Rail);

Short term worker induction

Visitor information/ orientation; and

Contractor induction.

The induction program includes training and assessment to ensure that all personnel entering the Projectare aware of their environmental and social responsibilities and are competent to carry out their work in anenvironmentally acceptable and safe manner. Environmental topics covered in the induction programinclude, but are not limited to:

Water management;

Waste management;

Weed hygiene;

Hydrocarbon spills;

Dust management;

Fire management;




Fauna management;

Aboriginal heritage;

Vegetation and flora management;

Environmental incident reporting; and

Contractor Environmental Compliance Requirements.

Social topics covered in the induction program that raise awareness and ensure the Project is compliantwith Equator Principles and IFC Performance Standards include:

Aboriginal heritage;

Indigenous relationships and stakeholders;

Communication – internal and external;

Occupational Health and Safety;

Community Health and Safety;

Security;

Access and recreational land use;

Incident reporting and response; and

Emergency preparedness and response.

Induction records, including names of people inducted and quiz results are retained and centrally recordedwithin the Roy Hill Learning Management System.

Personnel performing tasks that may potentially cause significant environmental impacts shall:

receive additional induction and / or training in a modular format to further inform them of particularrequirements, risks and controls; or

be certified as having completed induction and training processes, and/or as having gained appropriateexperience, before undertaking such tasks.

Personnel involved in communication and social interaction where recognition of culture, language and theneeds of vulnerable groups are required shall:

receive additional induction and/or training in a modular format to further inform them of particularrequirements; or

must be certified as having completed induction and training processes, and/or as having gainedappropriate experience, before undertaking such tasks.

12.2 Training registerStructured job descriptions with tasks, responsibilities, and selection criteria are documented. Minimumstandards for qualifications, work experience and physical fitness are established for the tasks defined.Selection is conducted based on compliance with defined criteria.

Personnel are required to possess appropriate accreditation, suitable qualifications and competency skillsand experience specific to the job requirements, and are fit for work.

Current and valid licences and/or certificates of competency or appropriate statutory exemptions areinspected and documented in the Learning Management Systems and approved document managementsystems.




12.3 Review and auditTraining needs are identified and regularly reviewed. Competent accredited trainers accredited trainingcourses, refresher courses and effectiveness reviews are used where available. All training outcomes aredetermined and documented.

Competency of the workforce is assessed through appropriate training, and social impact inspections andaudits to support the identification of any systematic failures and recommend corrective action(s).




13 CommunicationIFC Performance Standards and EP Requirements Guide


EP4 (EP4.1, 4.2) – Environmental and social management system and Equator Principles Action Plan

EP5 (EP5.1, 5.2, 5.3, 5.4) – Stakeholder engagement

EP6 – Grievance mechanism


IFC1 (1.8, 1.9, 1.10) - Assessment and management of environmental and social risks

IFC7 (7.1, 7.2) – Independent review

IFC8 (8.5) – Cultural Heritage.


13.1 Internal stakeholders13.1.1 Communication and participationThe ESMP and Stakeholder and Community Consultation Plan define the strategy and management actionsfor social engagement and communication with Stakeholders.

Roy Hill will conduct informed transparent internal consultation and participation processes which aretailored to the:

Environmental and social risks and impacts;

Phase of development;

Decision making processes; and

Community or Stakeholder needs.

Roy Hill and Contractor personnel are expected to communicate environmental and social issues to therelevant Roy Hill Manager/or delegated representatives with a particular focus on items that are:

Outside their responsibility;

Not adequately managed; and

Issues of environmental or social concern (e.g. near miss, environmental, health and safety incidents).

The relevant Roy Hill Manager or appointed delegate reviews, and where appropriate, responds to allinternal communication relating to environmental or social issues. All relevant internal communicationrelating to environmental and social issues are maintained and recorded on the Roy Hill DocumentManagement System (DMS); either as emails, memos, minutes, and/or letters.




13.1.2 Grievance / conflict mechanismManagement of internal conflicts relating to environmental and social management follow the internalescalation process at no cost and without retribution. The internal escalation process includes thefollowing steps:

1. Discussion of issue within the relevant Roy Hill Team and/or discussion with other functional or deliveryTeams.

2. If resolution cannot be achieved within one day it is escalated to the Manager of the relevant Department(i.e. Environment, Heritage, Human Resources, Health and Safety, External Affairs).

3. If resolution cannot be resolved within one day following escalation to the Roy Hill Department Manager,it is escalated to the relevant General Manger and/or Project Director/s.

4. If resolution cannot be resolved within one day following escalation to the General Manger or ProjectDirector/s then it is escalated to the CEO.

This process will be implemented during construction and operation of the project and will be subject toregular review.

13.1.3 ReportingWeekly and Monthly reports are submitted to the CEO outlining:

Progress of environmental and social activities;

Identification of environmental and social risks; and

Key objectives for following month.

Other internal reporting and methods of communication on environmental and social matters include:

Team meetings;

Handover meetings (site shift change);

Toolbox and pre-start meetings;

Site notice boards;

Roy Hill DMS;

Electronic alerts (e.g. environment/health and safety notices);

e-mails;

Newsletters; and

Roy Hill intranet.




13.2 External stakeholders13.2.1 CommunicationThe ESMP and Roy Hill Stakeholder and Community Consultation Plan define the strategy and managementactions for social engagement and communication with Stakeholders.

External communications are managed by the General Manager, External Affairs and General Manager HSE.

Roy Hill will conduct informed transparent external consultation and participation processes which aretailored to:

Environmental risks and impacts;

Phase of development;

Language of the relevant community group;

Decision making processes; and

Community or Stakeholder needs.

Roy Hill General Managers and Managers are responsible for managing communication with externalstakeholders including government regulators and land tenure holders (e.g. DER, DMP, Department ofWater (DoW), DAA). PMC and Contractors may communicate with land tenure holders if authorised to doso by Roy Hill but do not communicate directly with government agencies on key environmental or socialmatters relevant to the Project.

The Roy Hill General Manager External Affairs or nominated delegate is responsible for dealing with allmedia communications. Contractors and Roy Hill personnel are required to forward mediacommunications to the General Manager External Affairs. The General Manager External Affairs ordelegate will review the communication and decide on the appropriate course of action, and act as aspokesperson where appropriate.

Records of all external communication are kept within the Roy Hill DMS. Roy Hill ensures thatcommunication received from external stakeholders is documented and responded to in a timely manner.

The Leadership Team and members of the Environment and Land Tenure Teams regularly liaise withrelevant public authorities on a range of environmental and social matters relating to the Roy Hill Project.

Methods of external communication include:

Media releases;

Community consultation / forums / workshops;

Written correspondence;

Telephone conversations;

Site visits;

Stakeholder meetings;

Roy Hill website (internet); and

Meetings with regulators.




13.2.2 External Grievance mechanismCommunity complaints are managed in accordance with the Roy Hill Complaints Handling Procedure(100RH-0000-EN-PRO-2012) at no cost and without retribution. A Roy Hill Community Complaint Form isavailable for use. Any complaints received are entered into Roy Hills electronic Incident ManagementSystem and managed in the same way as all project incidents.

A Roy Hill complaints register is maintained on Roy Hills electronic Incident Management System forexternal complaints and detailed response procedures are used for community issues.

13.2.3 ReportingRoy Hill provides regular updates of Project progress to affected communities.

Regulatory environmental and social compliance reporting is undertaken by the relevant department(including External Affairs, Heritage, Health and Safety, Industrial Relations and Human Resources) asrequired by approvals and legislation.

13.2.4 Indigenous peoplesAgreements have been signed with all three Traditional Claimant Groups (Kariyarra, Palyku and Nyiyaparli)that outline the process for communication with the Groups as well as other matters including the heritageprocess; employment, education, and training; cross cultural awareness; and royalty payments.

Roy Hill meets at least quarterly with each of the Groups to discuss implementation of the commitments inthe Agreements as well as any other issues that Traditional Claimants may wish to raise.

Roy Hill also has an Indigenous Relations and Heritage Protocol document which outlines the following keyprinciples:

Respecting Culture: acting at all times in a responsible manner and with respect for the Indigenous cultureand people.

Communication: respectful, honest and open dialogue with Indigenous communities, groups and people.Friendly and productive long-term relationships with Traditional Claimant will be based on trust, goodwilland mutual respect.

Enterprise Development: promoting opportunities for Indigenous people to participate in its operation ona commercially competitive basis. Processes will be established to identify and support Indigenouscompanies and contractors that are able to provide services, personnel and/or equipment.

Employment: encourage and support Indigenous people and companies to compete effectively foremployment and contracts. Once employed, further support through policies and practices that aresensitive to the cultural and traditional obligations of Indigenous Australians will be provided.

Cross-Cultural Understanding: implement various processes to increase awareness and understanding ofthe following:

o Diversity of Indigenous cultures and customs;

o The business case for engaging with Indigenous communities;

o The socio-economic circumstances of many Indigenous communities and the potential role thePrincipal can have in achieving meaningful change; and

o Community development, business and diversification models that can facilitate the establishmentand maintenance of sustainable communities in accordance with ongoing agreements andcommitments.




14 Audit and ReviewIFC Performance Standards and EP Requirements Guide


EP3 (3.1, 3.2) – Environmental and social standards

EP7 (EP7.2) – Independent review

EP8 (EP8.2) – Covenants

EP9 (EP9.1, 9.2) – Independent Monitoring and Reporting

EP10 (EP10.3) –Reporting and transparency

IFC1 (IFC1.7) – Assessment and Management of Environmental and Social Risks and Impacts

IFC2 (IFC2.1, 2.2, 2.3, 2.4, 2.5) - Labour and working conditions

IFC6 (6.4, 6.5) - Biodiversity Conservation and Sustainable Management Living Natural Resources

14.1 Internal auditing and reviewAudits and inspections are conducted to ensure activities are completed in accordance with legal and otherrequirements and to deliver good environmental and social practice. Auditing is also conducted to ensurethat the ESMP is implemented in an effective manner, and to review and update the ESMP, environmentaland social management plans, procedures and monitoring programs.

Roy Hill has a developed a Roy Hill Environmental Compliance Audit Schedule (100RH-0000-EN-SCH-2007) toaudit PMC and Roy Hill contractors. The Roy Hill Environmental Auditing Guideline (100RH-0000-EN-GUI-2011) outlines the process for conducting and reporting on environmental audits.

14.2 Independent reviewRoy Hill has technical experts that operate independently from site based personnel. The role of theseexperts amongst other responsibilities is to conduct independent reviews and audits of environmental andsocial management practices and to undertake an annual review of the Roy Hill ESMP.

These experts include Environmental, Industrial Relations, Health and Safety, Heritage and Human Resourcespersonnel.

The Roy Hill ESMP will be subject to periodic review (not greater than 12 months) and, if required, will beamended to reflect changes in Project requirements, to correct disparities identified during audit and reviewprocess and ensure consistency with conditions of approvals.

The review of the ESMP will take into account the results of the Stakeholder and Community ConsultationPlan and will form the principle process for identifying social risks and impacts of the Project.

14.3 Primary Producer Supply chain reviewRoy Hill is committed to ensuring that Contractors and Suppliers engaged on the Project operate inaccordance with the Environmental and Social Standards outlined in this ESMP. Integrated ManagementStandard STD0009- Supplier and Contractor Management Standard ensures a contractually enforceableframework for a contractor or supplier exists in line with organisational and legal requirements andstandards.




The Roy Hill Project Tender process pre qualifies Contractors and Suppliers to ensure that theirenvironmental and social (including health and safety, human resource and industrial relationsmanagement) standards are consistent with and align to Roy Hill PPR and standards. This requirement isreinforced through clauses in final contracts issued between Roy Hill and Contractors. Roy Hill only engagesreputable suppliers.

Contractors are also required to commit to identifying and offering local procurement and indigenousemployment and business opportunities

Roy Hill contracts will require Contractors to declare that they are compliant with the Environmental andSocial Standards outlined in this ESMP.




15 Control of RecordsDocument control and record keeping procedures are aligned with the overarching Environmental andSocial Management framework

IFC Performance Standards and EP Requirements Guide



IFC1 (IFC1.1) – Environmental and social management systems

ISO14001:2004

15.1 Document control systemRoy Hill has developed the Systems Documentation and Document Control Standard (000RH-0000-RH-STD-011). Environmental and social management documents are created in accordance with the Roy HillDocument Control Procedure (100RH-0000-PM-PRO-2005).

All Roy Hill documents are subject to internal squad review through the electronic Document ControlSystem.

All final versions of documents are submitted to the Document Control Department who assign a uniqueidentification number to each document, version control all documents and file all documents in the RoyHill DMS. A transmittal receipt is issued by the Document Control Team to the relevant departmentresponsible for the document.

Roy Hill documents are electronically available to all personnel in the Roy Hill DMS.

DMS contains all procedures, registers, approvals and guidelines that make up the Roy Hill Environmentaland Social Management System.

All documents required to be submitted by Contractors under their contract are submitted and recorded bythe Roy Hill Document Control Team in the same way.

General Managers and Managers are responsible for ensuring that all documents relevant to their area ofresponsibility are managed in accordance with document control procedures.

15.2 Retention timesRetention periods of environmental and social management documents have been identified in accordancewith regulatory requirements and leading industry practices.

Environmental and social records are retained in accordance with the Roy Hill Record and DocumentationProcedure (100RH-0000-PM-PRO-2005).

15.3 Access to documentsRoy Hill and PMC personnel have access to applicable environmental and social documents through DMS,while contractors and others working on behalf of Roy Hill obtain access to applicable environmentaldocuments through the Roy Hill PPR and Roy Hill Document Control process.




16 Action PlanIFC Performance Standards and EP Requirements Guide


EP4 (EP4.1, 4.2) – Environmental and social management system and equator principles action plan.

IFC1 (IFC1.1) – Environmental and social management systems.

Actions that have been identified that require implementation to ensure compliance with environmentalstandards are outlined in Table 16-1. The plans and procedures outlined below will be prepared inaccordance with the operational readiness schedule prior to the timeframe within which they are required.

Table 16-1: Action Plan

Action ID Action Status Relevant sectionEP, IFCPerformanceStandard

1 Develop and Implement of OperationalEnvironmental Management Plans for Mine, Portand Rail that include management, monitoring andcontingency actions relevant to the operation phaseof the Project.

Complete 8.2 EP1, 2, 3, 4, 5,10, IFC1, 3, 4,6, 7, 8

2. Develop and Implement a Stakeholder andCommunity Consultation Plan that includesmonitoring and auditing of compliance with thePlan.

Complete 13 EP5

3. Develop and Implement a Supply Chain Procedure. Complete 14 EP3, 10IFC2, 6

4. Develop and Implement Operational HSESPerformance and Management Standards.

Complete 8.3 IFC1, 4EP3EHSG 2, 3, 4




Appendix 1: EPA objectives for relevant environmental factors (EPA,2013)




Theme Factor EPA Objective Project description

Land Flora andvegetation

To maintain representation,diversity, viability andecological function at a species,population and communitylevel.

The Project will require the total clearing of up to 18 375 ha ofnative vegetation across mine, port and rail. Progressiverehabilitation will occur across all project sites to facilitateongoing regeneration of vegetation throughout the life of theProject.

Land Terrestrialfauna

To maintain representation,diversity, viability andecological function at thespecies, population andassemblage level.

Development of the Roy Hill Project will result in the loss offauna habitat within the mine, port and rail Project areas.Progressive rehabilitation will occur across all Project sites tofacilitate ongoing restoration of fauna habitat throughout thelife of the Project.

MarineBenthiccommunitiesand habitat

To maintain the structure,function, diversity, distributionand viability of benthiccommunities and habitats atlocal and regional scales.

A limited area of mudflat including a small area ofcyanobacterial mats will be disturbed for the establishment ofport infrastructure. Environmental guidelines and compliancerequirements apply to contractors to minimise disturbance andmaximise opportunities for mudflat recovery.

Marine CoastalProcesses

To maintain the morphology ofthe subtidal, intertidal andsupratidal zones and the localgeophysical processes thatshape them.

The Port Hedland harbour topography varies from open harbourto tidal creeks, intertidal mudflats, bare coastal mudflats andsandy lowlands. It includes a dredged channel, 20 nautical milesin length leading to a dredged basin between Nelson Point andFinucane Island. Several intertidal creeks converge in theharbour. The harbour is already substantially modified bydevelopment and operation of the port. The berths that formpart of the Project are located adjacent to the existingdeveloped port area at the mouth of South West Creek. TheProject is unlikely to significantly impact tidal flows, given theelevation of the conveyor over South West Creek diversion.Temporary restriction of tidal flows will occur in association withthe construction causeway for the overland conveyor. Thewharf structure may slightly alter tidal flows.

Water Hydrologicalprocesses

To maintain the hydrologicalregimes of groundwater andsurface water so that existingand potential uses, includingecosystem maintenance, areprotected

The majority of the economic mineral ore deposit resides belowthe water table and the effective management and abstractionof groundwater from the mining pits is critical to economicproduct recovery. Groundwater will also be abstracted for useduring construction, and for water supply to the camps.

WaterInland WatersEnvironmentalQuality

To maintain the quality ofgroundwater and surfacewater, sediment and biota sothat the environmental values,both ecological and social, aremaintained.

The Pilbara is characterised by intermittent, ephemeral surfacewater flows; occurring within the Project Area. The creekstraversing the Mine area are dry for most of the year and onlycollect water from the foothills of the Chichester Range duringstorm events. Rain causing runoff intermittently occurs duringthe warmer months (November to May). The impact ofdisturbance during a rainfall event will be mitigated by themaintenance of flows through the landscape by use of culvertsor floodways or the temporary diversion of creeks arounddisturbance areas to maintain flows into downstreamcatchments including Fortescue River and Marsh.

People HeritageTo ensure that historical andcultural associations are notadversely affected.

The Project intersects the boundaries of three registered NativeTitle claims: the Kariyarra, Palyku and Nyiyaparli. Roy Hill hasreached agreement with each of these Native Title claimantsunder the Native Title Act 1993 to use the land for port, mineand rail purposes. Applications to disturb known Aboriginalheritage sites over the Project footprint have been submitted tothe Department of Aboriginal Affairs and State Governmentapproval has been obtained for the mine, port and rail areas.




Theme Factor EPA Objective Project description

People AmenityTo ensure that impacts toamenity are reduced as low asreasonably practicable

Background night time noise at sensitive receptors in PortHedland and surrounds currently exceed the EnvironmentalProtection (Noise) Regulations 1997. The Port infrastructure forthis Project will contribute additional noise sources. Operationalnoise emissions from the Port are predicted to comply withRegulations and State Planning Policy 5.4. Construction noiseemissions will be managed through the CECR.

Air

Air quality(Dust;Greenhousegas)

To maintain air quality for theprotection of the environmentand human health andamenity.

Dust may be generated as a result of the following Projectactivities: clearing and construction activities including blasting; stockpiles; crushing and screening operations; and vehicle movements.Generation of gaseous emissions will occur through the burningof hydrocarbon fuel in power generation, mobile and fixed plantand vehicles and from the decay of cleared vegetation.

Integratingfactor

Rehabilitationand closure

To ensure that premises areclosed, decommissioned andrehabilitated in an ecologicallysustainable manner, consistentwith agreed outcomes and landuses, and without unacceptableliability to the State.

A conceptual closure and rehabilitation management plan wasprepared for the environmental assessment process. This isnow referred to as the Preliminary Rehabilitation and ClosurePlan. This Plan and its revisions will form the basis of the FinalDecommissioning and Closure Plan for the Project.




Appendix 2: Material environmental and social permits relating to theProject

Material Authorisations as at 22 April 2014 page 1

SCHEDULE 1

MATERIAL AUTHORISATIONS

PART 1

GLOSSARY

The schedule set out below contains a list of all Material Authorisations relating to the Project Facilities

In this Schedule:

Aboriginal Heritage Act means the Aboriginal Heritage Act 1972 (WA)

Dangerous Goods Safety Act means the Dangerous Goods Safety Act 2004 (WA)

DEC means the Department of Environment and Conservation (now DER)

DoE means Department of Environment (formerly DSEWPaC).

Department of Health or DoH means the Department of Health Western Australia

DER means the Department of Environmental Regulation (formerly DEC)

DAA means Department of Aboriginal Affairs.

DMP means Department of Mines and Petroleum.

DoL means Department of Lands

DoW means Department of Water.

DSD means Department of State Development

DSEWPac means the Commonwealth Department of Sustainability, Environment, Water, Populations and

Communities. (now DoE)

EPBC Act means the Environmental Protection and Biodiversity Conservation Act 1999 (Cth).

Environmental Protection Act means Environmental Protection Act 1986 (WA).

EPA means the Environmental Protection Authority of Western Australia

HPPL means Hancock Prospecting Pty Ltd ACN 008 676 417.

Land Administration Act means the Land Administration Act 1997 (WA).

MRWA means Main Roads Western Australia.

Mining Act means Mining Act 1978 (WA).

MS means Ministerial Statement.

OEPA means Office of the Environmental Protection Authority

PHPA means Port Hedland Port Authority (now PPA).

Planning and Development Act means the Planning and Development Act 2005 (WA)

PPA means Pilbara Ports Authority

RDL means Regional Development and Lands (now DoL).

RHH means Roy Hill Holdings Pty Limited CAN 123 721 077

RHI means Roy Hill Infrastructure Pty Ltd ACN 130 249 633.

RHIO means Roy Hill Iron Ore Pty Ltd ACN 123 722 038.

RIWA means Rights in Water and Irrigation Act 1914 (WA).

SRL means Special Railway Licence.

Wildlife Conservation Act means the Wildlife Conservation Act 1950 (WA)

Note: We have highlighted in green those Material Authorisations and Specified Material Authorisations that are pending. A column has been added explaining the current status of each authorisation and/or report.



PART 2

MATERIAL AUTHORISATIONS

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PURPOSE COMMENC

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EXPIRES REPORTING REQUIREMENTS Report on status as at 21

April 2015i

1. PORT FACILITIES

1.1 Approvals required under Part IV of the Environmental Protection Act - (Ministerial Statements)

RHI Port Port Lease and

Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Project

constructio

n and

implementa

tion

EPA MS 858 Construct and operate port

infrastructure which includes

Port Ore Handling Facility

Stockyard, Rail Loop,

Elevated Overland Conveyor

and South West Creek Berths

within Port Hedland Inner

Harbour.

11 March

2011

End of

project (20+

years)

Annual Compliance Assessment

Report submitted to OEPA

This report is required to be

provided on 23 March each

year.

The report covering the 2014

reporting period was

provided to the OEPA before

the due date (March

2015).Approval remains

current.


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Ground

Disturbance

EPA MS 858 section

45C approval

(Attachment 1)

Approval to change the

proposal under section 45c of

the Environmental Protection

Act – to increase the area of

ground disturbance and

terrestrial vegetation

clearance from 370 ha to 382

ha

17

December

2012

End of

project (20+

years)





year.




the due date (March


current.


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Ground

Disturbance

EPA MS 858 section

45C approval

(Attachment 1)

Approval to change the

proposal under section 45c of

the Environmental Protection

Act to allow discharge of car

dumper hyper saline dewater

into the Roy Hill shipping

berths in South West Creek.

20 February

2014

End of

project (20+

years)





year.




the due date (March


current.


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PURPOSE COMMENC

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April 2015i

1.2 Works Approvals required under Part V of the Environmental Protection Act


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Pollution

prevention

DER Works Approval -

W5396-2013-1

for the Port Ore

Handling Facility

and Screening

Plant

Approval for construction of

Port ore handling and storage

of loading of ore, including

crushing and screening and

ship loading facility

Commence

ment of

constructio

n of facility

Commission

ing approval

granted by

DER

Construction/Commissioning

Audit Report to DER

This report is due upon

completion of construction.

A separate report will be

provided after

commissioning of the works.


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Pollution

prevention

DER Works Approval -

W5396-2013-1

for the Port Ore

Handling Facility

and Screening

Plant

Amendment to Works

Approval to allow discharge

of car dumper hyper saline

dewater into the Roy Hill

shipping berths in South

West Creek

23

September

2013

22

September

2016

Construction/ Commissioning

Audit Report to DER


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Pollution

prevention

DER Works Approval

for Temporary

Port Power

Station

Approval for construction of

a Temporary Power Station

8

September

2014

8

September

2017

Construction/ Commissioning

Audit Report to DER

A construction report has

been provided to DER prior

to commissioning

commencing.


provided after


Approval remains current.

1.3 Operating Licence required under Part V of the Environmental Protection Act


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Pollution

prevention

DER Operating Licence

for the operation

of the Port Ore

Handling Facility

and Screening

Plant.

Approval for operation of the

bulk ore handling and storage

of loading of ore, including

crushing and screening

Approval

will be

issued

following

commission

ing of the

Port Ore

Handling

Facility and

Screening

Plant

End of

project (20+

years)

Annual report to DER required

once the Operating Licence has

been granted.

The application for the

Operating Licence will be

made during the

commissioning period.


LICENS

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BY:

LICENCE/APPROV

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PURPOSE COMMENC

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April 2015i


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Pollution

prevention


for Temporary

Port Power

Station

Approval for operation of the

Temporary Power Station

Approval

will be

issued

following

commission

ing of the

power

station

Five years Annual report to DER required

once the Operating Licence has

been granted.

The application for the

Operating Licence will be

made during the

commissioning period.

1.4 Licences to take Groundwater under Section 5C of the Rights in Water and Irrigation Act

RHI Port SRL L4SA Groundwat

er

abstraction

DoW 5C groundwater

abstraction

licence -

GWL176004(1)

Dust suppression for

industrial purposes, railway

construction and

maintenance (Annual water

entitlement: 100,000kL)

31 August

2012

30 August

2017

Annual Report to DoW

required to be provided by 31

October each year.

Licence remains current.

RHH submitted the report on

31 October 2014 to the DoW.


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Groundwat

er

abstraction

DoW 5C groundwater

abstraction

licence

GWL175984(2)

Abstraction of 2,300,000 kl

pa for the purpose of

Dewatering for Construction

purposes

26 July 2013 24 July 2015 Annual Report to DoW


October each year.




1.5 Mining Tenure required under the Mining Act

RHI Port Port conveyor Tenure DMP L45/277 Construction and

maintenance of bridge,

communications facility,

conveyor system, pipeline,

power line and a road

30 April

2012

29 April

2033

An annual environmental

report is required under the

conditions under which this

mining tenement was issued.

The Annual Environmental

Report for 2014 was lodged

with the DMP in March

2015.

Tenure remains current.

2. RAIL FACILITIES

2.1 Railway (Roy Hill Infrastructure Pty Ltd) Agreement Act 2010

RHI SRL Miscellaneous

Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Tenure Premier Railway (Roy Hill

Infrastructure Pty

Ltd) Agreement

Act 2010

State Agreement 5 July 2011 4 July 2041 RHI is required to advise of any

change to a proposal. Note the

approval to the revised

proposal dated 13 February

Lease remains current.


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LICENCE/APPROV

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PURPOSE COMMENC

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April 2015i

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

2014.


Lease 4SA

Project

constructio

n and

implementa

tion

Premier Railway (Roy Hill

Infrastructure Pty

Ltd) Agreement

Act 2010

Approval of proposal under

clause 10 of the Railway

Agreement

30 June

2011

Term of

Railway

Agreement



Lease 4SA

Project

constructio

n and

implementa

tion


Infrastructure Pty

Ltd) Agreement

Act 2010

Approval of revised proposals

under clause 10 of the

Railway Agreement

7 October

2011

Term of

Railway

Agreement



Lease 4SA

Project

constructio

n and

implementa

tion


Infrastructure Pty

Ltd) Agreement

Act 2010

Approval of revised proposals

under clause 10 of the

Railway Agreement indicating

First Ore on Ship to occur in

2015.

13 February

2014

Term of

Railway

Agreement



RHI Rail Miscellaneous

Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Project

constructio

n and

implementa

tion

EPA MS 847 Construct and operate a

railway of approximately. 320

km length and associated

infrastructure

29

November

2010

End of

project (20+

years)



One report is required to be

provided for each Ministerial

Statement. The report

required to be provided on 23

March each year.




the due date (March


current.


Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Project

constructio

n and

implementa

tion

EPA MS 847 - section

45C Approval

2011/000192

Attachment 1 of MS847:

Change to Rail Corridor

Alignment (Bonney Downs

Rail Alignment)

20 May

2011

End of

project (20+

years)

This is an amendment to MS

847.



LICENS

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BY:

LICENCE/APPROV

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PURPOSE COMMENC

ES


April 2015i

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland


Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Project

constructio

n and

implementa

tion

EPA MS 864 -amends

conditions

applying to

MS847

MS which amends conditions

applying to MS847:

Amendment of condition 5-1

of MS847 to include the

Bonney Downs Rail

Alignment

2 June 2011 End of

project (20+

years)





Statement. The report

required to be provided on 23

March each year.




the due date (March


current.


Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Project

constructio

n and

implementa

tion

EPA MS 847 OEPA ref:

2010/000752-1

(A404252)

Final rail alignment based on

biological and heritage

survey data

7

September

2011

End of

project (20+

years)

This approval relates to an

amendment to MS 847.



Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Project

constructio

n and

implementa

tion

EPA MS 847 - OEPA

ref: 2011/000564

Final rail alignment based on

biological and heritage

survey data

4 October

2011

End of

project (20+

years)





Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Project

constructio

n and

implementa

EPA Section 45C to MS

847

Include a Lateral Access Road

into the project description

10 May

2013

2018 This approval relates to an




LICENS

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BY:

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PURPOSE COMMENC

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April 2015i

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

tion


Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Project

constructio

n and

implementa

tion

EPA Section 45C to MS

847

Increase in area of

disturbance for construction

to 7,400 ha

28 Nov

2013

End of

constructio

n of railway




2.3 Approvals required under the Environmental Protection and Biodiversity Conservation Act


Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Project

constructio

n and

implementa

tion

DoE

(formerly

DSEWPaC

)

EPBC 2010/5424 Construction and operation

of a heavy-haul standard

gauge railway line

approximately. 320 km long

from the Roy Hill 1 Mine to

Port Hedland, in the Pilbara

region of WA and

construction of support

infrastructure

23

November

2010

1 December

2030

Annual Reporting of financial

contribution to the trust fund

set up for contribution to

research must be provided to

DoE.

Annual (or other) Reporting as

stipulated in the Final Rail

Alignment Plan, Fauna

Management Plan, and

Threatened Fauna Offset plan

and any subsequent revisions

DOE can request an audit at

any time of all records

substantiating to all activities

associated with measures

taken to implement the Final

Rail Alignment Plan, Fauna

Management Plan, and

Threatened Fauna Offset plan

The annual report under the

Fauna Management Plan is

required to be lodged by 31

July each year.


Fauna Management Plan was

lodged on 29 July 2014.


Threatened Fauna Offset

Plan is required to be

submitted by 17 April each

year.

The annual report required

to be lodged by 17 April was

lodged prior to that date (24

March 2015).

The only reporting under the

Final Rail Alignment Plan is

the provision of confirmation


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April 2015i

and any subsequent revisions and evidence to DoE within

30 days of the completion of

the construction of fauna

friendly culverts.



Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Project

constructio

n and

implementa

tion

DoE

(formerly

DSEWPaC

)

EPBC 2011/5867 Construction and operation

of Bonney Downs Rail

Alignment & Associated

Infrastructure to transport

iron ore from the Roy Hill

mine to Port Hedland

20 May

2011

1 December

2032

Annual Reporting as stipulated

in the Final Rail Alignment Plan,

Northern Quall Research Plan,

and Fauna Management Plan

and any subsequent revisions

DoE can request an audit at any

time of all records

substantiating to all activities

associated with measures

taken to implement the Final

Rail Alignment Plan, Northern

Quall Research Plan, and Fauna

Management Plan and any

subsequent revisions


Fauna Management Plan is

required to be lodged by 31

July each year.


Fauna Management Plan was

lodged on 29 July 2014.

The first annual report under

the Northern Quoll Research

Plan was submitted by 30

March 2015.

The only reporting under the

Final Rail Alignment Plan is

the provision of confirmation

and evidence to DoE within

30 days of the completion of

the construction of fauna

friendly culverts.




Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Tenure DMP Miscellaneous

Licence 4SA

(AL70/4)

Construct, operate and

maintain the rail line

5 July 2011 4 July 2041 No reporting requirements Lease remains current.


LICENS

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PURPOSE COMMENC

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April 2015i

Town of Port

Hedland


Lease 4SA

Area of

tenement

Director

General,

DMP

Railway (Roy Hill

Infrastructure Pty

Ltd) Agreement

Act 2010

Approval of additional area

designated as File Notation

Area 9848 displayed on the

DMP Tengraph electronic

mapping system.

7 October

2011

Term of

Railway

Agreement

No reporting requirements Lease remains current.


Lease 6SA Lateral

Access Road to

SRL Town of Port

Hedland

Tenure DMP Miscellaneous

Licence 6SA

Lateral Access Road to SRL 25

September

2013

25

September

2017

No reporting requirements Lease remains current.

2.5 Licences to Take Groundwater under Section 5C of the Rights in Water and Irrigation Act


Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Groundwat

er

abstraction

DoW 5C Groundwater

Abstraction

Licence -

GWL178460(1)

Abstraction of 200,000 kl/pa

for rail construction

27 Nov

2013

26 Nov

2015



October each year.





Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Groundwat

er

abstraction

DoW 5C Groundwater

Abstraction

Licence -

GWL176892(1)

Abstraction of 4,000,000

kl/pa for rail construction

11 Sep 2013 10 Sep 2023 Annual Report to DoW


October 2014 each year.





Lease 4SA -

AL70/4 - Roy Hill

Groundwat

er

abstraction

DoW 5C Groundwater

Abstraction

Licence -



11 Sep 2013 10 Sep 2023 Annual Report to DoW


October each year.





LICENS

EE(S)

SITE LOCATION/TENU

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ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

GWL176893(1)


Lease 4SA -

AL70/4 - Roy Hill

Infrastructure

Railway, Shire of

Ashburton, Shire

of East Pilbara,

Town of Port

Hedland

Groundwat

er

abstraction

DoW 5C Groundwater

Abstraction

Licence -

GWL176893(2)



5 March

2014

10

September

2023



October each year.




2.6 Approvals required under the Aboriginal Heritage Act

RHI Rail Section 18 Notice

over Bonney

Downs Rail and

Mine Loop

Heritage DAA Section 18

Bonney Downs

Rail and Mine

Loop

Disturbance of aboriginal

heritage sites as listed in the

approval

16

December

2011

For life of

mine

project

As the salvage of heritage

materials has been completed

and a final report submitted to

the DAA, no further reporting

will be required unless

requested by DAA.



over Port Rail

Loop and

Infrastructure

Heritage DAA Section 18 Port

Rail Loop and

Infrastructure



approval

5 December

2011

For life of

mine

project






requested by DAA.



over L 4SA

chainage 220-265

Heritage DAA Section 18 Ch

220-265 Palyku



approval

24 January

2012

For life of

mine

project






requested by DAA.



LICENS

EE(S)

SITE LOCATION/TENU

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ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i


over L 4SA

chainage 25-110

Heritage DAA Section 18 Ch 25-

110 Kariyarra



approval

24 January

2012

For life of

mine

project






requested by DAA.



over L 4SA

chainage 110-136


110-136



approval

23 March

2012

For life of

mine

project






requested by DAA.



of L 4SA

(Kariyarra)

chainage 136-165


136-165



approval

8 May 2012 For life of

mine

project






requested by DAA.


2.7 Rail Accreditation Approvals

RHI Rail Roy Hill Railway Safety

requiremen

ts

Office of

Rail

Safety

Notice of Railway

Accreditation -

RH1-001-30-SR-

PER-0960 (18

November 2010)

Phase 1 of the railway

development covers the

planning, design and

construction of earthworks,

drainage, culverts, bridges

and structures (including

service works, crossings,

construction communication

infrastructure and cable

routes) to the sub ballast

capping level of the railway

alignment as described in

RHI's Accreditation

Application Form lodged 16

September. Accreditation is

approved subject to the

18

November

2010

Completion

of Phase 1

of railway

developme

nt

Completion of Phase 1 of

railway development



LICENS

EE(S)

SITE LOCATION/TENU

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BY:

LICENCE/APPROV

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PURPOSE COMMENC

ES


April 2015i

conditions set out in the

schedule below.

RHI Rail Roy Hill Railway Safety

requiremen

ts

Office of

Rail

Safety

Notice of Railway

Accreditation

(Amended 20

December 2012)

for Roy Hill

Infrastructure –

Correspondence

Ref –

DT/10/01591

Civil and rail infrastructure

construction works

This phase of the project will

involve the operation of track

work machines, rolling stock

for transport of construction

materials and field testing

and commissioning of the

signals and communications

systems, and associated rail

safe working procedures.

20

December

2012

Completion

of Phase 2

of railway

developme

nt

Completion of Phase 2 of

railway development


RHI Rail Roy Hill Rail Safety

requiremen

ts

Office of

Rail

Safety

Safety operating

approval

Full track commissioning and

commencement of the rail

infrastructure for operational

use

Not yet

applied

for/granted

Ongoing To be determined. This report was submitted on

2 October 2014 to the Office

of Rail Safety.

3. MINE FACILITIES


RHIO Mine

Stage 1

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Project

constructio

n and

implementa

tion

EPA MS 824 Mine iron ore from the Stage

1 project area on the

southern slopes of the

Chichester Range and

develop associated mining

infrastructure

22

December

2009

End of

project (20+

years)


Report to OEPA.



Statement.

The report required to be


year.




the due date (March 2015).


RHIO Mine

Stage 1

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Project

constructio

n and

implementa

tion

EPA Attachment 1 of

MS824: Revised

alignment of

Marble Bar Road -

To allow the diversion of the

existing Marble Bar Road

around mining areas.

15

December

2010

End of

project (20+

years)

This relates to an amendment

to MS 824.



LICENS

EE(S)

SITE LOCATION/TENU

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ASPECT ISSUED

BY:

LICENCE/APPROV

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PURPOSE COMMENC

ES


April 2015i

Mining Leases

M46/518 and

M46/519

RHIO Mine

Stage 1

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Project

constructio

n and

implementa

tion

EPA Attachment 2 of

MS824

To allow changes to mining

schedule, location of key

infrastructure, groundwater

drawdown figure and

coordinates -

3 February

2012

End of

project (20+

years)


to MS 824.


RHIO Mine

Stage 1

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Ground

Disturbance

EPA MS 902 – amends

conditions

applying to

MS824

Condition 9 of MS824

deleted and replaced; and

Schedule 3 and Figure 8 of

MS824 are deleted

4 July 2012 End of

project (20+

years)


to MS 824.


RHIO Mine

Stage 1

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Project

Infrastructu

re footprint

EPA Letter dated 18

July 2013

confirming that

the amendments

to the TSF and

Evaporation Pond

do not constitute

a change in

proposal and

therefore s.45C

approval not

required

No change to proposal 18 July 2013 End of

project (20+

years)

This relates to MS 824. Approval remains current.

RHIO Mine

Stage 1

Roy Hill Iron Ore

Mining Project

Project

Infrastructu

EPA MS 979 condition

7-1 of MS 824

To allow changes to surface

water diversion structures

19 August

2014

End of

project (20+

This relates to MS 824 Approval remains current.


LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

re footprint years) T

RHIO Mine

Stage 2

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Project

constructio

n and

implementa

tion

EPA MS 829 Mine iron ore from the Stage

2 project area on the

southern slopes of the

Chichester Range and

develop a remote borefield

and pipeline

31 March

2010

End of

project (20+

years)



Statement.

The report required to be


year.




the due date (March

2015).date. Approval remains

current.

RHIO Mine

Stage 2

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Project

constructio

n and

implementa

tion

EPA MS 829 - section

45C Approval

2011/000970:A45

0735

Attachment 1 of MS829:

Change to mining schedule,

location of key infrastructure,

groundwater drawdown

figure and coordinates

3 February

2012

End of

project (20+

years)


to MS 829.


RHIO Mine

Stage 2

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Project

Infrastructu

re footprint

EPA MS980 amend

condition 9-1 of

MS 829

To allow changes to surface

water diversion structures

19 August

2014

End of

project (20+

years)


to MS 829.



LICENS

EE(S)

SITE LOCATION/TENU

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ASPECT ISSUED

BY:

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PURPOSE COMMENC

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April 2015i


RHI Mine Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Pollution

prevention

DER Works Approval

W5067/2011/1

Approval for construction Mine Processing Plant and Tailings Storage Facility Amendment to works approval W5067/2011/1 to include commissioning of Mine Process Plant (Process Plant) and Tailings Storage Facility (TSF) during construction phase of the Process Plant and TSF

Commence

ment of

constructio

n of facility

This

approval

was granted

on 11 June

2012.

On

constructio

n

/commissio

ning of

facility

This

approval

expires on

10 June

2016.

Construction Audit,

Commissioning Plan and

Commissioning Report


3.3 Operating Licence required under Part V of the Environmental Protection Act

RHIO Mine Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Pollution

prevention

DEC Operating Licence

for Operation of

Mine Processing

Plant and Tailings

Storage Facility –

not yet granted

Approval for operation of

Mine Processing Plant and

Tailings Storage Facility

Amended in Q1 2015 to

include:

By letter dated 5 February 2015, DER issued RHIO an enhanced Licence which records the grant of the following:

(a) Category 57 has been added to the Licence to allow storage of tyres prior to their disposal in landfill;

(b) Category 89 landfill has been reclassified under Category 64 and the production and design capacity has been increased to

Not

submitted –

this will be

submitted

when these

facilities are

constructio

n and

commission

ed

End of

project (20+

years)

Annual Environmental Report


March each year.

The report required be lodged

this year was lodged before the

due date.

The current Operating

Licence is for the waste water

treatment plant, landfill and

crushing and screening

required in connection with

construction. Amendments

to the existing licence will be

sought when the Processing

Plant and the Tailings Storage

Facility have been

completed.



LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

8,000 tonnes per year; and

(c) a portion of the land the subject of the licenced area has been excised to allow Samsung C&T to operate a small waste water treatment plant and spray field (facility) to be constructed by Samsung. The facility will be built, owned and operated by Samsung and is required for Samsung’s expansion of the Roy Hill Mine accommodation village.

3.4 Mining Proposals required under the Mining Act


Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Enabling

Infrastructu

re and

Drilling

DMP Mining Proposal -

Enabling

Infrastructure and

Drilling,

Registration ID

29314

Construction of enabling

infrastructure and associated

drilling geotechnical work

24 March

2011

Until

project

completion

Annual environmental report

required to be provided to

DMP under the conditions

under which the mining

tenement was granted.


provided by 30 March each

year.

An extension was granted by

the DMP for the provision of

this report. The report has

been submitted in April 2015

for the 2014 reporting

period.

Proposal remains current.


Mining Project

Stage 1, 110

Enabling

Infrastructu

re and


Enabling

Infrastructure and

Construction of enabling

infrastructure and associated

drilling geotechnical work

24 August

2011

Until

project

completion

See first item under this

paragraph 3.4.

This item refers to the 1st

Addendum to the Proposal.



LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Drilling Drilling 1st

Addendum,

Registration ID

31578

paragraph 3.4.



Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Enabling

Infrastructu

re and

Drilling


Enabling

Infrastructure and

Drilling 2nd

Addendum,

Registration ID

33184

Addendum to Mining

Proposal (Reg ID 31578) -

enabling Infrastructure and

Drilling on Mining Lease

46/518 and 46/519

23 January

2012

Until

project

completion


paragraph 3.4.

This item refers to the 2nd



paragraph 3.4.



Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Enabling

Infrastructu

re and

Drilling


Enabling

Infrastructure and

Drilling 3rd

Addendum,

Registration ID

34170

Camp Relocation and Access

Road

18 April

2012

Until

project

completion


paragraph 3.4.

This item refers to the 3rd



paragraph 3.4.



Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Enabling

Infrastructu

re and

Drilling


Enabling

Infrastructure and

Drilling 4th

Addendum,

Registration ID:

35396

Additional disturbance area

to the M46/518 borrow pit

target areas, north/south

access road and airport, as

well as to introduce new

disturbance areas for a

topsoil dump and surface

water management

structures associated with

the airport construction.

1 June 2012 Until

project

completion


paragraph 3.4.

This item refers to the 4th



paragraph 3.4.


RHIO Mine Roy Hill Iron Ore Mining and DMP Mining Proposal - Approval for Mining Proposal 26 July 2012 2019 (when Annual environmental report An extension was granted by


LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

Stages 1

and 2

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

associated

infrastructu

re

1 to 5 years,

Registration ID

32525

A - Mining of iron ore from

M46/518 and M46/519

year 5 mine

pits mined

out)







year.





period.



Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Mining

Infrastructu

re

DMP Mining Proposal –

Years 1 – 5, Part

B, Registration ID

37113

Mine infrastructure - Tailings

Storage Facility, Evaporation

Ponds and Kulbee Creek

31 May

2013

July 2024

(TSF)

Annual environmental report







year.






period.



Mining Project

Stage 2, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Mining and

infrastructu

re

DMP Mining

Proposal(s) – Post

Years 1-5

Approval for mining

activities, operations and

infrastructure for the period

following that the subject of

‘Mining Proposal – Years 1-5’

referred to above.

Not yet

submitted/g

ranted

This application will be made

near the end of the first five

year mining period.

3.5 Tenure required under the Mining Act

RHIO Roy Hill

Mine

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/519

Tenure -

Mine

DMP M46/519 Mine 1 November

2010

31 October

2031

The annual environmental

report is required to be

provided to DMP under the

conditions under which the

mining tenement was granted.








period.



LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

year.

RHIO Roy Hill

Mine

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518

Tenure -

Mine

DMP M 46/518 Mine 1 November

2010

31 October

2031








year.






period.


RHIO Roy Hill

remote

borefiel

d

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

L47/347

Tenure –

borefield

and Pipeline

DMP L47/347 Construction and

maintenance of a borefield,

pipeline and power line

10 August

2010

9 August

2031

The conditions under which

this tenement was issued do

not require the issue of an

annual environmental report.


RHIO Roy Hill

remote

borefiel

d

Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara -

L47/346

Tenure –

borefield

and Pipeline


maintenance of a borefield,


29 March

2012

28 March

2033








year.






period.



Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara -

L47/642

Tenure - DMP L47/642 Search for groundwater 20 February

2013

19 February

2034

The conditions under which

this tenement was issued do

not require the issue of an

annual environmental report.


3.6 Licences to Take Groundwater required under Section 5C of the Rights in Water and Irrigation Act

RHIO Mine Roy Hill Iron Ore Groundwat DoW GWL172642(3) Dewatering of 17,000,000 kl 25 July 2013 29 March Annual Aquifer Review RHH submitted the report on


LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

er

abstraction

pa for mining purposes, dust

suppression, construction,

earthworks and processing.

2025 required to be provided in

October each year.



There was an amendment to

the approval during this

quarter.

The previous allocation of 3.7 GL/a was to meet construction water supply demands only and had been in place since mid-2011.

The amendment was for an allocation increase to 17 GL/a to cover Operational water supply demand equating to a nominal 46 ML/day for process plant, mining dust suppression and village water supply use.


RHIO Mine Section 18 Notice

over M46/518

and M46/519

Heritage DAA Section 18

10/12/10



approval

10

December

2010

For life of

mine

project






requested by DAA.



over M46/518

and M46/519

Heritage DAA Section 18 Mine

Stage 2



approval

27 June

2011

For life of

mine

project







LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i


requested by DAA.


over M46/518,

M46/519 and

L4SA


Stage 3



approval

30

December

2011

For life of

mine

project






requested by DAA.


RHI Mine Section 18 Notice

over L 4SA

chainage 265 -

Mine Bonney

Downs

Heritage DAA Section 18 Ch 265

- Mine Bonney

Downs



approval

16

December

2011

For life of

mine

project






requested by DAA.



over M46/518

and M46/519


Stage 1



approval

18 April

2011

For life of

mine

project






requested by DAA.



over M46/518

and M46/519


Stage 4



approval

2 May 2012 For life of

mine

project






requested by DAA.



over M46/518

and M46/519


Stage 5



approval

30 August

2012

For life of

mine

project






requested by DAA.



over M46/518


Stage 6



25 October

2012

For life of

mine





LICENS

EE(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMENC

ES


April 2015i

and M46/519 approval project and a final report submitted to



requested by DAA.


over M46/518

and M46/519


Stage 7



approval

30 January

2013

For life of

mine

project






requested by DAA.



over M46/518

and M46/519


Stage 8



approval

11 April

2013

For life of

mine

project






requested by DAA.



PART 3

SPECIFIED MATERIAL AUTHORISATIONS

LICENSE

E(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMEN

CES


April

1. PORT FACILITIES

1.1 Development approvals required under the Port Authorities Act


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Tenure PHPA Letter dated 20

November 2013

from PHPA to RHI

granting approval

to commence

Package 3 Port

Landside Works

and Drive Station

Civil Works.

Approval to commence

Package 3 Port Landside

Works and Drive Station Civil

Works

20

Novembe

r 2013

Not

applicable

RHI is required to submit

detailed plans and

specifications to proposed

works to the PHPA and must

not undertake works in

accordance with those works

without the consent of the

PHPA. If RHI wishes to make

any change to those detailed

plans and specifications, it

must obtain PHPA’s approval of

the change.



Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Tenure PHPA Letter dated 9

January 2014

from the PHPA to

RHI granting

approval to

commence

Package 4 Port

Marine works


Package 4 Port Marine works

9 January

2014

Not

applicable

See above. Approval remains current.


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Tenure PHPA Letter to be

issued by the

PHPA to RHI

granting approval

to commence

Package 3

Structural,

Mechanical and


Package 3 Structural,

Mechanical and Piping

14 July

2014

Not

applicable



LICENSE

E(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMEN

CES


April

Piping (SMP)


Licence Lot 370

on Plan 35619,

Lot 372 on Plan

35620 and

Reserve 50892

Tenure PHPA Letter to be

issued by the

PHPA to RHI

granting approval

to commence

construction of

temporary power

station


construction of temporary

power station

13 June

2014

Not

applicable


2. RAIL FACILITIES


RHI Rail Bulk Fuel Storage-

Terminal Yard

Pollution

prevention

DER Works Approval

for Bulk Fuel

Storage and

instillation of

Waste Water

Treatment Plant

at Rail Terminal

Yard

For storage of bulk fuel

quantities and instillation of

Waste Water Treatment

Plant.

4 August

2014

3 August

2017

Works Approval Commissioning

Audit

This report is due upon

completion of construction.


provided after


The approval was received on

the 4 August 2014

Approval remains current

2.2 Operating Licences required under Part V of the Environmental Protection Act

RHI Rail

Camp 1

Rail Construction

Camp 1, located

approximately 50

km south of Port

Hedland within

SRL

Pollution

prevention


L8608/2011/1

For operation of the

Wastewater Treatment Plant

at Rail Camp 1

An amendment to the Rail

Camp 1 Operating Licence

(L8608/2011) to include the

disposal of reverse osmosis

reject water through the

existing WWTP to the spray

irrigation field.

9 July

2012

8 July 2017 The annual environmental







year.

The report required for the

2014 reporting period was

provided by the due date.



LICENSE

E(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMEN

CES


April

RHI Rail

Camp 2

Rail Construction

Camp 2, located

approximately

100 km south of

Port Hedland

within SRL

Pollution

prevention

DER Operating Licence For operation of the


at Rail Camp 2

3

Septembe

r 2012

2

September

2017








year.





RHI Rail

Camp 3

Rail Construction

Camp 3, located

approximately

160 km south of

Port Hedland

within SRL

Pollution

prevention

DER Operating Licence For operation of the


at Rail Camp 3

3

Septembe

r 2012

2

September

2017








year.





RHI Rail

Camp 4

Rail Construction

Camp 4, located

approximately

230km south of

Port Hedland

within SRL

Pollution

prevention

DER L8609/2011/1 For operation of the


at Rail Camp 4

29

October

2012

28 October

2017








year.





RHI Rail Bulk Fuel Storage-

Terminal Yard

Pollution

prevention


for Bulk Fuel

Storage at Rail

Terminal Yard

For storage of bulk fuel

quantities

Post

commissi

oning of

the Bulk

Fuel

Storage

Facility.

For the Life

of the

facility

Before the storage facility is

commissioned, an application

will be made to DER to

amend the Operating Licence

to include this storage

facility.

2.3 Dangerous Good Safety Act

RHI Rail Rail terminal yard Dangerous DMP Handling and Handling and transport of 11 11 There is a requirement under Licence remains current.


LICENSE

E(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMEN

CES


April

Goods Site

Licence –

terminal

yard

transport of

dangerous goods

dangerous goods at rail

terminal yard

Septembe

r 2014

September

2019

the Dangerous Goods Act to

review the facility for

compliance once every five

years and to decommission the

facility once every 10 years in

order to conduct a

comprehensive facility

assessment.

3. MINE FACILITIES


RHIO Mine Road to BHPB Rail

Corridor


maintenance of a road,


Applicatio

n

withdraw

8

Septembe

r 2014

N/A N/A

Identified as not required

and was withdrawn on 8

September 2014. A letter

advising of this was sent to

the Intercreditor Agent on

the 6 August 2014.

RHIO Mine Mine camp access

road

Mine DMP L46/104 Construction and

maintenance of a road

27 June

2012

27 June

2033

This tenement will be

replaced in due course by

L46/110 – see below.

RHIO Mine Mine camp access

road –

replacement for L

46/104

Mine DMP L46/110 Construction and

maintenance of a road -

replacement for L46/104

Pending RHIO submitted this

application on 13 September

2012. The grant of the

licence is subject to:

(a) the negotiation of an

access agreement with

Fortescue Metals Group

(FMG); and

(b) the Native Title

objection lodged by the


LICENSE

E(S)

SITE LOCATION/TENU

RE

ASPECT ISSUED

BY:

LICENCE/APPROV

AL DESCRIPTION

PURPOSE COMMEN

CES


April

Wunna Nyiyaparli;

people being processed.

RHIO has an agreed access

agreement with FMG. This

was finalised in March 2015.

The tenure is scheduled to be

granted well before it is

required on 31 December

2018.



over L4SA,

L46/59, E46/567,

E46/728 (part) for

Marble Bar Road

realignment

Heritage DAA Section 18 for

Marble Bar Road

realignment



approval

24

January

2012

For life of

mine

project






requested by DAA.


3.3 Programme of Work required under the Mining Act

RHI Mine Roy Hill Iron Ore

Mining Project

Stage 1, 110

Kilometres North

of Newman, Shire

of East Pilbara –

Mining Leases

M46/518 and

M46/519

Disturbance DMP 40601 Drilling investigations and

access tracks

18 Oct

2013

18 Oct 2017 The annual environmental







year.






period.


i This report contains all changes up to from 1 January 2015 to 22 April 2015




Appendix 3: Equator Principles (June 2013)




ID Principle Heading Objective Requirement Identifier RelevantSection

EP1 Review andCategorisation

To categorise Project basedon potential environmentaland social risks and impacts.

EP1 -Demonstrate Category A Status 1

EP 2 Environmental andSocial Assessment

To address relevantenvironmental and socialrisks and impacts of theProject.

EP2.1- Environmental Impact Assessment 6

EP2.2 - Social Impact Assessment (Heritage) 6, 8

EP2.3 – Greenhouse Gas (GHG) AlternativesAssessment

6, 8

EP 3 Environmental andSocial Standards

To comply with host countrylaws, regulations and permitsthat pertains toenvironmental and socialissues.

EP3.1 - Environmental Monitoring/AuditProgram

4, 6, 8, 14

EP 3.2 - Social Monitoring/Audit Program(Heritage)

4, 8, 14

EP4 Environmental andSocial ManagementSystem and EquatorPrinciples ActionPlan

To develop and maintain anEnvironmental and SocialManagement System

EP4.1 - Environmental Management Plan 8, 13, 16

EP4.2 - Social Management Plan 6, 8, 13, 16

EP5 StakeholderEngagement

To demonstrate effectiveongoing stakeholderengagement

EP5.1 - Informed Consultation andParticipation Process

6, 13

EP5.2 - Assessment DocumentationAvailability

6, 13

EP5.3 - Engagement Results 6, 13

EP5.4 - Indigenous People 6, 13

EP 6 Grievancemechanism

Establish grievancemechanisms to receive andfacilitate resolution ofconcerns and grievancesabout environmental andsocial performance

EP6 - Grievance mechanism 13

EP7 Independent review To demonstrate compliancewith Equator Principles

EP7.1 - Independent review 6

EP7.2 - Independent review of high riskimpacts

6, 14

EP 8 Covenants To incorporate covenants infinancial documentationrequiring compliance,reporting anddecommissioning

EP8.1 - Compliance Covenants (Financing) 3.0

EP8.2 - Equator Principles FinancialInstitution Reporting

14

EP8.3 - Decommissioning 3.0

EP 9 Independentmonitoring andreporting

To assess Project compliancewith Equator Principles

EP9.1 - Verification of monitoring 8, 14

EP9.2 - Verification of Independentmonitoring

8, 14

EP 10 Reporting andtransparency

To demonstrate compliancewith client reportingrequirements

EP10.1 - Reporting and transparency 6

EP10.2 - Reporting of GHG emissions 4

To comply with EPFIreporting requirements

EP10.3 - EPFI Reporting 8, 13, 14, 15

Source: Equator Principles Association (June 2013)




Appendix 4: IFC Performance Standards (January 2012)




Heading Objectives Requirement identifier RelevantSection

IFC1 Assessment andManagement ofEnvironmentaland Social Risks

To identify and evaluate environmentaland social risks and impacts of theProject

To adopt a mitigation hierarchy toanticipate and avoid, or where avoidanceis not possible, minimise, and, whereresidual impacts remain,compensate/offset for risks and impactsto works, Affected Communities, and theenvironment

To promote improved environmentaland social performance of clientsthrough the effective use ofmanagement systems

To ensure that grievances from AffectedCommunities and externalcommunications from otherstakeholders are responded to andmanaged appropriately.

IFC1.1 - Environmental and SocialManagement System(ESMS)

6, 8, 9, 10, 12,15, 16

IFC1.2 - Environmental and SocialPolicy

8

IFC1.3 - Environmental and SocialAssessment

6

IFC1.4 - Environmental and SocialManagement Program

8

IFC1.5 - ESMS OrganisationalStructure

7, 11

IFC1.6 - Emergency ResponseSystems

8, 9, 10

IFC1.7 - Monitoring and review 8, 14

IFC1.8 - Stakeholder EngagementPlan

13

IFC1.9 - External communication -Grievance Mechanism

13

IFC1.10 - Ongoing project progressreports to affected communities

13

IFC2 Labour andworkingconditions

To promote fair treatment, non-discrimination, and equal opportunity ofworkers

To establish, maintain, and improve theworker-management relationship

To promote compliance with nationalemployment and labour laws

To protect workers, including vulnerablecategories of workers such as children,migrant workers, workers engaged bythird parties, and workers in the client'ssupply chain

To promote safe and healthy workingconditions, and the health of workers

To avoid the use of forced labour.

IFC2.1 - Working conditions andmanagement of workerrelationships

8

IFC2.2 - Child and forced labour 8

IFC2.3 - Occupational Health andSafety

8

IFC2.4 - Conditions for workersengaged by third parties

8

IFC2.5 - Child and forced labour -contractors

8

IFC3 ResourceEfficiency andPollutionPrevention

To avoid or minimise adverse impacts onhuman health and the environment byavoiding or minimising pollution fromproject activities

To promote a more sustainable use ofresources, including water and energy

To reduce project-related GHGemissions.

IFC3.1 - Resource efficiency andpollution prevention

6, 8

IFC3.1 - GHG Reporting 6, 8

IFC3.2 - Pollution Prevention 6, 8

IFC3.3 - Waste Management 6, 8

IFC3.4 - Pesticide use andmanagement

6, 8

IFC4 Community,Health, Safetyand Security

To anticipate and avoid adverse impactson the health and safety of the AffectedCommunity during the project life fromboth routine and non-routinecircumstances

To ensure that the safeguarding ofpersonnel and property is carried out inaccordance with relevant human rightprinciples and in a manner that avoids or

IFC4.1 - Community health andsafety

6, 8

IFC4-2 - Engagement of securitypersonnel

8





minimises risks to the AffectedCommunities.

IFC5 Land acquisitionand involuntaryresettlement

To avoid, and when avoidance is notpossible, minimise displacement byexploring alternative project designs

To avoid forced eviction To anticipate and avoid, or where

avoidance is not possible, minimiseadverse social and economic impactsfrom land acquisition or restrictions onland use by (i) providing compensationfor loss of assets at replacement cost and(ii) ensuring that resettlement activitiesare implemented with appropriatedisclosure of information, consultation,and the informed participation of thoseaffected

To improve, or restore, the livelihoodsand standards of living of displacedpersons

To improve living conditions amongphysically displaced persons through theprovision of adequate housing withsecurity of tenure are resettlement sites.

IFC5.1 - General 5, 6

IFC5.2 - Displacement 5, 6

IFC5.3 - Private SectorResponsibilities Under Governmentmanaged resettlement

5, 6

IFC6 BiodiversityConservationand SustainableManagementLiving NaturalResources

To protect and conserve biodiversity To maintain the benefits from ecosystem

services To promote the sustainable

management of living natural resourcesthrough the adoption of practices thatintegrates conservation needs anddevelopment priorities.

IFC6.1 - Protection andconservation of biodiversity

6, 8

IFC6.2 - Management of ecosystemservices

6, 8

IFC6.3 - Weed, pathogen and feralanimal management

6, 8

IFC6.4 - Demonstrate non-primaryproduction of natural resources

6, 8

IFC6.5 - Develop systems andprocedures to ensure supply chainmeets IFC 6

6, 7, 8

IFC7 Indigenouspeople

To ensure that the development processfosters full respect for the human rights,dignity, aspirations, culture, and naturalresource-based livelihoods of IndigenousPeoples

To anticipate and avoid adverse impactsof projects on communities ofIndigenous Peoples, or when avoidanceis not possible, to minimise and/orcompensate for such impacts.

To promote sustainable developmentbenefits and opportunities forIndigenous Peoples in a culturallyappropriate manner.

To establish and maintain an ongoingrelationship based on InformedConsultation and Participation (ICP) withthe Indigenous Peoples affected by athroughout the Projects life-cycle.

IFC7.1 - Identification of IndigenousPeople

5, 8, 13

IFC7.2 - Indigenous PeopleEngagement

8, 13

IFC7.3 - Indigenous PeopleManagement Plan.

8

IFC7.4 - Circumstances requiringFPIC.

8

IFC7.5 - Mitigation andcompensation for affectedcommunities.

8

IFC7.6 - Private sectorresponsibilities where Governmentis responsible for managingindigenous peoples issues.

8





To ensure the Free, Prior, and InformedConsent (FPIC) of the AffectedCommunities of Indigenous Peopleswhen the circumstances described in thisPS are present.

IFC8 CulturalHeritage

To protect cultural heritage from theadverse impacts of project activities andsupport its preservation.

To promote the equitable sharing ofbenefits from the use of culturalheritage.

IFC8.1 - Cultural Heritage survey. 6, 8

IFC8.2 - Use of competentprofessionals in the identificationand protection of Cultural Heritage.

6, 8

IFC8.3 - Cultural Heritage ImpactAssessment

6, 8

IFC8.4 - Management of chancefinds

6, 8

IFC8.5- Consultation with AffectedCommunities

13

IFC8.6 - Cultural Heritage –continued access

6, 8

IFC8.7 - Management of CulturalHeritage

8

IFC8.8 - Commercial use of CulturalHeritage

8

Source: IFC Performance Standards (January 2012)




Appendix 5: IFC Environmental, Health, and Safety General Guidelines(April 2007)





EHSG1 Environmental To incorporate EHS considerations intocorporate and facility-level businessprocesses

To identify project hazards andassociated risks as early as possible in thefacility development or project cycle

To involve EHS professionals to assessand manage EHS impacts and risks andcarry out specialised environmentalmanagement functions includingpreparation of project or activity-specificplans and procedures.

EHSG1.1 – Air Emissions andAmbient Air Quality

8

EHSG1.2 – Energy Conservation 8

EHSG1.3 Wastewater and AmbientWater Quality

8

EHSG1.4 – Water Conservation 8

EHSG1.5 – Hazardous MaterialsManagement

8

EHSG1.6 – Waste Management 8

EHSG1.7 – Noise 8

EHSG1.8 – Contaminated Land 8

EHSG2 OccupationalHealth andSafety

To provide reasonable precautions tomanage principle risks to occupationalhealth and safety

To ensure companies hire personnelwith the technical capability to manageoccupational health and safety issues.

To apply preventative and protectivemeasures based on comprehensive jobsafety analyses

To design and equip places or work toprotect occupational health and safety.

EHSG2.1 - General Facility Designand Operation

7, 8

EHSG2.2 – Communication andTraining

12, 13

EHSG2.3 – Physical Hazards 8

EHSG2.4 – Chemical Hazards 8

EHSG2.5 – Biological Hazards 8

EHSG2.6 – Radiological Hazards 8

EHSG2.7 – Personal ProtectiveEquipment

8

EHSG2.8 – Special HazardEnvironments

8

EHSG3 CommunityHealth andSafety

To ensure that EHS considerationsaddress aspects of project activitiestaking place outside of the traditionalproject boundaries.

EHSG3.1 – Water Quality andAvailability

6, 8

EHSG3.2 – Structural Safety ofProject Infrastructure

6, 8

EHSG3.3 – Life and Fire Safety 8, 9

EHSG3.4 – Traffic Safety 8

EHSG3.5 – Transport of HazardousMaterials

8

EHSG3.6 – Disease Prevention 8

EHSG3.7 – EmergencyPreparedness and Response

9

EHSG4 ConstructionandDecommissioning

To provide guidance on prevention andcontrol of community health and safetyimpacts that occur during new projectdevelopment, at the end of the projectlife-cycle or due to expansion ormodification of existing project facilities.

EHSG4.1 – Environment 8





EHSG4.2 – Occupational Health andSafety

8

EHSG4.3 – Community Health andSafety

6, 8




Appendix 6: JBIC Environmental and Social Guidelines




ID Heading Equivalent Equator Principles and/or International Finance Corporationguidelines / Additional requirements

ESMPSection(whererelevant)

J1 General

J1-1 EnvironmentalImpact Assessment

The requirements of J1-1 are partially addressed by the following: Environmental Impact Assessment (EP2.1) Social Impact Assessment (EP2.2) GHG Alternatives Assessment (EP2.3) Environmental and Social Assessment (IFC1.3) Independent Review (EP7.1) Independent Review of High Risk Impacts (EP7.2)Additional requirements relate to the assessment of (and recording ofoutcomes) alternative proposals including an analysis of environmental costsand benefits in as quantitative terms as possible be conducted in close harmonywith economic, financial, institutional, social and technical analyses of theProject.

7

J2 Scope of impact to be examined

J2-1 Examination ofalternative proposals

The requirements of J2-1 are partially addressed by the following: Environmental Impact Assessment (EP2.1) Social Impact Assessment (EP2.2) GHG Alternatives Assessment (EP2.3) Environmental and Social Assessment (IFC1.3) Independent Review (EP7.1) Independent Review of High Risk Impacts (EP7.2)Additional requirements include the assessment of multiple alternatives.However, mitigation hierarchy is required via State impact assessment processthat may achieve this standard.

7

J2-2 Factors to beinvestigated

The requirements of J2-2 are fully addressed by the following: Community Health and Safety (IFC 4) Community Health and Safety (IFC 4.1).

-

J2-3 Examine derivativeand cumulativeimpacts

The requirements of J2-3 are fully addressed by the following: Environmental and Social Management System(ESMS) (IFC1.1) Community Health and Safety (IFC 4) Community Health and Safety (IFC 4.1)

-

J3 Compliance with laws, standards and plans

J3-1 Compliance withlocal law

The requirements of J3-1 are fully addressed by the following: Environmental and Social Standards (EP3).

-

J3-2 Protection of naturaland cultural heritageareas

The requirements of J3-2 are fully addressed by the following: EP3 Environmental and Social Standards IFC6 Biodiversity Conservation and Sustainable Management Living Natural

Resources IFC8 Cultural Heritage Cultural heritage impact assessment (IFC 8.3).

J4 Social acceptability and social impacts

J4-1 Social acceptabilityof projects

The requirements of J4-1 are fully addressed by the following: Informed Consultation and Participation Process (EP5.1) Assessment Documentation Availability (EP5.2) Engagement Results (EP5.3) Indigenous People (EP5.4) Stakeholder engagement (IFC 1.8)

-






Informed consent (IFC 7) Indigenous People engagement (IFC 7.2) Identification of Indigenous people (IFC 7.1).

J4-2 Consideration of thevulnerable

The requirements of J4-2 are fully addressed by the following: Stakeholder engagement (IFC 1.8) Identification of Indigenous people (IFC 7.1) Indigenous People engagement (IFC 7.2).

-

J5 Ecosystem and biota

J5-1 Critical naturalhabitats

The requirements of J5-1 are fully addressed by the following: Biodiversity Conservation and Sustainable Management Living Natural

Resources (IFC 6) Protection and conservation of biodiversity (IFC 6.1) Management of Ecosystem Services (IFC 6.2).

-

J5-2 Illegal logging The requirements of J5-2 are fully addressed by the following: Biodiversity Conservation and Sustainable Management Living Natural

Resources 9 (IFC6) Protection and conservation of biodiversity (IFC 6.1).

-

J6 Involuntary resettlement

J6-1 Involuntaryresettlementavoidance

The requirements of J6-1 are fully addressed by the following: Land Acquisition and Involuntary Resettlement (IFC 5) General (IFC 5.1) Displacement (IFC 5.2) Private Sector Responsibilities Under Government-Managed Resettlement

(IFC 5.3).

-

J6-2 Compensation forinvoluntaryresettlement

The requirements of J6-2 are fully addressed by the following: Land Acquisition and Involuntary Resettlement (IFC 5) Displacement (IFC 5.2) Private Sector Responsibilities Under Government-Managed Resettlement

(IFC 5.3)

-

J6-3 Participation byaffected people

The requirements of J6-3 are fully addressed by the following: Land Acquisition and Involuntary Resettlement General (IFC 5.1)Grievance mechanism (EP6).

-

J6-4 Resettlementplanning

The requirements of J6-4 are fully addressed by the following: Land Acquisition and Involuntary Resettlement (IFC 5) General (IFC 5.1)Resettlement is not relevant to the Roy Hill Project.

-

J7 Indigenous peoples

J7-1 Avoidance of impactson indigenouspeoples

The requirements of J7-1 are fully addressed by the following: Assessment and Management of Environmental and Social Risks (IFC1) Indigenous Peoples (IFC7) Identification of Indigenous people (IFC 7.1) Mitigation and compensation for Affected Communities (IFC 7.5).

-

J7-2 Respect ofindigenous rights

The requirements of J7-2 are fully addressed by the following: Indigenous Peoples (IFC 7) Indigenous People engagement (IFC 7.2) Circumstances requiring FPIC (IFC 7.4).

-

J7-3 Indigenous peoplesplanning

The requirements of J7-3 are partially addressed by the following: Indigenous People engagement (IFC 7.2) Indigenous People Management Plan (IFC 7.3)

13, 16






Additional requirements relate to accessible procedures to address grievancesby the affected communities, and monitoring and reporting on implementationof an Indigenous Peoples Plan.

J8 Monitoring

J8-1 Monitoringimplementation

The requirements of J8-1 are fully addressed by the following: Environmental Monitoring/Audit Program (EP 3.1) Social Monitoring/Audit Program (EP 3.2) Verification of monitoring (EP 9.1) Independent verification of monitoring (EP 9.2) Monitoring and review (IFC 1.7)

-

J8-2 Monitoring feasibilityand effectiveness

The requirements of J8-2 are fully addressed by the following: Environmental Monitoring/Audit Program (EP 3.1) Social Monitoring/Audit Program (EP 3.2) Verification of monitoring (EP 9.1) Independent verification of monitoring (EP 9.2) Monitoring and review (IFC 1.7)

-

J8-3 Monitoring resultsavailability

The requirements of J8-3 are fully addressed by the following: Environmental Monitoring/Audit Program(EP 3.1) Social Monitoring/Audit Program (EP 3.2) Assessment Documentation Availability (EP 5.2) Monitoring and Review (IFC 1.7) Stakeholder engagement (IFC 1.8)

-

J8-4 Monitoringimplementation

The requirements of J8-4 are fully addressed by the following: Grievance mechanism (EP 6) Assessment and Management of Environmental and Social Risks (IFC 1) External Communication - Grievance Mechanism (IFC 1.9).

-

J9 EIA reports for Category A Projects

J9-1 EnvironmentalImpact AssessmentProcess

The requirements of J9-1 are fully addressed by the following: Environmental Impact Assessment (EP 2.1) Social Impact Assessment (EP 2.2) GHG Alternatives Assessment (EP 2.3) Informed Consultation and Participation Process (EP 5.1) Assessment Documentation Availability (EP5.2) Identification of Indigenous people (IFC 7.1) Indigenous People engagement (IFC 7.2)

-

J9-2 Scope ofEnvironmentalImpact Assessment

The requirements of J9-2 are fully addressed by the following: Environmental Impact Assessment (EP 2.1) Social Impact Assessment (EP 2.2) GHG Alternatives Assessment (EP 2.3) Informed Consultation and Participation Process (EP 5.1) Assessment Documentation Availability (EP 5.2) Identification of Indigenous people (IFC 7.1)Indigenous People engagement (IFC 7.2).

-




Appendix 7: NEXI Environmental and Social Considerations




ID Heading Equivalent Equator Principles and/or International Finance Corporationguidelines / additional requirements

AdditionalrequirementSection(whererelevant)

N1 Underlying Principles

N1-1 EnvironmentalImpactAssessment

The requirements of N1-1 are partially addressed by the following: Environmental and Social Assessment (EP 2) Environmental and Social Assessment (IFC1.3) Independent Review (EP7.1) Independent Review of High Risk Impacts (EP7.2)Additional requirements include an assessment of alternative proposals including ananalysis of environmental costs and benefits in as quantitative terms as possible beconducted in close harmony with economic, financial, institutional, social andtechnical analyses of the Project.

7

N2 Examination of measures

N2-1 Examination ofalternativeproposals

The requirements of N2-1 are partially addressed by the following: Environmental Impact Assessment (EP2.1) Social Impact Assessment (EP2.2) GHG Alternatives Assessment (EP2.3) Environmental and Social Assessment (IFC1.3)Additional requirements include an assessment of multiple alternative proposals.

7

N2-2 Monitoringplans andsystems

The requirements of N2-2 are partially addressed by the following: Environmental Monitoring/Audit Program (EP3.1) Social Monitoring/Audit Program (EP3.2) Environmental Management Plan (EP4.1) Social Management Plan (EP4.2) Environmental and Social Management System(ESMS) (IFC1.1) Environmental and Social Management Program (IFC1.4)Additional requirements include the preparation of cost plans relating to monitoringplans and environmental management plans.

7

N3 Scope of Impacts to be examined

N3-1 Factors to beinvestigated

The requirements of N3-1 are fully addressed by the following: Environmental Impact Assessment (EP2.1) Social Impact Assessment (EP2.2) GHG Alternatives Assessment (EP2.3) Environmental and Social Assessment (IFC1.3) Community, Health, Safety and Security (IFC4) Community Health and Safety (IFC 4.1).

-

N3-2 Protection ofnatural andcultural heritageareas

The requirements of N3-2 are fully addressed by the following: Environmental and Social Standards (EP 3) Biodiversity Conservation and Sustainable Management Living Natural

Resources (IFC 6) Cultural Heritage (IFC 8) Cultural heritage impact assessment (IFC 8.3)

-

N3-3 Critical naturalhabitats

The requirements of N3-3 are fully addressed by the following: Biodiversity Conservation and Sustainable Management Living Natural

Resources (IFC 6) Protection and conservation of biodiversity (IFC 6.1) Management of Ecosystem Services (IFC 6.2)

-

N3-4 Illegal logging The requirements of N3-4 are fully addressed by the following: Biodiversity Conservation and Sustainable Management Living Natural

Resources (IFC 6) Protection and conservation of biodiversity (IFC 6.1)

-






N4 Social acceptability and social impacts

N4-1 Socialacceptability ofprojects

The requirements of N4-1 are fully addressed by the following and compliance withthe Western Australian environmental impact assessment process: Assessment and Management of Environmental and Social Risks and Impacts

(IFC 1) Informed Consultation and Participation Process (EP5.1) Assessment Documentation Availability (EP5.2) Engagement Results (EP5.3) Indigenous People (EP5.4) Stakeholder engagement (IFC 1.8) Informed consent (IFC 7) Indigenous People engagement (IFC 7.2) Identification of Indigenous people (IFC 7.1).

-

N4-2 Consideration ofthe vulnerable

The requirements of N4-2 are fully addressed by the following: Stakeholder engagement (IFC 1.8) Identification of Indigenous people (IFC 7.1) Indigenous People engagement (IFC 7.2).

-

N5 Involuntary resettlement

N5-1 Involuntaryresettlementavoidance

The requirements of N5-1 are fully addressed by the following: Land Acquisition and Involuntary Resettlement (IFC 5) General (IFC 5.1) Displacement (IFC 5.2) Private Sector Responsibilities Under Government-Managed Resettlement (IFC

5.3).

-

N5-2 Compensationfor involuntaryresettlement

The requirements of N5-2 are fully addressed by the following: Land Acquisition and Involuntary Resettlement (IFC 5) Displacement (IFC 5.2) Private Sector Responsibilities Under Government-Managed Resettlement (IFC

5.3)

-

N5-3 Participation byaffected people

The requirements of N5-3 are fully addressed by the following: Land Acquisition and Involuntary Resettlement (IFC 5) General (IFC 5.1) Grievance mechanism (EP6)

-

N5-4 Resettlementplanning

The requirements of N5-4 are addressed by the following: IFC 5 Land Acquisition and Involuntary Resettlement General (IFC 5.1).Resettlement is not relevant to the Roy Hill Project.

-

N6 Indigenous People

N6-1 Avoidance ofimpacts onindigenouspeoples

The requirements of N6-1 are addressed by the following: Assessment and Management of Environmental and Social Risks (IFC 1) Indigenous Peoples (IFC 7) Identification of Indigenous people (IFC 7.1) Mitigation and compensation for Affected Communities (IFC 7.5).

-

N6-2 Respect ofindigenousrights

The requirements of N6-2 are addressed by the following: Indigenous Peoples (IFC 7) Indigenous People engagement (IFC 7.2) Circumstances requiring FPIC (IFC 7.4).

-

N6-3 Indigenouspeoplesplanning

The requirements of N6-3 are partially addressed by the following: Indigenous People engagement (IFC 7.2) Indigenous People Management Plan (IFC 7.3)

16






Additional requirements relate to Indigenous peoples plan to include the elementslaid out in the World Bank Safeguard Policy, OP4.10, Annex B.

N7 Monitoring and follow-up

N7-1 Monitoringimplementation

The requirements of N7-1 are fully addressed by the following: Environmental Monitoring/Audit Program (EP3.1) Social Monitoring/Audit Program (EP3.2) Verification of monitoring (EP9.1) Independent verification of monitoring (EP9.2) Monitoring and review (IFC 1.7).

-

N7-2 Monitoringfeasibility andeffectiveness

The requirements of N7-2 are fully addressed by the following: Environmental Monitoring/Audit Program (EP3.1) Social Monitoring/Audit Program (EP3.2) Verification of monitoring (EP9.1) Independent verification of monitoring (EP9.2) Monitoring and review (IFC 1.7).

-

N7-3 Monitoringresultsavailability

The requirements of N7-3 are fully addressed by the following: Assessment Documentation Availability (EP5.2) Monitoring and Review (IFC 1.7).

-

N7-4 Grievancemechanisms

The requirements of N7-4 are fully addressed by the following: Grievance mechanism (EP6) Assessment and Management of Environmental and Social Risks (IFC 1) External Communication - Grievance Mechanism (IFC 1.9).

-

N8 EIA reports for Category A projects

N8-1 EnvironmentalImpactAssessmentProcess

The requirements of N8-1 are fully addressed by the following: Environmental Impact Assessment (EP 2.1) Social Impact Assessment (EP 2.2) GHG Alternatives Assessment (EP 2.3) Informed Consultation and Participation Process (EP 5.1) Assessment Documentation Availability (EP 5.2) Identification of Indigenous people (IFC 7.1) Indigenous People engagement (IFC 7.2).

-

N8-2 Scope ofEnvironmentalImpactAssessment

The requirements of N8-2 are fully addressed by the following: Environmental Impact Assessment (EP2.1) Social Impact Assessment (EP2.2) GHG Alternatives Assessment (EP2.3) Informed Consultation and Participation Process (EP5.1) Assessment Documentation Availability (EP5.2) Identification of Indigenous people (IFC 7.1) Indigenous People engagement (IFC 7.2).

-




Appendix 8: US EX-IM Environmental and Social Due Diligence Proceduresand Guidelines




ID Heading Equator Principles and/or International Finance Corporation equivalent guidelines /additional requirements

ESMPsection(whererelevant)

E1

Assessmentagainstinternationalguidelines

Project assessed against the IFC Performance standards. -

E2 Objectives and scope of EX-IM Bank’s Environmental Guidelines

E2-1 Air Quality

In addition, the requirements of E2-1 are partially addressed by the following: Resource efficiency and pollution prevention (IFC 3.1) GHG reporting (IFC 3.2) Waste management (IFC 3.4) Protection and conservation of biodiversity (IFC 6.1) Management of Ecosystem Services (IFC 6.2)Additional requirement relates to compliance with quantitative limits set forth in theapplicable World Bank international guidelines.

16

E2-2Water Use andQuality

In addition, the requirements of E2-2 are partially addressed by the following: Pollution Prevention (IFC 3.3) Waste management (IFC 3.4) Pesticide use and Management (IFC 3.5) Protection and conservation of biodiversity (IFC 6.1) Management of Ecosystem Services (IFC 6.2) Weed, pathogen and feral animals management (IFC 6.3) Demonstrate non-primary production of natural resources (IFC 6.4) Supply chain (IFC 6.5)Additional requirement relates to compliance with quantitative limits set forth in theapplicable World Bank international guidelines.

16

E2-3 WasteManagement

In addition, the requirements of E2-3 are partially addressed by the following: GHG reporting (IFC 3.2) Pollution Prevention (IFC 3.3) Waste management (IFC 3.4) Pesticide use and Management (IFC 3.5) Protection and conservation of biodiversity (IFC 6.1) Management of Ecosystem Services (IFC 6.2)Additional requirement relates to compliance with quantitative limits set forth in theapplicable World Bank international guidelines.

16

E2-4Natural andManmade Hazards.

In addition, the requirements of E2-4 are partially addressed by the following: Emergency Response Systems (IFC 1.6) GHG reporting (IFC 3.2) Pollution Prevention (IFC 3.3) Waste management (IFC 3.4) Pesticide use and Management (IFC 3.5)Additional requirement relates to compliance with quantitative limits set forth in theapplicable World Bank international guidelines.

16






E2-5 Biodiversity.

In addition, the requirements of E2-5 are partially addressed by the following: Resource efficiency and pollution prevention (IFC 3.1) GHG reporting (IFC 3.2) Pollution Prevention (IFC 3.3) Waste management (IFC 3.4) Pesticide use and Management (IFC 3.5) Protection and conservation of biodiversity (IFC 6.1) Management of Ecosystem Services (IFC 6.2) Weed, pathogen and feral animals management (IFC 6.3) Demonstrate non-primary production of natural resources (IFC 6.4) Supply chain (IFC 6.5)Additional requirement relates to compliance with quantitative limits set forth in theapplicable World Bank international guidelines.

16

E2-6

InvoluntaryResettlement,IndigenousPeoples, CulturalProperty.

In addition, the requirements of E2-6 are partially addressed by the following: General (IFC 5.1) Displacement (IFC 5.2) Private Sector Responsibilities Under Government Managed Resettlement (IFC 5.3) Identification of Indigenous people (IFC 7.1) Indigenous People engagement (IFC 7.2) Indigenous Peoples Management (IFC 7.3) Circumstances requiring FPIC (IFC 7.4) Mitigation and compensation for Affected Communities (IFC 7.5) Private sector responsibilities where Government is responsible for managingindigenous peoples issues (IFC 7.6)Given the involuntary resettlement is not relevant to the Project; a requirement gaphas not been reported.

-

E2-7 Noise

In addition, the requirements of E2-7 are partially addressed by the following: Resource efficiency and pollution prevention (IFC 3.1) Pollution prevention (IFC 3.3) Protection and conservation of biodiversity (IFC 6.1)Additional requirement relates to compliance with quantitative limits set forth in theapplicable World Bank international guidelines.

16

E2-8Protection ofWorkers

In addition, the requirements of E2-7 are addressed by the following: Working conditions and management of worker relationships (IFC 2.1) Child and forced labour (IFC 2.2) Occupational Health and Safety (IFC 2.3)A potential gap relates to the compliance with the World Bank EHS Guidelines that setsout prescriptive levels for emissions, energy and water conservation, OH&S,community health and safety, construction and decommissioning.

16

E2-9Community Healthand Safety Requires compliance with the World Bank EHS Guidelines 16

E2-10 Global Climate

In addition, the requirements of E2-7 are addressed by the following: Reporting of GHG emissions (EP10.2) GHG reporting (IFC 3.2) Pollution Prevention (IFC 3.3)Additional requirement relating to compliance with the World Bank EHS Guidelines.

16

E3Environmental andSocial ImpactAssessment

Project assessed against the IFC Performance standards.-






E4Environmental andSocialSustainability

Project assessed against the IFC Performance standardsAdditional requirement relating to compliance with the World Bank EHS Guidelines.

16

E5 EHS GuidelinesProject assessed against the IFC Performance standards.Additional requirement relating to compliance with the World Bank EHS Guidelines.

16




Appendix 9: OECD Revised Council Recommendations




No. Heading Equator Principles and/or International Finance Corporation equivalent guidelines /additional requirements

ESMPsection(where

relevant)

1 Category A Category A status is also recognised under the Equator Principles. -

2

Social review The OECD recommendations are provided through: Environmental and Social Assessment (EP 2) Environmental and Social Assessment (IFC1.3) Independent Review (EP7.1) Independent Review of High Risk Impacts (EP7.2) Engagement Results (EP5.3).

-

3

Social ImpactAssessment

The OECD recommendations are provided through: Environmental and Social Assessment (EP 2) Environmental and Social Assessment (IFC1.3) Independent Review (EP7.1) Independent Review of High Risk Impacts (EP7.2) Engagement Results (EP5.3).

-

4Benchmarking The Project has been assessed against the IFC Performance Standards and Equator

Principles which are two relevant environmental standards meeting the requirement ofthis recommendation.

-

5

National andinternationalstandards

The OECD recommendations are provided through: Environmental and Social Standards (EP 3) Environmental Monitoring/Audit Program (EP3.1) Social Monitoring/Audit Program (EP3.2)

-

6

Application ofstandards

The OECD recommendations are provided through: Environmental and Social Standards (EP 3) Environmental Monitoring/Audit Program (EP3.1) Social Monitoring/Audit Program (EP3.2)

-

7 Memberrequirements

Noted -

8Memberrequirements

Noted -


Noted -


Noted -


Noted -


Noted -

13Memberrequirements

Noted -


Noted -


Noted -


Noted -


Noted -

18EIA scope anddetail

The OECD recommendations are provided through: Environmental Impact Assessment (EP2.1)

-




No. Heading Equator Principles and/or International Finance Corporation equivalent guidelines /additional requirements

ESMPsection(where

relevant) Social Impact Assessment (EP2.2) GHG Alternatives Assessment (EP2.3) Informed Consultation and Participation Process (EP5.1) Assessment Documentation Availability (EP5.2) Identification of Indigenous people (IFC 7.1) Indigenous People engagement (IFC 7.2)




Appendix 10: Roy Hill Governance Policy

Roy Hill - Policy

GOVERNANCE POLICY

Purpose The Roy Hill vision is to be a high performing iron ore business where people contribute and realise their full potential. Through the direction of the Roy Hill Board and the implementation of the Integrated Management System, we will deliver sustained, low cost production of iron ore which is consistent in quality and grade.

Policy Statement

• All Roy Hill employees understand their contribution to leadership, demonstrate the Roy Hill Core Values of Lead, Care, Think and Perform and commit to take accountability for actions to achieve the strategic business objectives.

• The role of the Roy Hill Board of Directors is to protect and optimise the performance of Roy Hill. The Board takes accountability for setting strategic direction, establishing policy, overseeing the financial positions and monitoring the business and affairs on behalf of the shareholders. The responsibility for the day to day operations is delegated to the Chief Executive Officer and Senior Management.

• The Board ensures that effective review mechanisms are in place and challenges management decisions. Review processes are established when required to identify areas of weakness and scope for improvement and respond to current and emerging issues facing the company.

• Roy Hill will implement and maintain an Integrated Management System that incorporates a set of Policies and Standards on a variety of important topics that provides the framework for ensuring everyone works in an agreed way that is aligned to the Roy Hill Core Values. The implementation of the Integrated Management System ensures the delivery of sustainable improvement, consistency and reliability at all levels of the business.

• Roy Hill commits adequate and appropriate resources to maintain our systems to ensure regulatory and lega l compliance is achieved and applied consistently across all business functions and the different disciplines.

• Roy Hill has a risk management system that provides an assessment of inherent risk aimed to reduce the undesirable or unrelated risks to allow us to produce sustainable value.

• Roy Hill is committed to ensure that risk analysis is performed at all levels of the organisation, that targets and actions are established, reviewed and integrated into our planning and decision making processes.

Chief Executive Officer

Roy Hill Holdings

Date: 22 ·i · 20 14

OOORH-0000-RH-POL-0005 Rev 0 Page 1 of 1




Appendix 11: Roy Hill Environmental Policy

Roy Hill - Policy

ENVIRONMENT POLICY

Purpose Roy Hill recognises its responsibility in ensuring its activities are performed in an environmentally conscious manner,

Policy Statement • We will identify, implement and promote environmentally responsible business practices.

• We will aim to progressively return areas impacted by our activities to a safe, stable, non-polluting, selfsustaining agreed end land use.

• We will provide training to all employees and contractors regarding their environmental responsibility to recognise and minimise the potential impact of their activities.

• We will enhance understanding of surrounding biodiversity and the impacts of our activities through monitoring programs.

• We will promote efficient use of resources including reducing and preventing pollution.

• We will comply with legal requirements and report on our environmental performance to internal and external stakeholders.

• We will assess and understand the environmental risks and potential impacts of our activities and ensure that risk based objectives, targets and standards are established, reviewed and integrated into our environmental and operational management practices.

• We will aim for continuous improvement in environmental performance through the development and achievement of key performance indicators and the monitoring and review of our systems.

• We will communicate and consult with employees, contractors, the community, regulators and other parties in relation to environmental matters.

• We will commit adequate and appropriate resources to achieve environmental goals and objectives.

• We will align and maintain our Environmental Management System in accordance with International Principles and Standards including 15014001

• We will review this policy annually to reflect the progress in achieving Roy Hill's key environmental objectives.

Barry Fitzgerald


Roy Hill Holdings

Date: ll · '6 · 2014





Appendix 12: Roy Hill Health and Safety Policy

Roy Hill - Policy

HEALTH AND SAFETY POLICY

Purpose Roy Hill is committed to providing a safe, productive and healthy work environment for all employees, contractors and visitors.

Policy Statement At Roy Hill we will:

• Comply with applicable legal requirements as a minimum and go beyond those requirements where necessary to comply with our core values.

• Ensure that our risk based objectives, targets and actions are established, reviewed and integrated into our planning and decision making processes.

• Assess the potential health and safety impacts of our activities to ensure appropriate action is taken to prior to commencing work.

• Aim for continuous improvement in our hea lth and safety performance via development of KPl's and the monitoring and review of our systems.

• Communicate and consult with our employees, contractors, and other relevant parties in relation to health and safety issues and performance.

• Advise and train our employees and contractors as necessary to meet our health and safety objective of providing a safe system of work.

• Commit adequate and appropriate resources to enable us to provide a safe system of work.

• Ensure fair injury management processes.

• Establish accountabi lity of employees for their health and safety performance.

• Ensure that critical controls associated with our Principle Hazards are understood and processes are established to verify that the critica l controls are effective.

• Having in place a culture that allows us to ask questions and provide support when there is doubt regarding the performance of an activity or task.

• Ensure that our contractors implement and effectively manage their workforce in a safe and healthy manner when working on our project.

Barry Fitzgerald


Roy Hill Holdings

Date: ,;2) - S- 2u 1 <..../'

OOORH-OOOO-RH-POL-0001 Rev 0 Page 1 of 1




Appendix 13: Roy Hill Stakeholder Engagement Policy

Roy Hill - Policy

STAKEHOLDER ENGAGEMENT POLICY

Purpose Roy Hill recognises its responsibility in ensuring stakeholder engagement develops and maintains long-term mutually beneficial, constructive and responsive relationships. Our continued success relies on the ensuring that our stakeholders are informed and their views are considered.

Policy Statement

• We believe in sustainable development and being responsive to community relationships, encouraging participation and involvement.

• We believe in having relationships with our key suppliers to form true partnerships to assist us in delivering on our Strategic Business Objectives.

• We will provide our shareholders and investment partners with full and timely information about our activities

• We will ensure our employees are appropriately informed of impacts that will affect them directly or the company.

• We will maintain compliance with legal and other requirements, including the rights and protections for workforce, Indigenous Peoples and where relevant, other stakeholders.

• We will establish, implement and promote sustainable community development benefits in the Town of Port Hedland, Shire of East Pilbara and relevant traditional owners of the area.


Roy Hill Holdings

Date: 2-l · f · 2-01y

OOORH-0000-RH-POL-0006 Rev 0 Page 1 o f 1




Appendix 14: Roy Hill Employment Policy

Purpose

Roy Hill - Policy

EMPLOYMENT POLICY

Roy Hill is committed to providing a better place to work for all employees and contractors. We believe a trained, competent and motivated workforce is essential to the creation and sustainability of Roy Hill. We aim to create a culture that is able to attract and retain high performing people who are able to achieve great outcomes and develop personally.

Policy Statement

• We employ on the basis of position requirements and acknowledge all types of diversity, including gender, age, ethnic or social origin, sexual orientation, politics or religion.

• We treat each other and people outside of our company, the same, by demonstrating the Roy Hill Core Values of Lead, Care, Think and Perform.

• We believe that attitudes are the driver of behaviour as they serve to influence and direct what people say and do.

• We encourage the challenging of inappropriate behaviour at any level in the organisation when you encounter it and never walk past anything unsafe or accept poor behaviour without addressing the issue.

• We are committed to providing a harm free environment that is conductive to and enables continuous learning, growth and personal development for employees and contractors.

• We provide systems that establish how we do our work and what employment conditions we need to follow to enable us to be a thinking and innovative organisation.

• Our remuneration processes are structured to ensure that we are equitab le and maintain a competitive position in the market. We seek to attract high ca libre people and to retain and motivate them, in part, by providing a tangible link between performance and reward.

We encourage employees to learn, develop and take on new positions and provide the support and resources to make it happen.

• Our diversity objectives are aimed at improving gender equity and we will ensure that we report on progress against these objectives.

• We do not tolerate any forms of bullying and harassment or unethical behaviour in the workplace and we will maintain a work environment that supports diversity.

• We do not misuse employment for personal advantage and provide a fair and equitable process for those employees who leave the business which allows them to provide feedback to Roy Hill.

Barry Fitzgerald


Roy Hill Holdings
