OFFSHORE CAPE THREE POINTS ENVIRONMENTAL AND SOCIAL ...€¦ · this suggestion as it went some way to enabling work to be done with respect to achieving objective 6 of the site visit

Intended for

Vitol Upstream Ghana Limited and the International Finance Corporation

Date

3rd July 2018

Project Number

1700002167

OFFSHORE CAPE THREE POINTS ENVIRONMENTAL AND SOCIAL MONITORING REPORT (MARCH 2018)

OFFSHORE CAPE THREE POINTS ENVIRONMENTAL AND SOCIAL MONITORING REPORT (MARCH 2018)

Ramboll Box House Box Wiltshire SN13 8AA United Kingdom T +44 122 574 8420 www.ramboll.com






Made by: C Halliwell, R Bisset Checked/Approved by: Jon Hancox

This report has been prepared by Ramboll Environment and Health UK Limited with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between Ramboll Environment and Health UK Limited and the Client. This report is confidential to the Client, and Ramboll Environment and Health UK Limited accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by Ramboll Environment and Health UK Limited beforehand. Any such party relies upon the report at their own risk. Ramboll Environment and Health UK Limited disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services. Version Control Log

Revision Date Made by Checked by Approved by Description

Issue A 18_4_18 C Halliwell and R

Bisset

C Halliwell J Hancox Draft issued to client

Issue B 21/05/18 C Halliwell and R

Bisset

C Halliwell J Hancox Draft –for disclosure

Issue 1 3/7/18 C Halliwell and R

Bisset

C Halliwell J Hancox Final – for disclosure

Project No. 1700002167 Issue No. Issue 1 Date 3 July 2018 Made by C Halliwell, R Bisset

Checked by C Halliwell Approved by J Hancox

Environmental and Social Monitoring Report (March 2018) Offshore Cape Three Points

1700002167_Issue 1_Final

CONTENTS

ACRONYMS AND ABBREVIATIONS EXECUTIVE SUMMARY I 1. INTRODUCTION 1 2. SCOPE AND STRUCTURE OF THE REPORT 3 2.1 Scope of the monitoring visit 3 2.2 Project Standards 4 2.3 Structure of the Report 4 2.4 Limitations 4 3. PROJECT DESCRIPTION 6 3.1 Project description 6 3.2 Material design changes 6 3.3 Status of the Project at time of the monitoring visit 7 4. SIGNIFICANCE ASSESSMENT 9 4.1 Review Findings 9 4.2 Assessment of Significance 9 5. LEGISLATIVE FRAMEWORK AND OTHER PROJECT

STANDARDS 11 5.1 Summary of legislative framework 11 5.2 Permitting 11 6. PERFORMANCE STANDARD 1: ASSESSMENT AND

MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 13

6.1 Requirements specified in the ESAP 13 6.2 HSE and Sustainability Responsibilities and Resources 14 6.3 Contractor management and performance 20 6.4 Closure of earlier IESC findings 26 6.5 Community Investment Strategy 26 6.6 Cumulative impacts and influx 27 6.7 Stakeholder engagement 28 6.8 Community Grievance mechanism 29 6.9 Contingency planning 33 6.10 WBG preliminary TTIP audit findings 33 6.11 Audit and Inspection 34 6.12 Management of Change 35 6.13 Operations readiness 35 7. PERFORMANCE STANDARD 2: LABOR AND WORKING

CONDITIONS 41 7.1 Introduction 41 7.2 Management of labour and working conditions 41 7.3 Local labour dispute 41 7.4 Workers’ accommodation 46 7.5 Occupational health and safety 46 8. PERFORMANCE STANDARD 3: RESOURCE EFFICIENCY

AND POLLUTION PREVENTION 49 8.1 Air quality 49 8.2 Noise 49 8.3 Surface and groundwater 50 8.4 Waste management 51 8.5 Greenhouse gas emissions (GHG) 51 9. PERFORMANCE STANDARD 4: COMMUNITY HEALTH,

SAFETY, AND SECURITY 56 9.1 Introduction 56



9.2 Community Health and Safety 56 9.3 Security 57 10. PERFORMANCE STANDARD 5: LAND ACQUISITION AND

INVOLUNTARY RESETTLEMENT 64 10.1 Introduction 64 10.2 Land - focused economic displacement 64 10.3 Fisheries-focused economic displacement 67 11. PERFORMANCE STANDARD 6: BIODIVERSITY

CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 73

11.1 Introduction 73 11.2 ESAP biodiversity requirement 73 11.3 Site drainage 74 11.4 Top soil management 74 12. PERFORMANCE STANDARD 8: CULTURAL HERITAGE 75

APPENDICES

Appendix 1 Environmental and Social Action Plan

Appendix 2 Project Documentation Provided for Review

Appendix 3 Monitoring Visit Itinerary

Appendix 4 Status of Issues Identified in Preceeding Monitoring Visit

Appendix 5 Photolog



ACRONYMS AND ABBREVIATIONS

AMR Annual Monitoring Report BOD5 Biological Oxygen Demand (measured over a 5-day period) CHMP Cultural Heritage Management Plan CLO Community Liaison Officer COD Chemical Oxygen Demand DFI Delta Flash Intervention (a security provider) DAoI Direct Area of Influence

EC Energy Commission

E&S Environmental and Social ESAP Environmental and Social Action Plan ESDD Environmental and Social Due Diligence EHS Environmental, Health and Safety EIS Environmental Impact Statement EPA Environmental Protection Agency EPIC Engineering Procurement Installation and Commissioning ERP Emergency Response Plan ESHIA Environmental, Social and Health Impact Assessment FCP Flora Conservation Plan FLO Fisheries Liaison Officer FMCC Fisheries Management Coordination Committee FPSO Floating Production Storage and Offloading GES Gas Export Sealine GIIP Good International Industry Practice GMA Ghana Maritime Authority GNGC Ghana National Gas Company GNPC Ghana National Petroleum Corporation H2S Hydrogen sulphide HIV/AIDS Human Immunodeficiency Virus/Acquired Immunodeficiency

Syndrome HSE Health, Safety and Environment HSE and S Health, Safety, Environment and Sustainability IESC Independent Environmental and Social Consultant IFC International Finance Corporation ITT Invitation to Tender LTE Landfall Terminal End LR Livelihood Restoration LRP Livelihood Restoration Plan LDV Land Valuation Division MIGA Multilateral Investment Guarantee Agency MMO Marine Mammal Observer MoU Memorandum of Understanding MS Management System NO2 Nitrogen Dioxide O&G Oil and Gas OCTP Offshore Cape Three Points OIM Offshore Installation Manager OSRP Oil Spill Response Plan ORF Onshore Receiving Facility OHS Occupational Health and Safety PAP Project-Affected Person



AMR Annual Monitoring Report PC Petroleum Commission PLET Pipeline End Terminal

PLONOR Pose little or no risk PM10 Particulate matter <10 microns in diameter PPE Personal Protective Equipment PS Performance Standard PTW Permit to Work QMR Quarterly Monitoring Report RoW Right of way SEP Stakeholder Engagement Plan SHERPA Safety Health Environment Radiological Protection Data Acquisition SLC Sustainability & Local Content SMP Security Management Plan SO2 Sulphur Dioxide STI Sexually Transmitted Infection TRMS Takoradi Regulating and Metering Station Vitol Vitol Exploration and Production Limited Voluntary Principles Voluntary Principles on Security and Human Rights VRA Volta River Authority VUGL Vitol Upstream Ghana Limited WB World Bank WBG World Bank Group WMP Waste Management Plan WRCF Western Region Coastal Foundation


1700002167_Issue1_Final

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EXECUTIVE SUMMARY

In March 2018, Ramboll Environment and Health UK Limited (previously Ramboll Environ UK Limited), acting in the role of Independent Environmental and Social Consultant (IESC), undertook the third in a series of 6-monthly site visits to monitor the environmental and social (E&S) performance of the Offshore Cape Three Points (OCTP) project, Republic of Ghana (the ‘Project’). The Project is operated by Eni Ghana Exploration and Production Ltd (Eni Ghana). Vitol Upstream Ghana Limited (VUGL), an affiliate of Vitol Exploration and Production Limited (Vitol), and Ghana National Petroleum Corporation (GNPC) are JV non-operating partners.

The overall role of the IESC is to monitor the Project’s management of E&S matters, including the implementation of the Project Environmental and Social Action Plan (ESAP); the adequacy of Health, Safety, Environment and Sustainability Management Systems; and the implementation of a suite of E&S management plans intended to address applicable Project standards, notably the World Bank Group (WBG) Performance Standards1.

For the sake of consistency, the same two-person team that visited the Project in the previous monitoring visits (February 2017 and September 2017) also participated in this, the third, monitoring visit. Given the follow-up nature of the site visit the primary objectives were to:

1. Confirm closure of the issues identified during the previous visits;

2. Address any issues identified following review of the Eni Ghana’s Q4, 2017 Monitoring Report2;

3. Visit the offshore Floating Production Storage and Offloading (FPSO) facility to meet with Yinson (responsible for operating the FPSO) and inspect the facility;

4. Visit the Ghana National Gas Company (GNGC) Takoradi regulating and metering station (TRMS) to inspect construction works and follow up on issues identified by the WBG during an initial due diligence performed by the WBG during a previous visit;

5. Interview Eni Ghana’s main construction contractors;

6. Hold meetings with Project-Affected Community members; and

7. Revisit compliance with the updated ESAP (February 2018).

In addition, a key specific objective of the monitoring visit was to better understand the nature and status of a recent labour dispute (late February and early March 2018), including both the cause of the dispute and actions taken by the Eni Ghana to address the root causes.

The IESC was able to visit the GNGC TRMS and travel offshore to inspect the FPSO; however, the IESC was unable to revisit the Onshore Receiving Facility (ORF) because resolution of the labour dispute was ongoing at the time of the visit. Due to the inability to visit the ORF site, the IESC was unable to meet the intended range of Project-Affected Community members in a ‘face-to-face’ context. On the first day of the monitoring visit, Eni Ghana informed the IESC that two meetings could be organized using a VC and/or skype link from the Takoradi logistics base between the IESC and the participants (a group of farmers and a group representing fishery-based livelihoods respectively) being present in the ORF meeting room. The IESC agreed with this suggestion as it went some way to enabling work to be done with respect to achieving objective 6 of the site visit.

With regard to the first objective, the IESC found that Eni Ghana had made good progress with the closure of the actions reported following the previous IESC monitoring trip. The IESC was unable to confirm closure of a small number of previous issues, primarily because it was unable to visit the ORF but also due to time constraints.

1 WBG Performance Standards refer to IFC (January 2012), WB (July 2012) and MIGA (October 2013) Performance Standards 2 During the reporting period the IESC received the 2017 Annual Monitoring Report. Consideration of the 2017 AMR is included in this

report.



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The IESC was able to follow up on issues identified in its review of the Q4 2017 QMR, visit the FPSO and the GNGC TRMS thus satisfying objectives 2, 3 and 4. Meetings were held with the main contractors, Yinson, Sri EMAS, Technip and its sub-contractors Consar and Orsam. With the exception of a meeting on the FPSO with Yinson, these meetings took place in Takoradi rather than the site due to the ongoing labour dispute at the time. Although not ideal as compared to onsite meetings, the IESC was able to hold face-to-face meetings with key HSE staff from each of these organisations. Further meetings also took place with Saiwest (at the GNGC TRMS) and Technoserve (Eni Ghana office, Accra).

In relation to the seventh objective, the IESC found the Project to be compliant with the ESAP, noting the completion dates for certain deliverables have been extended with the Lenders’ consent.

Throughout the monitoring process, VUGL, Eni Ghana and Eni Ghana’s contractors cooperated fully and responded to all the IESC’s requests in relation to the monitoring effort.

The IESC found the Project to be compliant with the requirements of the ESAP, necessary management plans have been prepared and disseminated and the HSE and social matters are well managed. Nevertheless, 31 findings were identified during the monitoring visit. Of these 5 are considered to be of ‘High’ significance; 10 are considered to be of ‘Moderate’ significance and the remainder to be of ‘Minor’ significance.

The findings categorized as ‘High’ relate to:

1. Labour Management – recent labour disputes, prompted by workers’ grievances relating primarily to pay, have disrupted the construction, and there is a risk of further labour disputes. The IESC recommends that Eni Ghana makes best endeavours to gain awareness of any future labour disputes at the earliest opportunity to limit risk of worker concerns escalating to disputes. To facilitate this action, Eni Ghana should: i) mobilize on-site contractor human resources staff to implement ‘early warning’ actions; ii) require key contractor human resources staff to share social intelligence daily with each other and with a designated Eni Ghana senior manager; iii) devise and implement preventive actions, should intelligence indicate that a concern shared by several workers, might lead to a dispute/withdrawal of labour; and iv) undertakes an audit, focusing solely on the timescale/s taken to close-out grievances submitted via the Workers’ Grievance Mechanism, and amend the Workers’ Grievance Mechanism procedure accordingly.

2. Currently there is no senior member of the SLC team based at the ORF site available to advise, quickly, Contractor human resource personnel and, as necessary, lead dispute management actions early in the process. The IESC recommends deployment, as soon as possible, of a senior member of Eni Ghana’s Sustainability & Local Content (SLC) department to be based at the ORF site until the end of the construction phase. Regular communication on labour issues to be held between this SLC person and a senior Ghanaian staff member of the Human Resources/Personnel department;

3. Onshore Security Management following recent labour dispute- in light of the recent labour dispute a revised and updated risk assessment is to be undertaken and the Project Security Management Plan Onshore/Offshore amended accordingly, and re-issued. This update and revision needs to take account of all pertinent international and Oil and Gas (O&G) sector guidance on managing security provision. Also, A Memorandum of Understanding (MoU) should be agreed, as soon as possible, on the use of State actors (police and military) in the protection of assets and personnel. This MoU to be based, to the extent feasible, on international guidance; such as IFC’s (2017) Good Practice Handbook entitled ‘Use of Security Forces: Assessing and Managing Risks and Impacts: Guidance for the Private Sector in Emerging Markets’.

4. Offshore Security Management: fishing vessel incursions into exclusion zones - In addition, efforts to enforce offshore exclusion zones must continue/new initiatives must



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be sought to persuade fishermen to respect these zones. Eni Ghana should consider liaison with other O&G operators in the region to understand whether they have experienced similar issues, and if so, what measures have been used to enforce exclusions zones. Also, efforts to be renewed to try to progress reaching agreement on an MoU with the Ghana Navy with regard to mutual and shared responsibilities for preventing incursions and resolving them promptly when they occur;

5. Livelihood Restoration Transitional Support - ensuring that the proposed changes to the health and educational support measures targeted at eligible households under the Transitional Support component of the Livelihood Restoration (LR) programme maintain:

An equivalence in terms of delivery of ‘benefits’ to those eligible for Transitional Support so that there is no reduction in the ‘benefits’; and that

Funding sources are clarified so that there can be no perception that funding available to those eligible for Transitional Support has been reduced.

The findings categorized as ‘Moderate’ relate to:

1. Security gates at the GNGC Takoradi Regulating and metering Station – a second security gate was left open and unmanned. Controls and signage should be put in place to prevent unauthorised access/the uncontrolled introduction of an ignition source via the second gate;

2. Management of Project impacts on fisheries – reporting lines and senior managerial responsibilities are unclear. Clarification of reporting lines and senior managerial responsibilities relating to fisheries management functions;

3. Community grievances - increased efforts are required to assist the Fisheries Management Coordinating Committee to find resolutions for the 4 open fisheries-related grievances and then rapidly implement the required action/s so that they can be closed out as soon as possible;

4. Potential severance issues resulting from additional fencing at the ORF site – a review is required of the potential impacts of the additional fencing, at the ORF site, on access routes. Depending on the results, it may be necessary to implement design/location changes to avoid impeding access and/or actions that reduce the adverse impact/s on access to an acceptable level;

5. Labour management – to help avoid future labour disputes, a labour audit is required to confirm that all contractors have met their contractual obligations to their workers and, in particular, have paid their workers in full at the end of the construction period;

6. Labour management- there is some uncertainty about workers’ rights and responsibilities in different contractors’ contracts. Eni Ghana should therefore ensure clarity in contract terms and conditions. Contracts will remain different, but ambiguities and uncertainly about rights and responsibilities, in contracts, should be minimized to the extent possible;

7. Labour management - amend the Worker Management Plan to contain a requirement for repeat refresher training on worker terms and conditions of employment and worker rights and responsibilities (as provided to new recruits during induction) and then implement the refresher training according to the schedule set out in the revised Worker Management Plan;

8. Community health and safety – An important SLC post is not filled. Identifying and then appointing a qualified individual to occupy, formally, the post of ‘Community Health Management’ is viewed as a priority;

9. The date for termination of food aid has yet to be determined. Eni Ghana should ensure that the evidence base to be used to assist in determining the date for food aid termination is robust, credible and justifiable. This will require careful examination of the



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method to be used to acquire the needed data and consultations with Project-Affected Persons and community leaders on pre-determined indicators for food aid termination; and

10. Eni Ghana, working closely with Technoserve, to ensure that a replacement Project Manager, for the ‘Support Services’ component of the LR programme, is appointed and deployed as soon as possible.

The findings presented in this report should be incorporated within Eni Ghana’s audit findings and closure process, with evidence of corrective actions provided via the Lenders’ quarterly reporting process. The IESC will continue to undertake desk-top review of quarterly reports and perform a further monitoring visit in approximately six months (from the date of this third monitoring visit) during which the issues identified in this report will be revisited and their closure/status confirmed.



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1. INTRODUCTION

Ramboll Environment and Health UK limited (previously Ramboll Environ UK Limited) was commissioned in January 2017 by Vitol Upstream Ghana Limited (VUGL) to undertake environmental and social monitoring of the proposed Offshore Cape Three Points (OCTP) project (the ‘Project’), Republic of Ghana. The Project is operated by Eni Ghana Exploration and Production Ltd (Eni Ghana). VUGL, an affiliate of Vitol Exploration and Production Limited (Vitol), and Ghana National Petroleum Corporation (GNPC) are JV non-operating partners.

In fulfilling the role of Lenders’ Independent Environmental and Social Consultant (IESC), Ramboll Environ has a duty of care to a consortium of lenders (the ‘Lenders’) to the Project, including the International Finance Corporation3 (IFC), World Bank4 (International Development Association) and the Multilateral Investment Guarantee Agency5 (MIGA) which are all members of the World Bank Group (WBG).

This report provides the findings following the third of a series of independent monitoring visits in which the Project is assessed against applicable Project Standards, specifically, WBG Performance Standards and applicable WBG Environmental, Health and Safety (EHS) guidelines, thereby identifying any environmental and social risks associated with the Project’s realisation.

The same two-person team that visited the Project in September 2017 participated in this second monitoring visit. Given the follow-up nature of the site visit the primary objectives were to:

Confirm closure of the issues identified during the previous visits;

Address any issues identified following review of the Eni Ghana’s Q4, 2017 Monitoring Report;

Visit the offshore Floating Production Storage and Offloading (FPSO) facility to meet with Yinson and inspect the facility;

Visit the Ghana National Gas Company (GNGC) Takoradi regulating and metering station (TRMS) to inspect construction works and follow up on issues identified by the WBG during an initial due diligence performed by the WBG during a previous visit.

Interview Eni Ghana’s main contractors and environmental monitoring consultants;

Hold meetings with Project Affected Community members; and

Revisit compliance with the updated ESAP (February 2018).

The ‘Project Operator’ is Eni Ghana. Face-to-face interviews were held primarily with Eni Ghana’s:

Senior Management;

Health, Safety and Environment (HSE) Team;

Sustainability & Local Content (SLC) Team; and the

Security Manager.

Further face-to-face interviews were held with representatives of the following Eni Ghana contractors, including:

Technip India Limited (Technip) - the main contractor for construction of the ORF;

Consar and Orsam, both sub-contractors to Technip:

Yinson (FPSO);

3 Lender to VUGL debt financing package 4 Guarantor to support the gas development 5 Insurer for the lenders to VUGL, including Equator Principles Banks and Export Credit Agencies.



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SRI/EMAS (installation of 26-inch gas pipeline and landfall facilities);

Saiwest, the main contractor for the TTIP project; and

Technoserve (livelihood restoration ‘Support Services’ programme delivery);

Vitol’s Environmental and Social Assurance Manager and HSE Manager were also present during interviews and available to answer any questions raised by the IESC. On this occasion, representatives from the WBG did not participate in the monitoring visit. A GNPC representative did however participate as an observer to the monitoring visit.

Originally, it was planned that the IESC would meet a range of Project-Affected Community members; however, just before the arrival of the IESC to Ghana, labour unrest at the ORF site escalated and the IESC was unable to visit the ORF site area and, therefore, to meet with community members in a face-to-face setting. On the first day of the monitoring visit, Eni Ghana informed the IESC that two meetings could be organized using a VC and/or skype link with the IESC operating from the Takoradi logistics base and the participants (a group of farmers and a group representing fishery-based livelihoods respectively and all of whom are Project-Affected Persons (PAPs) being present in the ORF meeting room. Thus, two meetings were held via VC and skype links with:

A group of 10 fisheries-dependent individuals from the villages in the Project’s Direct Area of Influence (DAoI), including the Chief Fisherman of Bakanta and, also, a member of the Fisheries Management Coordination Committee (FMCC), plus 1 fishmonger (a woman). This group included both beach seine fishermen and offshore fishermen; and

A small group of farmers which, at the beginning of the meeting, consisted of 4 women only. Subsequently, two male farmers (they appeared to be, also, members of the Project workforce) joined and participated in the meeting discussion.

These two meetings faced some communication challenges (sometimes poor voice quality making mutual understanding difficult on occasions). Nevertheless, useful information was obtained and the meeting ‘results’ are used to illustrate certain issues or points throughout this report.



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2. SCOPE AND STRUCTURE OF THE REPORT

2.1 Scope of the monitoring visit

As a condition of the Project ESAP (Appendix 1), Eni Ghana and VUGL are required to appoint an IESC to monitor and report on the implementation of the ESAP and compliance with WBG Performance Standards and Project Environmental and Social (E&S) commitments.

This E&S Monitoring Report details the Project’s compliance with the applicable Project Standards listed in Section 2.2, and in doing so, presents the E&S risks associated with the Project. It has been prepared for the attention of VUGL, the IFC and other entities defined as relying parties6. It addresses the various components of the Project (as defined in Section 3, Project Description).

The report presents the findings of the monitoring visit based on information gained following: interviews with Eni Ghana personnel, key contractors and their subcontractors, certain Project- Affected Community members and other stakeholders as listed in Section 1 above. This report also provides a description of visual observations made during walkover inspection of Project facilities, notably the GNGC TRMS and the FPSO.

A full list of Project documentation reviewed during preparation of this E&S Monitoring Report is provided in Appendix 2.

The site visit was undertaken during the period 12-16 March 2018. The tasks performed are summarised below and detailed in the monitoring visit itinerary (Appendix 3):

An opening meeting followed by meetings, in the Eni Ghana offices, Accra, with Eni Ghana HSE and SLC teams;

A three-day visit to active Project locations including the Takoradi logistics base, FPSO and GNGC TRMS for site walkover inspection and meetings with construction contractors and Eni Ghana’s Security Manager. Also during this period, meetings with community members (farmers and those with fishery-based livelihoods); and

Further meetings in Accra with Eni Ghana HSE and SLC teams and Technoserve (responsible for delivery of the livelihood restoration ‘Support Services’ programme) and a close-out meeting to present preliminary findings.

Meetings and interviews primarily concerned the management and monitoring of the following Project Health, Safety, Environment and Sustainability (HSE and S) aspects:

Waste management;

Audit and inspection programmes;

Management of change;

Land-based livelihood restoration (planned implementation actions);

Fisheries displacement and impact management (fishing and fishmongering);

Labour and working conditions, primarily the labour dispute;

Environmental monitoring;

Greenhouse Gas Emissions monitoring;

Influx management;

Community Investment Strategy;

Stakeholder engagement/grievance mechanism;

Occupational Health and Safety (OHS) plans and procedures;

6 Relying parties include World Bank, MIGA, Eni Ghana and other lenders.



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Security management;

Operational readiness; and

ESAP discussions.

2.2 Project Standards

In accordance with the IESC’s Terms of Reference, the Project was assessed against the following standards and guidelines:

Applicable laws and regulations of Ghana;

WBG Performance Standards (2012):

PS1: Assessment & Management of Environmental & Social Risks & Impacts;

PS2: Labour and Working Conditions;

PS3: Resource Efficiency and Pollution Prevention;

PS4: Community Health, Safety, and Security;

PS5: Land Acquisition and Involuntary Resettlement; and

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources;

WBG Environmental Health & Safety (EHS) Guidelines applicable to the Project including:

- EHS General Guidelines (2007);

- EHS Guidelines for Offshore Oil and Gas Development (2015); and

- EHS Guidelines for Onshore Oil and Gas Development (2007).

PS7 (Indigenous Peoples) was excluded from the scope of the independent monitoring on the basis that the Environmental and Social Due Diligence7 performed prior to financial close concluded that no Indigenous Peoples are affected by the Project.

PS8 (Cultural Heritage) was excluded from the IESC’s scope, however some text is included insofar as it relates to specific issues such as shrines and chance finds (Section 12). The IESC also notes that Eni Ghana has developed a Cultural Heritage Management Plan.

2.3 Structure of the Report

Section 3 below describes the status of construction activities at the time of the visit. Section 4 describes how different levels of significance are attributed to issues highlighted in the report, and Section 5 outlines the Ghanaian legislative framework and other applicable Project Standards. The report is then structured around the seven IFC Performance Standards applicable to the Project as listed above. The key issues identified during the monitoring visit are summarised in ‘significance tables’ for each Performance Standard. The status of key issues identified in previous monitoring reports is provided in Appendix 4.

The report has endeavoured to provide a balanced opinion, providing examples of good practice. However, due to the nature of a compliance report, and the broad range of aspects covered, it does focus on observations and non-compliances.

2.4 Limitations

At the time of the visit, work at the ORF had halted following a labour dispute. Whilst work restarted towards the end of the monitoring visit it was agreed by all parties that the IESC would

7 An environmental and social due diligence (ESDD) exercise was performed by KBC Process Technology Ltd on behalf of potential

lenders [Ref - Environmental and Social Review OCTP Project, Ghana September 2016]. The ESDD Report identified a number of issues and made recommendations that were transposed into an Environmental and Social Action Plan (ESAP). The ESAP provided in the ESDD report formed the basis of the final agreed ESAP included in Appendix 1 of this report.



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focus its attention on offshore (FPSO) and TTIP facilities; this approach was largely consistent with the agreement made following the previous visit. Nevertheless, meetings were held with some community members via VC and skype links. Face-to-face meetings with ORF based contractors took place at the Takoradi logistics base (for SLC issues) and the Atlantic Hotel, Takoradi (HSE issues).

The IESC only considered activities relevant at the time of monitoring visit based on ongoing Project activities. Future activities will be the subject of forthcoming monitoring visits.



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3. PROJECT DESCRIPTION

This section is intended to provide a brief description of the Project and the status of construction activities at the time of the visit. It also highlights any material design changes that might result in HSE or S impacts. A more comprehensive project description, inclusive of the socio-economic setting, was provided in the first IESC monitoring report and is not duplicated here.

3.1 Project description

The Project involves the development of the Sankofa East oil field and non-associated gas in the Sankofa and Gye Nyame Gas Fields, which are located 55 to 60 km offshore in the Western Region of the Republic of Ghana. The operator, Eni Ghana is developing these fields as an integrated oil and gas development Project utilising a newly converted double-hulled FPSO facility. Other key components of the Project include:

Fourteen wells for oil exploitation (producing and injection wells); oil will be transferred to shuttle tankers before export;

Five wells for non-associated gas exploitation;

A 63km subsea gas pipeline from the FPSO to shore;

A 1.5 km onshore gas pipeline from the shore to the ORF;

The ORF, including a gas compressor station, accommodation camp, firefighting station, helipad and medical facility; and a tie-in to the existing Ghana National Gas Company (GNGC) 20-inch gas pipeline;

A logistics base in Takoradi and a quay within the port of Takoradi; and

Upgrade of regulating and metering stations associated with the West Africa Gas Pipeline (see Section 3.2, Material Design Changes).

The Project is split into two phases:

Phase 1: Oil Development Project. This phase will consist of the 14 subsea wells (8 oil producers, 3 water injectors and 3 associated gas injectors), subsea facilities, and a FPSO unit that would be located approximately 60 km offshore south of Sanzule; and

Phase 2: Gas Development Project. This phase will consist of 5 subsea wells, subsea facilities, gas treating facilities on the FPSO unit, a 63km subsea gas pipeline (gas export sealine or GES), the ORF, and tie-in with the GNGC sales gas pipeline.

3.2 Material design changes

3.2.1 Micro tunnelling

In the previous monitoring report, the IESC highlighted the Project’s intention to use a Horizontal Direction Drilling (HDD)/micro tunnelling technique for the subsea gas export sealine landfall instead of the original planned open-cut trench beach crossing method. The environmental and social benefits associated with this option were also described. During the March 20182018 monitoring visit Eni Ghana informed the IESC that the length of the microtunnel would be reduced from 1 km to 770m. Post visit note: The IESC has been informed that Eni Ghana is considering simplified trenching option because of technical difficulties encountered during microtunnelling.

3.2.2 Takoradi / Tema interconnecting project (TTIP)

The Project scope has been amended to include the upgrade of RMSs in Takoradi and Tema to allow transport of additional gas at an increased pressure via the West Africa Gas Pipeline



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(WAGP) to Accra and beyond. Consistent with the change in the scope of the Project, the IESC remit has been amended to assess and report on the compliance of the TTIP (Figure 1).

Figure 1: Location of upgrade works for the TTIP

3.2.3 Infilling wells

During the visit the IESC was informed that Eni Ghana is considering drilling an additional 4 infilling wells. At the time of writing it is unclear whether Eni Ghana intends to proceed with the additional wells.

3.3 Status of the Project at time of the monitoring visit

At the time of the March monitoring visit the FPSO was in position and lifting oil since mid-2017, materials supply was complete and drilling and completion ahead of schedule. Construction of the ORF tie-in to the GNGC gas pipeline was also complete. However, construction of the ORF and gas export pipeline (between the FPSO and ORF) was behind schedule.

Progress at the ORF was on schedule until July 2017 but has since slipped. Construction work at the ORF was 77.4% complete compared with a planned progress of 87% (end of January 2018). Several factors have contributed to the slippage, including labour unrest occurring immediately prior to and during the IESC’s visit. Eni Ghana has rescheduled the work plan to accelerate construction such that the original target (25th June 2018) for start-up will be met. Key to this acceleration will be the use of additional manpower in the form of additional employees and not by means of increased overtime working.

Laying of the shallow water section of the 26” gas export sealine has been completed, however overall progress with the gas export sealine is also behind schedule with 55.3% actual completion compared with a planned completion of 76.6% as of end January 2018. The delay has been caused by technical issues associated with the microtunnelling at the landfall. To meet the original timeframes Eni Ghana has adjusted the sequencing of pipelay activities and shortened the buried section of pipeline. Drilling was scheduled to restart at the end of March 2018.

The TTIP contract was not awarded on the planned date. Construction works are progressing to plan, however Eni Ghana is looking to accelerate progress because of the late start.



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At the time of the March monitoring visit, overall progress was 89.5% compared with the overall planned project schedule of 91.9% i.e. slightly behind schedule. As of 31 December 2017, the workforce consisted of 1164 employees at the ORF site excluding the security guards who number 588 (an increase of 434 since the equivalent figure presented in the September 2017 IESC monitoring report). Of these 1164 workers, 91% are Ghanaian and 32% are from the DAoI communities; these proportions are down a little from the previously reported figures. There are 112 workers on the FPSO and 230 on the Maersk Voyager. None are from the DAoI and the Ghanaian proportions are almost 50% for the Maersk Voyager and 27% for the FPSO respectively (these proportions, also, are down compared to those previously reported). No figures are available for the support vessels.

8 Figures taken from the Q4, 2017 monitoring report prepared by Eni Ghana



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4. SIGNIFICANCE ASSESSMENT

4.1 Review Findings

A summary of the review findings is presented in a significance table at the end of each section. For each item, the following is presented:

The topic/aspect;

A description of the issue, for example deficiencies or omissions;

The phase(s) to which an issue relates;

Identification of the standard(s) against which the deficiency has been identified;

The IESC’s recommendation, where applicable, to resolve/manage the deficiency; and

The significance on a three-point scale (see below for criteria).

4.2 Assessment of Significance

A ranking system has been used to indicate the relative significance of an issue identified during the monitoring visit. As well as highlighting the most important areas requiring attention, it can also be used to aid the tracking and rectification of specific items requiring improvement.

Identified issues have been placed into one of the following three categories:

Minor: Minor non-compliance, risk or minor technical breach of Applicable Standards and commitments with no material, actual or likely potential: environmental or social consequences; or significant human injury or harm.

Moderate: Moderate non-compliance or risk with actual or likely potential: localised and short-term environmental or social consequences; minor human injury or harm; or material short-term breach of Applicable Standards and commitments.

High: Major non-compliance or risk with actual or likely potential: spatially extensive and/or long-term environmental or social consequences; serious human injury/death or harm; or material and extensive breach of Applicable Standards and commitments.

Not Item is noteworthy, but it is not an issue of non-compliance. Applicable

Where time-critical recommendations for specific actions are made, a timeframe linked to Construction/Operational phase milestones is indicated in the IESC recommendation column. Time-critical issues can lead to a higher classification of significance.

Table 1: Example of the summary table format

ID Aspect Issue Description

Phase9 Standard IESC Recommendations

Significance

00 Storm water runoff – monitoring

The ESAP requires Company X monitors the quality of surface water run-off from facilities.

Ops WBG EHS Guidelines ESAP

Company X shall expedite procurement of monitoring equipment with the support of senior management.

Moderate

9 Phases can include: construction; operations; decommissioning or any combination of these phases.



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ID Aspect Issue Description

Phase9 Standard IESC Recommendations

Significance

To date the Company has been unable to procure monitoring equipment – no monitoring has been undertaken.



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5. LEGISLATIVE FRAMEWORK AND OTHER PROJECT STANDARDS

5.1 Summary of legislative framework

The undertaking of projects such as oil and gas developments requires registration and authorisation by the Environmental Protection Agency (EPA). The EPA was established under the Environmental Protection Agency Act (Act No. 490 of 1994) as the leading public body responsible for the protection and improvement of the environment in Ghana. The EPA has the authority to require an EIA Report and is responsible for issuing and enforcing requirements specified in environmental permits. Permits are also required from other regulatory bodies including the Petroleum Commission (PC), Energy Commission (EC) and Ghana Maritime Authority (GMA).

5.2 Permitting

The status of key permits is presented below.

Permit and expiry date Expiry date IESC Comment

ORF Construction Permit from the Energy Commission (EC)

10 September 2018

Permit duration extended by a letter from EC dated 8th September 2017 granting a 1-year extension

ORF Construction Permit from the Petroleum Commission (PC)

10 August 2018

Permit no. PC/001/CP/ENI/2016

Operation Permit for FPSO Commission & Testing issued by the PC

19 August 2017 and then extended to 31st March 2018

Due to expire shortly after the monitoring visit – status of this permit should be clarified in April 2018.

Operation permit - production and associated commissioning (Offshore) issued by the EPA

14 November 2018

Initially extended by a permit (ref. EPA CE00217801179) through to July 2018 then subsequently annulled and merged with the new Production (Operation) Permit CE0021780218 issued by EPA on 15 May 2017.

Offshore Pipe Laying Permit (GMAP/ES/PL/17/001) issued by the GMA

15 November 2018

Can be renewed on an annual basis

Offshore Oil Wells Installation Permit (GMAP/ES/SSI/17/001) issued by the GMA

15 November 2018

The permit is for 19 wells

EPA Environmental Permit (CE0021780338) issued to Eni Ghana to undertake the proposed offshore drilling of four infilling Development wells, Issued 19 February 2018.

18 February 2019

IESC was informed that a final decision to proceed with the infilling works had



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Permit and expiry date Expiry date IESC Comment

not been made at the time of the visit

EPA Environmental Certificate (CE00031560462), issued to GNGC 13 January 2018, to commence construction of …….and associated works in the Takoradi Regulating and Metering Stations at Aboadze in the Western Region.

13 January 2019

The permit was issued to GNGC

In the September 2017 IESC Monitoring Report, it was noted that the offshore pipe laying permit issued by the GMA was due to expire on 15 November 2017, and that the validity of the permit was insufficient with pipelay activities due to extend into 2018. The IESC confirms a new permit was issued by the GMA on the 15th November 2017 that extends to 14th November 201810.

The IESC was also informed that Eni Ghana is in the process of obtaining a Hydrotest Permit for the gas export sealine. This permit will be required prior to discharge of hydrotest water during the pipeline pre-commissioning phase and is expected in May 2018.

The IESC has been given access to the permits referenced in the table above and can confirm they have been acquired by Eni Ghana. In summary, the IESC is not aware of any missing permits necessary at the time of the visit.

10 Permit no. GMAP/ES/PL/17/001



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6. PERFORMANCE STANDARD 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS

6.1 Requirements specified in the ESAP

The ESAP was revised with the Lenders agreement and reissued on the 1st February 2018. The changes relate to item 10 which requires development and implementation of a Livelihood Restoration Plan. Whereas the actual item 10 ‘Task’ is unchanged, the ‘Indicator of Completion’ and timeframes have been modified as follows. The revised dates are highlighted yellow in Appendix 1 and are included below for convenience:

d) Update report by Eni Ghana/Vitol on actions taken (e.g., financial training, food aid, education and health support, stakeholder engagement, feasibility studies by the 4 NGOs). The report will also summarize implementation issues faced in 2016-2017 and lessons learned by 28 February 2018.

e) Evidences of implementation included in the periodic E&S progress reports and Annual Monitoring Report (timeframe based on the LRP).

f) Interim Implementation Audit carried out by an external competent resettlement professional and report submitted to WBG by 31 March 2019.

g) Finalization report by implementing organization submitted to WBG and Completion Implementation audit carried out by an external competent resettlement professional and report submitted to WBG. Timeframe: Finalization report: at the completion of the LRP; Completion audit: One year after the completion of the implementation of the LRP.

Further commentary on d) is provided in Section 10.2.

Other ESAP items due since the previous monitoring visit in September 2017 are listed below with cross-references to where they are addressed in the report.

Item Task Indicator of completion

Timeframe (due date)

Comment/Cross reference

3 Well Control Emergency Response Plans

Auditable evidences of implementation provided to WBG in the Annual Monitoring Report

31 December 2017

Eni Ghana conducted a level three oil spill drill in October 2017 - see Section 6.9.

6 Refinement of the air emission dispersion and noise propagation modelling

Modelling updated and submitted to WBG

31 October 2017

Submitted to WBG and received by IESC - see Sections 8.1 and 8.2.

8 Quantification program for GHG emissions

a) Quantification and minimization program for GHG emissions submitted to WBG b) First annual report by anticipated completion date.

31 October 2017 31 December 2017

Submitted to WBG and received by IESC - see Section 8.5. Note. First report will be for a partial year

11 Fisheries Management Plan

Evidences of implementation of the FMP and participatory monitoring program

31 December 2017

Submitted to WBG and received by IESC - see Section 10.3.



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Item Task Indicator of completion

Timeframe (due date)

Comment/Cross reference

included in the Annual Monitoring Report

12 Biodiversity Management Plan

Evidences of implementation of the BMP / BAPs included in the Annual Monitoring Report

31 December 2017

Eni Ghana commissioned the services of GWS to implement the BMP/BAPs. GWS reports were attached to the AMR – see Section 11.2.

14 Community investment strategy

Final Community Investment Strategy submitted to WBG

31 October 2017

Submitted to WBG and received by IESC - see Section 6.5.

The IESC concludes that there are no overdue actions/deliverables based on the dates specified in the revised ESAP.

6.2 HSE and Sustainability Responsibilities and Resources

As indicated in previous reports, Eni Ghana has established HSE and the SLC teams that have strong leadership and team members that demonstrate a good level of competency. During the recent monitoring visit Eni Ghana’s HSE and SLC resourcing levels were revisited.

The HSE team continues to be led by an experienced HSE Manager and in general the team is stable with few personnel changes. Two new HSE specialists are in place as part of the operational readiness programme and a further additional staff member is required at the earliest opportunity to provide assistance to the TTIP. Otherwise the HSE Manager confirmed he has an appropriate level of resourcing in place and that these resourcing levels will soon start to decrease as construction draws to a close. The structure of the HSE team is provided in Figures 4 (Project) and 5 (Operations as of March 2018). See also Section 6.13, Operational Readiness.

The HSE and SLC teams continue to receive good support from senior management. Confirmation was received from managers of both departments that they continue to be satisfied with the level of resourcing made available; that is, they are not constrained by resourcing levels.

A copy of the current SLC organogramme is shown in Figure 2. An important change in personnel has occurred in terms of responsibility for resettlement/livelihood restoration. The post of Livelihood Restoration Advisor no longer exists. A new post of Local Sustainable Development Coordinator has been created with the current occupant being in place since 20 October 2017 (start of contract). The Local Sustainable Development Coordinator retains direct managerial responsibilities for livelihood restoration and sustainable development work except for issues relating to the ‘delivery’ of the Fisheries Management Plan. Starting work at the end of October 2017 allowed for a ‘handover’ period which enabled the occupant of the new post to become familiar with the intricacies of both the Project and land-based livelihood restoration issues.

There are other changes that relate to the management of fisheries issue. In the current organogramme, the Fishery Management Plan Delivery Officer, and the ‘National Service’ supporting staff member, are linked to both the Local Sustainable Development Coordinator and the Local Content & Community Relations function. As shown in Figure 2 the linking lines are not solid instead they are two differing ‘dashed’ lines indicating an indirect linkage. Previously, the Fishery Management Plan Delivery Officer reported directly to the Livelihood Restoration Advisor (Figure 3). The change in location and reporting responsibilities of the Fishery Management Plan



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Delivery Officer function brings it closer, institutionally, to the Community & Fishery Liaison Supervisor. The Fishery Management Plan Delivery Officer function is based in Sanzule as is the Community & Fishery Liaison Supervisor.

The IESC notes that a comparison of the two organograms shows that management of fisheries issue is now more consolidated under the direct responsibility of the Local Content & Community Relations function. However, reporting lines are not clearly defined as there remains an indirect link to the post that is a de facto replacement of the Livelihood Restoration Advisor. Essentially, reporting lines are now more complex, and the allocation of responsibility is less clear-cut. Another uncertainty centres on the responsibilities of the Local Content & Community Relations function and the current ‘manager’ (it is noted that the acting ‘manager’ of the Local Content & Community Relations function is also the Regulatory Affairs and Stakeholder Engagement Coordinator and will be the acting ‘manager‘ until the incumbent returns from training in Eni’s Head office in Milan). This function is already responsible for local content, community relations and the work of the Community Labour Relations Officer. Responsibilities for fishery-related issues have been given to a manager that is also responsible, to a certain extent, for labour relations (an issue of increasing prominence and concern as the construction effort increase to meet the expected delivery date for first gas in June 2018) and other functions.

A meeting with fishermen (all men) and a fishmonger (the sole woman), attended by the IESC’s social specialist, demonstrated that the issue of economic displacement and payment for disturbance to livelihoods is causing concern to those dependent on fisheries. There are some key issues still ‘unresolved’, to the satisfaction of all parties, such as the calculation of the disturbance allowance for loss of ability to fish from the beach during the period when the pipeline is being laid below a section of the beach between Sanzule and Anwolakrom. It may be expected, reasonably, that managing the expectations of those dependent on fisheries will be an important task for the Project soon.

The current institutional change with respect to management of fishery-related issues may not be conducive to ensuring sufficient senior management oversight to ensure the successful delivery of this responsibility. It is suggested that the SLC Department ensures that there are clear reporting lines and identification of the senior manager that has responsibility for management of fishery-related issues. The effectiveness of the change in the management of fisheries issues will be investigated in the forthcoming IESC monitoring visit in Q3 2018.

There has been an addition to the set of SLC management functions with the creation of a post entitled Community Health Management. Currently, this post is not filled, but the holder of the new post of Social Projects Assistant Manager is responsible for this function in the interim. Also, under the Community Health Management function is a new post of Eni Foundation Activities & Evaluation Officer - with a staff member already in place.

The current SLC organogramme contains 39 posts of which 2 are not filled and 7 are occupied by ‘National Service’ personnel. Twenty-two (22) staff members (just over 50% of the SLC complement) are based in Sanzule indicating the continuing commitment, noted in the IESC’s September 2017 monitoring report, to implementation of a ‘policy’ of locating staff to the Project site (Sanzule). In total, the staff complement has risen slightly from 36 to 41 (14% increase) since the September 2017 monitoring visit compared to an increase in staff of 57% recorded between February and September 2017. The reduced level of the rate of increase probably reflects a management view that the staff complement is now reaching the number considered adequate for managing all sustainability and local content issues.

The SLC Department continues to be supported by the Eni HQ Sustainability function, which is based in Milan. Senior staff remain based in Accra.



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Figure 2: Sustainability & Local Content Department Organogramme – March 2018



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Figure 3: Draft Sustainability & Local Content Department Organogramme – September 2017



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Figure 4. Safety, Environment and Quality Organogramme – March 2018 (Project)



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Figure 5. Safety, Environment and Quality Organogramme – March 2018 (Operations)



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6.3 Contractor management and performance

6.3.1 SLC issues

As stated in the IESC’s September 2017 monitoring report, Eni Ghana prepared a set of generic SLC requirements (Ref: SUST-STAN-007-00, entitled ‘Sustainability & Local Content Requirements for Contractors’ and referred to as Appendix Y) which have been ‘cascaded’ to all contractors. Appendix Y requires contractors to ensure that its ‘Sustainability & Local Content Program’, to be submitted to Eni Ghana, requires implementation of, ‘…Eni Ghana applicable commitments which is disclosed and accessible in IFC/WBG website under ‘Client Documentation’. This statement refers to the applicable suite of Eni Ghana management plans. Several issues are raised in the IESC September 2017 monitoring report about the suitability of this website as a vehicle for transmitting, efficiently, the required plans to contractors as well as specific issues about its content and maintenance. The IESC has since been informed that the documents were posted on the IFC/WBG website for disclosure purposes, rather than as the only point of access for contractors. Whereas the link should be tested to confirm it is functioning, it is understood contractors can access the materials independently of the web link.

6.3.2 Security

In its September 2017 Monitoring report, the IESC reported that Eni Ghana had produced a revised and updated version of its Security Management Plan11 although, at that time, it was still a draft (Rev01) and had been commented upon by WBG. Subsequently, a further updated and revised version was prepared and approved by Eni Ghana, with an effective date of 1 January 2018 (entitled OCTP Integrated Project Security Management Plan Onshore/Offshore [SUST-PLAN-006] – referred to as the Project Security Management Plan (SMP).

Security-related requirements are provided to potential contractors via Appendix Q. During the March 2018 IESC monitoring visit, the IESC held a meeting with the Security Manager who confirmed that, following the labour unrest and closure of the ORF site, the existing Risk Assessment (basis for the focus of certain of the Plan contents) would be reviewed and the Plan revised accordingly. In its September 2017 monitoring report, the IESC recommended that, following approval of the Plan, Appendix Q should be amended prior to issue to potential/actual sub-contractors. Given the fact that the Project SMP was already under review with a revised version to be approved soon, the IESC did not consider it to be useful to check that the (then) current version of the Project SMP and Appendix Q were aligned. It is planned to undertake this check during the forthcoming IESC monitoring visit in Q3 2018/upon provision of the revised SMP. At the same time a random selection of ‘site-specific’ security management plans will be reviewed to determine the extent that they are aligned with the forthcoming updated/revised ‘Project-wide’ Plan.

6.3.3 Saiwest (construction relating to the TTIP)

Introduction

Saiwest (a joint venture involving Saipem and De Simone) was commissioned recently to perform upgrade works associated with the TTIP. Due to the recent and rapid commissioning of Saiwest the IESC had no previous interaction with Saiwest, nor any knowledge of its HSEC performance. As a consequence, a primary focus for the IESC during the monitoring visit was to inspect an active TTIP construction site and meet with HSEC representatives from both Saiwest and Eni Ghana to assess HSE and SLC performance.

11 OCTP Integrated Project Security Management Plan Onshore/Offshore (SUST-PLAN-006)



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The IESC team spent a day at the GNGC TRMS site at Aboadze near Takoradi. During this period the team conducted office-based interviews and had the opportunity to view ‘on the ground’ management of HSE and S matters. The monitoring visit therefore was a combination of office based discussions/document review and visual inspection of the site.

Of note, the works are relatively small-scale compared to other components of the Project and are, for the most part, being undertaken within an existing industrial site and therefore there are few concerns relating to biodiversity and the environment in general.

HSE Minimum requirements

Minimum requirements for Saiwest are specified within various Appendices to the contractual agreement, namely:

Appendix E – Minimum HSE Requirements (tailored to the TTIP);

Appendix Q – Security requirements (including requirement to develop a site Security Management Plan);

Appendix Y – Sustainability (including stakeholder engagement, recruitment and training and monitoring requirements); and

Appendix Z – Local Content Development Plan.

HSE Management System

Saiwest’s HSE Management System is based upon the Saipem MS which is ISO 14001, OHSAS 18001 and ISO 9001 certified, with each certification covering a wide range of services including project management and construction services for the oil and gas sector. The IESC understands Saipem’s MS shares a considerable level of commonality with Eni Ghana’s for historical reasons12.

The TTIP HSE Plan, dated January 2018, presents Saiwest’s organisation and arrangements (resources, responsibilities, procedures and plans) necessary to fulfil its contractual requirements to manage HSE. The HSE Plan covers the key aspects expected for a project of this nature, including Project standards; roles and responsibilities; management of subcontractors and suppliers, applicable HSE policies, key performance indicators, competency and training, emergency preparedness, risk assessments, environmental management and monitoring, and management review process. The HSE Plan is a high-level framework document that signposts other relevant HSE plans and procedures necessary for the management of HSE matters.

As with the other contractors there is close daily interaction with Eni Ghana personnel including a permanently present Eni Ghana HSE Supervisor. Consistent with all other construction contractors on the Project, Saiwest is contractually obliged to ensure the presence of 1 HSE professional for every 25 constructions workers on site.

Project HSE deliverables, as specified in Appendix E of Saiwest’s contract with Eni Ghana, include:

Project HSE plan;

HSE MS bridging document;

Emergency response plan;

Management of change procedure;

HSE training programme;

Incident notification, investigation and reporting;

Audit plan;

12 Historically Saipem was a subsidiary of Eni



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Environmental management plan (includes requirements for dust suppression, top soil management; invasive species, bush meat, noise control);

Waste management plan (use of ZOIL as waste management contractor);

Transportation plan;

Spill prevention;

Permit to work (PTW) procedure (broadly categorised as cold work, hot work and excavation work); and

Various plans and risk assessment procedures to manage HSE.

All HSE plans are reviewed and approved by Eni Ghana HSE Supervisor/Security Manager. Several of the documents listed above were provided to the IESC and are discussed below.

HSE Training

HSE Training requirements are defined in an HSE Training Programme document that includes a job role vs training requirement matrix. The trainings are primarily HSE related which is appropriate given the location and nature of works being undertaken. All personnel are given induction awareness training that includes environmental protection measures such as the policy on bush meat.

The IESC was also informed of a 2-week intensive training programme provided to workers following award of the contract. The training was purposefully held off site ahead of any upgrade works at the site.

Toolbox talks occur every morning. The on-site doctor (on site as a contractual requirement) participates in the toolbox talks.

Saiwest Employment Agreement

An example employment contract was provided for review. The contract is comprehensive and clearly states the terms of employment and therefore IESC has no observations following its review.

Safe working procedure/Permit to work

Saiwest operates a PTW Procedure as part of its approach to safe execution of work. The Procedure applies to Saiwest and its contractors working on the TTIP and has been reviewed and approved by Eni Ghana. The PTW procedure is consistent with PTW procedures elsewhere on the Project, with the exception that at the GNGC TRMS site, GNGC, as owner of the site, is also required to approve the permits.

Audit and Inspection

HSE inspections are carried out on a weekly basis and Saiwest has introduced a small incentivisation scheme to encourage the use of HSE Observation Cards13. Formal audits, with a joint Eni Ghana and Saiwest audit team, are carried out periodically. The IESC saw evidence of corrective actions following a previous inspection/audit, for example, the introduction of a T-Card system at the site entrance. However, emergency exit and muster point diagrams presented during the HSE induction did not indicate the location of the office in which we were present. It is understood this had been a finding of an earlier audit.

13 Saiwest stated that 57 observation cards had been submitted in the preceding month. A selection was reviewed by the IESC for

verification purposes.



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Incident Reporting

Saiwest has prepared an Incident Notification, Investigation and Reporting Procedure. The IESC was provided with evidence of incident reporting and notification.

Drug and Alcohol Policy

Saiwest doctor reported that random alcohol tests are carried out every 3-4 days by the site doctor. To date there have been no positive results.

Environmental monitoring

Environmental monitoring will be undertaken by ESL. The approach is sensible given ESL is undertaking environmental monitoring at other Project sites.

Waste management

Saiwest has prepared a waste management plan and contracted the services of ZOIL to manage its wastes.

Site walkover

The site is very small and the IESC was able to inspect the GNGC TRMS on foot. During the site visit, the IESC observed many examples of good practice and an overall high level of HSE management. Examples of good practice include: clear HSE information boards (photo 15); secondary bunding (photo 16); permit to work documentation on site; use of flagmen (photo 21); clear signage, segregation of wastes (photo 18), dust suppression (photo 19), recent inspection of fire extinguishers and correct use of Personal Protective Equipment (PPE).

The IESC does however make one significant observation. Upon entry to the live gas site via a gate in the internal perimeter fence, the IESC group was required to leave all ignition sources, including phones with the GNGC security guard. The security guard was equipped with a metal detector to confirm phones/other ignition sources were not taken into active gas plant areas. The control at this gate was robust, however a second gate was found to be open and unmanned allowing free access (photo 20). The IESC understands the second gate was opened as a temporary measure to allow vehicular access into the active gas site, but nevertheless uncontrolled access presents a risk of uncontrolled ignition sources being brought on site.

The IESC understands Saiwest is in the process of employing its own security team which will provide additional security resource.

Summary of HSE at the GNGC TRMS (Aboadze)

In summary, the IESC found the site to be well-managed and subject to the same requirements and oversight by Eni Ghana that has been witnessed by the IESC at other Project locations. Further commentary, including observations made during the site visit, are provided below in Section 6.10 and, also, in Chapter 7 (PS2 Labour and Working Conditions) and 8, PS3 (Pollution Prevention and Resource Efficiency).

6.3.4 Yinson (FPSO Contractor)

One member of the IESC team travelled by helicopter to the FPSO to meet with Yinson and Eni Ghana HSE representatives, and management on the FPSO, and then to undertake a walkover survey. Upon arrival the IESC was given a full HSE induction (typical for those arriving for a one-month rotation).

The Yinson HSE MS is compatible with Eni Ghana requirements and fully aligned by means of a Bridging Document approved by Eni Ghana (see previous IESC Monitoring reports). Time



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constraints prevented a detailed review of the implementation of the HSE MS. Instead the IESC efforts were directed to:

Key elements of the HSE MS, primarily the Permit to Work system;

monitoring of effluents; and

Observations made during the walkover inspection.

Permit to Work

An electronic Permit to Work system (UniSea14) is used on the FPSO. All PTW requests are discussed twice a day (at the beginning of each shift). The PTW system requires review and approval by various parties and ultimately no PTW can be issued until it receives sign off by the Offshore Installation Manager (OIM). The IESC’s PTW for use of a camera on the FPSO was evident in the system.

The UniSea software was demonstrated to the IESC and is considered to be working very well with strict controls in place. The electronic nature of the system allows access to the system from multiple locations, including onshore.

Monitoring of effluents

The FPSO is equipped with various effluent treatment plants to achieve compliance with applicable discharge limits. Certificates are issued to confirm equipment is designed to meet relevant standard, for example those of MARPOL, although a design certificate does not necessarily mean discharge limits are met.

Yinson explained systems are designed to shut down in the event of an exceedance, e.g. if the bilge water exceeded 15ppm oil content. The IESC requested evidence that the oil in water analyser was tested; a manufacturer’s factory certificate was provided confirming it was functioning within tolerance limits at the time it was despatched.

At this stage of production there is no discharge of produced waters.

Observations during the walkover

Numerous examples of good practice were observed including:

Localised bunding for temporary activities (photo 2);

Permanent bunding for modules and deck plugs (photos 4 and 6);

Waste segregation (photos 3 and 13); and

In-date fire extinguishers, life rafts (photo 10) and other equipment.

Whereas, based on a brief inspection the FPSO is well-managed, four observations providing opportunities for improvement are made.

1. Spill response bins should be fitted with soft locks to avoid depletion of the spill equipment stored within the bins and the bins should be checked periodically.

2. Large quantities of fuel/other hydrocarbon based products were stored without localised secondary containment (photo 12).

3. An unidentified 200 litre drum was present. The IESC understands the drum has been on board since the FPSO left Singapore.

4. Fishermen were continually breaching the 500m exclusion zone and mooring on the anchor chains where they were observed cooking over a naked flame (photos 8 and 11).

14 UniSea has multiple capabilities including PTW.



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The first three observations are relatively minor and can be readily addressed. The fourth observation is more significant and is discussed in more detail in Section 9.3.

6.3.5 Technip (and Orsam and Consar) – ORF

The IESC met with representatives from Technip, Orsam and Consar in Takoradi. During this meeting the IESC was provided evidence of ‘close out’ for issues identified in the preceding monitoring visit.

HSE performance at the ORF has been reported upon in the September 2017 IESC Monitoring Report and is not detailed again here. However, a number of statistics are provided below to emphasise the good performance and positive attitude towards HSE demonstrated by Technip and its sub-contractors.

Two Medical Treatment Injuries (MTI) to date resulting from a total of 1,721,940 man hours;

Zero Loss Time Injuries (LTIs)15;

There is a ratio of 1 HSE representative to 22 workers at the ORF;

3728 Permits to Work issued;

1.47% of total man hours is spent on HSE training;

Approximately 75 safety observation cards are submitted each month;

The site has 10 snake wranglers – if found snakes are safely removed without harm to the snakes;

All vehicles are fitted with an In-Vehicle Monitoring System (IVMS);

Random alcohol tests are performed;

Incentivisation scheme (on the spot prizes) in place for good HSE performance;

Workers are allowed to take breaks whenever they need a break (to avoid heat exhaustion); and

There is an on-site clinic, medical practitioner and ambulance.

Technip noted unauthorised access to the site was a problem.

6.3.6 SRI EMAS (offshore gas pipeline and Landfall Terminal End)

As stated previously, the IESC was unable to visit the Sri EMAS onshore Landfall Terminal End (LTE) work area at the ORF. Instead the IESC met briefly with non-HSE representatives from Sri EMAS in Takoradi. It is understood there are relatively few workers onshore (approximately 50 to 70). Of these there are 8 HSE representatives plus an Eni Ghana HSE representative.

The IESC was given a presentation about HSE management and was informed about closure of findings following an audit by Eni Ghana. The IESC was also informed that early housekeeping issues have been addressed, although the IESC is unable to give first-hand observations.

Of note, a grievance had previously been made about the absence of workers from the Project Affected Communities (PAC), that is those in the DAoI, at the Sri EMAS site. Sri EMAS explained many of the workers at the time had to be skilled and has since recruited approximately 6-10 PAC workers.

15 This compares favourably with the average LTI for Europe, which in 2017, was 0.7/million man-hours. Ref: Oil and Gas UK Health

and Safety Report 2017.



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6.4 Closure of earlier IESC findings

The IESC’s September 2017 monitoring visit made 28 findings many of which had recommended corrective actions. Where possible the IESC has revisited these findings within this report and described progress made towards the closure of earlier findings.

The issues identified in the previous monitoring visits (February 2017 and September 2017) are tabulated in Appendix 4 with an indication of the current status of each issue provided by the IESC.

The IESC was unable to revisit certain findings, in part because it was unable to visit the ORF. In such instances, the status is categorised as ‘pending’.

It is the IESC’s opinion that all significant actions are fully closed with the exception of the following ‘Moderate’ significance items taken from the February (Row xxx 2/17) and September 2017 (Row xxx 9/17) IESC monitoring reports:

Row 021 2/17 - Contractor management – The Project Security Management Plan has been revised and approved by Eni Ghana and it includes the ‘minimum requirements’; however, it will be updated and revised; therefore, this remains an OPEN (re-opened) action.

Row 023 2/17 - Landless labourers (the need for additional measures, following recent survey effort, needs to be confirmed); The IESC has been informed that an LR Programme Project-affected households survey has been conducted. However, it is unclear whether the survey results have triggered the need to identify and implement any additional measures. The IESC was not able to verify the situation during the March 2018 monitoring visit and the action remains OPEN on this basis. Of note, Eni Ghana considers this action to be CLOSED. The IESC will confirm this conclusion during the next monitoring visit in Q3 2018.

Row 027 2/17 - Influx management; Progress has been made; however, the IESC believes this action remains OPEN until the Multi-Stakeholder Forum is fully established and functioning.

Row 019 9/17 - Contractor Management (security); Appendix Q to be updated16 to reflect the approved and ‘signed off’ Security Management Plan. Once updated and revised Appendix Q to be issued with all ITTs/model contracts to prospective contractors (with a proviso that a contractor can seek Eni Ghana approval that security requirements are not applicable to its operations).

Row 020 9/17 - Implementation of LRP Support Services; Delays in establishing the complete LRP delivery team (in Accra and in the concession area) and in implementing the LR Programme have continued.

Row 022 9/17 – Influx Management; The potential effectiveness of the Influx Management Plan is threatened by the limited progress to date in establishing the collaborative multi-stakeholder forum for managing influx and of coordinated actions to manage influx. This item remains OPEN as the Multi-Stakeholder Forum is not yet established and functioning.

007 9/17 - Workers’ Grievance Mechanism: Not all Contractors are implementing the Workers’ Grievance Mechanism.

For the ‘open’ items listed above, the IESC acknowledges that good progress has been made towards closure. Minor items are not captured in the list, but are detailed in Appendix 4.

6.5 Community Investment Strategy

Action 14 of the ESAP requires, “Eni Ghana and Vitol Ghana, as partner of the OCTP project, will develop and implement a community investment strategy for the area of influence of the project 16 To some extent superseded because the Project SMP was updated, however Project SMP requires further revision which will then

need to be communicated to contractors.



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by identifying areas of potential social investment based on community assets and needs. The community investment strategy will be developed in consultation with local and regional stakeholders.”

Specifically, the ESAP requires a) the final Community Investment Strategy to be submitted to WBG by 10/31/17; and b) Updates and evidences of implementation of the strategy to be included in the Monthly E&S Reports and Annual Monitoring Report by 12/31/2018. As noted in the September 2017 IESC monitoring report, the focus of the Community Investment Strategy was expanded beyond the Project’s DAoI, following the agreement of all key stakeholders.

The IESC confirms that the final Community Investment Strategy was submitted for approval by the due date (submitted on 29 October 2017) with the final issue being dated and approved by Eni Ghana on 27 November 2017. Its ‘effective date’ is given as 08 December 2017.

Also, in Q4 2017, work started to implement parts of the Strategy with the aim of designing, agreeing and then implementing projects that could deliver ‘quick impacts’ to local communities near the ORF. Following initial internal meetings, the focus was on provision of potable water supply projects for selected DAoI villages. Subsequently, meetings were held in certain DAoI villages to introduce the project/s and obtain community support. The actions taken in Q4 2017 as recorded, with documentary support, in the Q4 2017 Quarterly Monitoring Report and, also, in the VUGL 2017 Annual Monitoring Report, enable the IESC to confirm that evidence has been provided, already, of Strategy implementation beginning from the date of the final version of the Strategy being submitted for approval.

6.6 Cumulative impacts and influx

ESAP line 5 states ‘Eni Ghana will report on their best efforts to engage other developers, local institutions and government, and other stakeholders in designing coherent management strategies to mitigate cumulative impacts.’

6.6.1 Cumulative impacts

Eni Ghana remains active, in joint efforts with WBG, to create a multi-stakeholder initiative to manage cumulative impacts, particularly influx impacts (Eni Ghana has prepared and is implementing its Influx Management Plan, to the extent feasible. See section 6.6.2 below).

As stated in the IESC’s September 2017 monitoring report, WBG representatives (IFC and IDA) conducted a joint scoping mission in Accra during the week of the IESC monitoring visit and met with the EPA, PC and with O&G companies that are WBG clients. As a result, the WBG has confirmed that it will host a workshop on 6 and 7 June 2018 (with invited stakeholders concerned about cumulative impact issues and their mitigation/management).

A meeting, involving the PC, WBG and Eni Ghana, was held on 11 October 2017 with a focus on influx management. One of the actions arising from this meeting was a ‘Multi-stakeholder workshop to discuss the Influx Management Plan, slated for the 2nd week of January, 2018’. This meeting did not occur17. Thus, progress in establishing an implementing a framework, such as the Multi-Stakeholder Forum, has occurred, but of necessity has been slow due to the multiplicity of stakeholders and the complexity of managing cumulative impacts at a regional/sub-regional level.

6.6.2 Influx in the DAoI

A key impact for the construction phase was, and still remains, the potential for influx into the DAoI settlements. An Influx Management Plan (IMP), effective 31 May 2016, is being

17 The IESC does not know why the meeting did not occur



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implemented to manage influx within the DAoI. Also, the revised Workers Management Plan and the Recruitment, Employment and Training Plan both contain measures that assist Eni Ghana to continue to make its contribution to influx management, primarily through the local content provisions of its recruitment procedure, which also applies to contractors and sub-contractors.

The IMP has been implemented since end May 2016 and the main Project construction phase will be mostly completed in the summer of 2018. The role of the IMP, in this context, was discussed by the IESC in a meeting with the Local Sustainable Development Coordinator, the ESAP Monitoring & Evaluation Coordinator and the Social Projects Assistant Manager. It was stated by the Eni Ghana personnel that there was little evidence of influx into the DAoI and, due to the demobilization of the construction workforce over the next few months, one of the key drivers for influx (job availability) would no longer be present. This view, which it was admitted is not based on results from a robust research programme, is given some support by the recent population projections for the Ellembelle District Assembly which showed projections for the DAoI villages in line with Ghana-wide expectations for a rural population growth rate indicating that there were no specific factors justifying using a higher rate as might be expected in an area which had been experiencing influx, and where it might be expected to continue.

The limited evidence, available to date, indicates that the IMP may not be required to be implemented, in its current format, once the construction phase is completed. Instead, it may be possible to adopt an adaptive management approach where evidence on influx is gathered, according to a robust and credible research protocol, on a regular basis, and the results are used, in the context of a regular review process, to determine whether the IMP should be ‘re-activated’ or amended to take account of new factors and then implemented. It is suggested that Eni Ghana consider whether an adaptive management approach is a feasible way forward, subject to agreement with WBG, in terms of being able to manage influx in a cost-effective manner. Should it decide that an adaptive management approach is appropriate then Eni Ghana should formalize the procedure to be followed in an operations phase IMP or Influx Management Framework.

As reported in both the September 2017 IESC monitoring report and the IESC’s Q3 2017 monitoring report, the Western Region Coastal Foundation (WRCF) had prepared an ‘influx management approach’. The IESC recommended that Eni Ghana determine whether this ‘WRCF influx management approach’ was an appropriate basis for revising the IMP. After the issue of a draft version of the IESC’s Q3 2017 quarterly monitoring report, the IESC was informed by Eni Ghana that the ‘approach’ related only to means of implementing the IMP’s actions. Thus, the IMP did not require a structural/content revision based on the WRCF ‘approach’.

6.7 Stakeholder engagement

Initially, the March 2018 monitoring visit itinerary included a visit to certain of the DAoI villages (Krisan, Bakanta and Sanzule) with the intention of holding meetings with those dependent on fisheries for their livelihoods (fishermen and fishmongers). In addition, a meeting was planned with selected representatives of the Fisheries Management Coordination Committee (FMCC). Just before arrival in Ghana, the IESC was informed that a visit to the DAoI was not feasible due to labour unrest at the ORF. Instead, and at short notice, two meetings were organized with two small, but separate groups of farmers and fisheries-dependent individuals (including one FMCC member and a single fishmonger), by Videoconference (VC) and Skype links respectively. This enabled one of the key intentions of the original visit itinerary to be met in part, although the communication medium posed some challenges in terms of meeting ‘management’ and mutual understanding. Despite the difficulties, the meetings yielded useful information.

Although the number of meeting attendees was small, these meetings confirmed previous IESC findings that the Project continues to disclose information and consult, effectively, with community-level stakeholders. In both meetings, participants confirmed their awareness of key



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facts pertaining to the implementation of livelihood restoration measures by Technoserve (farmers) and issues related to fisheries such as the proposed cash allowance for disturbance resulting from fishery-related disruption caused by pipeline laying in the inshore waters and beneath the section of the beach between Sanzule and Anwolakrom (fishermen and the fishmonger). For both groups, there were some specific issues/information where there was uncertainty or lack of clarity about specific details, but these related either to issues under discussion between the Project and the communities or to matters still to be disclosed, formally, and to be subject of consultation. Signs of stakeholder fatigue were present in the fisheries-focused meeting (perhaps due to the recent, comprehensive efforts to engage with those dependent on fisheries with respect to implementation of the Fisheries Management Plan, the establishment of the FMCC and the participatory fish catch monitoring work). Results from these meetings are used to illustrate IESC observations and specific issues, as appropriate, in the text of this Report (See Chapter 10).

6.8 Community Grievance mechanism

This section considers the following:

Eni Ghana Implementation of Community Grievance Mechanism; and

Contractor Implementation of Community Grievance Mechanism.

6.8.1 Eni Ghana Implementation of Community Grievance Mechanism

In line with its stated intention in its September 2017 monitoring report, the IESC focused attention during the March 2018 monitoring visit on the community Grievance Mechanism (as applied by Eni Ghana and contractors).

In the September 2017 IESC monitoring report, it is stated that, for the year 2017 to date (end August), 22 grievances were registered. The Eni Ghana 2017 Annual Report on the Grievance Redress Mechanism (approved on 01 March 2018) states that 35 grievances were registered in total for the year (13 additional grievances being registered in the 4-month period until the end of 2017). Two (2) grievances were escalated to the Grievance Management Committee. Four (4) grievances were not closed out though they had been resolved. The delay in closure was due, primarily, to outstanding payments yet to be received by the complainants.

Most grievances related to labour issues (18) - these are mostly issues such as the working of the local hiring process and equity between locals/non-locals and between the DAoI villages in terms of number of individuals hired and do not relate to individual workers and their perceived or actual prejudicial treatment while at work. Seven (7) grievances related to the Livelihood Restoration Programme (primarily the Transitional Food support delivery) and 10 are classed as ‘general’ grievances. A summary of 2017 grievance data is provided in Figure 3.

In 2018 to date, 17 grievances have been registered (almost 50% of the total for the whole of 2017 total). These include 9 grievances related to labour issues (reflecting the recent labour unrest in early March 2018) and 4 related to the Fisheries Management Plan. It is suggested that Eni Ghana increase its efforts to assist the FMCC to find resolutions for these grievances and then rapidly implement the required action/s so that they can be closed out as soon as possible. Six (6) grievances are open including all the fisheries-related grievances. However, all of the 9 labour-related grievances are closed which is consistent with the return to work and resumption of construction activities at the ORF site. A summary of 2018 grievance data, to date, is provided in Figure 6.

Figure 7 shows the source of grievances (by village only; therefore, excludes grievances form individuals) over the periods 2017 and 2018 to date. For 2017, most village-level grievances (18; almost 50%) emanated from Sanzule with the number of grievances originating from other



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villages being at a very low level (2 or fewer grievances). Sanzule has the second highest population of all the DAoI villages, is subject to more extensive and intensive exposure to impacts, and has more interaction with the Project compared to other villages. For these reasons it might, reasonably, be expected to generate, proportionately, a relatively high number of grievances; however, it is unlikely that the number of ‘Sanzule’ grievances in 2017 can be linked to population size alone. It is likely that another factor or factors are influencing the number of submitted grievances. The IESC is aware of the ‘risk’ implications, to the Project, of the continuing Sanzule chieftaincy dispute and the generation and submission of grievances may be a symptom of local political dynamics; however, the IESC has no evidence to support this potential explanation for the relatively high number of grievances from Sanzule in 2017.

Figure 6: Grievance summary data, 2017 and 2018 to date

Figure 7: Source of grievances by settlement, 2017 and 2018 to date



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In its February 2017 monitoring report, after review of Eni Ghana’s 2016 Annual Review of the Grievance Mechanism, the IESC noted that 23 grievances were recorded and closed out in 2016. These grievances were mainly related to a single livelihood restoration issue - the misinterpretation of information provided by the Project to community members, during the Transitional Support Food Aid ‘pilot’ testing period. There was an increase of 12 grievances (almost 50%) between 2016 and 2017. Unlike the 2016 situation when most of the grievances related to livelihood restoration issues, the largest number of the 2017 grievances focused on labour-related issues. This is of interest as it was in the middle of 2017 that labour unrest/disputes started to occur and then became progressively more prominent and disruptive toward the end of 2017 and then into Q1 of 2018. Despite the non-delivery of Transitional Support Food Aid in September 2017, the number of grievances related to livelihood restoration fell significantly.

The 2016 Annual Review of the Grievance Mechanism did not provide data on the individuals/organizations that were the subject of the grievances. However, the 2017 Annual Report of the Grievance Mechanism provides these details as does the Grievance Register. Figure 8 shows a section of the Grievance Register (a copy of the submitted grievance – may be a letter or an email or a completed copy of the Grievance Mechanism Registration and Acknowledgment Form is embedded in the column headed ‘Case No’).

It is noted that, in the 2017 Annual Report of the Grievance Mechanism, it is stated that some people are wary of submitting grievances for fear of being ‘victimized’. While this is an understandable perception for some people with limited or no experience of the operation of a formal Grievance Mechanism, Eni Ghana needs to ensure that local community members are made aware of the successful resolution of grievances and that the process works to the mutual benefit of both the Project and complainants (across all grievances).

6.8.2 Contractor Implementation of Community Grievance Mechanism

In its September 2017 monitoring report, the IESC reported a certain level of confusion, during a discussion with the Technip CLO (who was relatively new to the post), over the definition of a grievance and under what circumstances a grievance/complaint should be reported to Technip management and then passed on to the SLC team within Eni Ghana. In Q4 2017, workshops were led by the SLC department to reinforce the ‘message’ to contractors, regarding the key role of the Grievance Mechanisms (both community and workers) and the procedures to be implemented and tools to be used (for example, the Grievance tracker).

These workshops were followed by audits on the implementation of the Grievance Mechanisms in Q1 2018. In this context, the IESC notes that an ESAP Monitoring and Evaluation Audit, focusing on Rigworld Maersk, was undertaken in December 2017 and it was found that Rigworld Maersk was not aware of the Grievance tracker (see IESC September 2017 Monitoring Report for details of the grievance tracker). Remedial measures were formulated. An earlier series of audits focusing on ‘onshore’ contractors exercise was undertaken with regard to Technip, Consar, Orsam, Sri/EMAS and a small number of other contractors/sub-contractors, and resulted in broadly similar findings.



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Figure 8: Section of the Grievance Register



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6.9 Contingency planning

Emergency planning was reviewed only in the context of an Emergency exercise conducted in October 2017. Details of the exercise, including strengths and improvement points are provided in the report entitled ‘Emergency Response Exercise 3rd level Emergency Drill – Eni Ghana’, dated 17 October 2017. The emergency scenario included a power failure aboard the Maersk Voyager resulting in a loss of oil to sea and a medical injury.

The resulting action tracking register was viewed by the IESC. In total 18 actions are highlighted including inter alia:

Involvement and collaboration of JV partners needs to be ensured whilst planning and resource mobilization during an emergency; and

Eni Ghana to ascertain the emergency handling plans and facilities (speed boats, marine ambulance and air surveillance plane etc) currently in place with the various Ghana authorities and include this information in the Emergency Response Plan(ERP).

These example actions remained open/ongoing at the time of the monitoring visit.

Of note, various organisations were invited to participate as observers to the drill (letters were sent to the National Disaster Management Organisation (NADMO); Ghana Navy, PC, GNGC, GNPC and EPA dated 25th September 2017). The IESC agrees with the finding that future Level 3 drills should include active involvement of response partners/other relevant parties.

6.10 WBG preliminary TTIP audit findings

Representatives from the WBG visited the TTIP (specifically the GNGC TRMS at Aboadze) in September 2017 and identified a number of issues, with resultant actions, for further investigation. Thus, one of the key objectives of the IESC’s March 2018 monitoring trip was to visit the GNGC TRMS to inspect construction works and follow up on issues identified by the WBG during its initial due diligence. The majority of the actions were previously addressed in the IESC’s Q3 2017 Monitoring Report, with the exception of actions 3, 4 and 5, which are addressed below following discussion with Eni Ghana.

Action 3 - Eni Ghana and Vitol to perform an environmental, health and safety risk assessment at the existing facilities and along the existing 1.5km pipeline, as per Eni Ghana GIIP.

The TTIP Project HSE Plan includes a hazard identification and risk assessment process as part of an ongoing approach to the management of risk. Risk assessments are detailed and tailored towards specific plant/activities. The IESC was provided with an example risk assessment18 as evidence that the process was being followed, however it is understood that Eni Ghana and Vitol have not provided WBG with an overall HSE risk assessment of the TTIP facilities that fall under the Project’s scope.

Action 4 - Carry out a walkthrough of the line to document the status of the line RoW, any sensitivities and to ensure that there is no encroachment along the RoW. Eni Ghana and Vitol to present the relevant reports with findings to WBG.

In response to the WBG request Eni Ghana undertook a walkover survey of the 1.5 km pipeline Right of Way (RoW)19. The scope of the walkover included identification of any social sensitivities (cultural artefacts) and encroachment of industrial or residential buildings. During discussion with Eni Ghana it became clear that land-use, for example for agricultural purposes, was also considered during the survey.

18 Risk Assessment for Double Block and Bleed Plug System 19 Ref. TTIP RoW Social Survey Report, February 2018



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The survey report is brief, but the IESC was able to confirm through discussion with survey team members that the land does not support livelihoods. The IESC was unable to walk the RoW, but visual observations from the GNGC TRMS did not contradict the survey report findings.

Action 5 - Eni Ghana and Vitol to report on the land acquisition history and status for the 1.5km pipeline RoW, obtaining the relevant information from GNGC, confirming land ownership and that all land has been compensated. The report should also provide information on any eventual court cases or litigations associated with the land acquisition process.

During the IESC March 2018 site visit (and before the IESC’s visit to the TTIP site), an Eni Ghana report, entitled, Report on Land Acquisition and Compensation for 1.5 km Right-of-Way (February 2018) was provided to the IESC. The IESC reviewed the report prior to the TTIP site visit.

The IESC found the report to be a useful and comprehensive summary of the background to land acquisition/compensation regarding the entire pipeline right-of-way, but at the time lacking specific and clear justification for the conclusions reached on the 1.5 km section of interest. During a meeting with the report authors at the GNGC TRMS site, there was an opportunity for the IESC to seek an understanding on the specific situation regarding land acquisition/compensation for the 1.5km right-of-way. After considerable discussion, the required understanding was achieved and then the IESC made several suggestions as to how the report could be restructured to enable a clear presentation of its conclusions, with the appropriate justification, to be provided. Eni Ghana and VUGL agreed to re-draft the report and then to re-submit it to the WBG. Post visit note: As agreed during the site visit, a second report20 was prepared that focuses specifically on the 1.5km of specific interest to the OCTP Project. The report divides the 1.5 km length of pipeline into two parts (1km and 500m) and provides an explanation of the land acquisition and compensation processes undertaken for both as summarised below.

Acquisition and compensation for the 500m section – land was acquired by the Volta River Authority (VRA) in 1994 following land valuation by the Land Valuation Division (LDV). The affected community agreed to 4 community projects. At the time when the land was transferred to GNGC there were no livelihood activities within the 500m RoW. Compensation was offered to VRA for loss of acacia trees; VRA decline the compensation.

Acquisition and compensation for the 1 km section– the report states that compensation has been paid in 2014 to all affected land owners based on LVD valuations, but that they can appoint independent land valuers if desired. Affected land owners have filed a grievance concerning lack of funds to progress land claims. In response the LVD has ‘recommended that they will assist with land claim processing at a fee and this will be deducted from compensation benefits of the land owners’. This statement is unclear, for example, as to whether a claimant has to pay the fee regardless of the outcome of any claim. The implications of the situation described in the report will be further discussed in upcoming monitoring reports. To date no claims have been made against GNGC.

The report states there are no court cases and litigations against VRA or GNGC.

6.11 Audit and Inspection

IESC has reviewed Eni Ghana’s 2018 Audit Programme21. A total of 9 internal and external audits are planned that cover the main contractors and facilities, including HQ, FPSO, Sri EMAS operations – LTE and gas export sealine, logistics base, ORF and rig (the latter to be confirmed).

20 Report on Land Acquisition and Compensation for 1.5km Right of Way, April 2018. 21 Ref. pro ms hse 010 eni ghana – HSE Audit



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The audit programme does not identify the TTIP project, although it is known that GNGC TRMS has been audited/inspected.

The IESC was provided with an audit action plan from Sri/EMAS following an audit by Eni Ghana’s HSE team. A total of 14 corrective actions were identified with evidence of close-out. The observations were relatively minor housekeeping issues demonstrating the high standard of HSE management expected by the Eni Ghana HSE team.

The IESC was also provided access to an external audit report produced by Rina Services in November 201722. The audit assessed the Project against OHSAS18001:2007 and ISO14001:2004 and identified no non-compliances and only 5 relatively minor recommendations.

6.12 Management of Change

The Project has an established Management of Change Procedure which includes notification and reporting to Lenders where certain HSE or SLC materiality thresholds are reached. The Management of Change Procedure has been discussed in previous reports (February 2017) and its adequacy is not the subject of this section.

During the site visit, the IESC was informed that no design/other changes in the reporting period had required lender notification/reporting. The IESC was shown a Deviation Request Flowchart (detailing the deviation and notification process) and an actual Deviation Request made by a contractor. Both require the involvement/notification of the HSE Department, as evidence by Deviation request emails.

IESC discussed a number of potential changes including the four additional infilling wells (See Section 3.2.3) and additional fencing around the ORF site (following the recent labour dispute). It was explained that these were proposed changes at the time of the monitoring visit and therefore had not triggered the need to consider Lenders’ notification protocols.

The IESC notes that an EPA permit23 was received for the additional infilling wells, suggesting a strong likelihood this additional drilling will proceed. In the event that additional infilling wells will be drilled, the MoC procedure, including notification to Lenders as specified in the procedure, will be required. Similarly, Eni Ghana must consider the implications of the additional fencing and whether this triggers notification actions under the MoC procedure.

See also Section 10.2 regarding notification of change to the Livelihood Restoration Plan- transitional support on Health and Education.

6.13 Operations readiness

Eni Ghana is in the process of preparing for the start of operations at the ORF at the end of May 2018 and has developed an HSE Action Plan for operations. Bi-weekly readiness meetings are being held and 2 individuals working in rotation (back-to-back) are dedicated to revising the HSE documentation/management plans in readiness for operations.

As part of the operational readiness programme Eni Ghana will update the following plans prior to first gas:

ESHMP

Waste Management Plan

Onshore Pollution Prevention and Control Plan

Traffic Management Plan

22 Ref. Audit report 17 GE 246 ME 23 Environmental permit no. CE0021780338 issued to ENI Ghana by the EPA on 19th February 2018 to undertake the proposed

offshore drilling of four infilling wells in the OCTP Block



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Water Management Plan

Biodiversity Management Plan

Security management plan

At the time of writing this report the status for each of these plans is unknown and will be the subject of future monitoring. The IESC understands the agreed delivery date for these documents to be 26 May 2018.



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Table 2: Summary of Findings, PS1

ID Aspect Issue Description Phase Standard IESC Recommendations Significance

001_ 03/18

Saiwest closure of inspection findings

A number of findings were made following an inspection/audit of the GNGC audit facility. Whereas the majority of the actions had been closed out, one action relating to emergency exit and muster point diagrams was not closed. Specifically, the emergency exit and muster point diagrams did not indicate the ‘you are here’ location in order for users to orientate themselves.

Construction PS1 Ensure all audit/inspection findings are closed out.

For this specific observation emergency exit and muster point diagrams should clearly indicate the ‘you are here’ location in order for users to orientate themselves.

Minor

002_ 03/18

Security gates at the GNGC TTIP

A second gate was found to be open and unmanned allowing workers free access to a live gas plant presenting a risk of uncontrolled ignition sources being taken though the gate.

Construction PS1, PS2, PS4

Controls and signage should be put in place to prevent unauthorised access/the uncontrolled introduction of an ignition source.

Additional security may be required if the gate cannot be manned by the current GNGC security resource.

Moderate

003_ 03/18

Management of Project impacts on fisheries

Recent changes to the SLC department’s structure (as shown in the SLC organogramme) show a consolidation of fisheries management functions, but reporting lines and senior managerial responsibilities are unclear.

Construction and Operations

PS1 SLC Department to ensure that there are clear reporting lines with identification of the senior manager that has responsibility for management of fishery-related issues.

Moderate

004_ 03/18

Influx Management Plan (IMP)

Relevance and effectiveness of continuing to implement the IMP now that the construction phase is coming to an end (summer 2018).


PS1 Eni Ghana to consider whether it is feasible and cost-effective to change to an adaptive approach to managing potential/actual influx and to reach a

Minor



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decision on its preferred option as to the mechanism to manage influx. Should it decide that an adaptive management approach is appropriate then Eni Ghana should formalize the procedure to be followed in an operations phase IMP or Influx Management Framework.

005_ 03/18

FPSO walkover – soft locks

Spill response bins should be fitted with ‘soft locks’ to avoid depletion of the spill equipment stored within the bins.

Operations PS1 Use of soft locks (breakable in the event of a spill) to ensure the content of the spill bins is not depleted over time. The locks should be checked periodically.

Minor

006_ 03/18

FPSO walkover

Large quantities of fuel/other hydrocarbon based products where stored without localised secondary containment.

Operations PS1 Project should consider localised secondary containment around the stockpile and reducing the number of drums stockpiled on board the FPSO.

Minor

007_ 03/18

FPSO walkover

A 200 litre drum containing unknown contents was present. The IESC understands the drum has been on board since the FPSO left Singapore.

Operations PS1 Efforts are required to identify the contents of the drum. The drum and its contents should be safely disposed in accordance with the approved waste management plan.

Minor

008_ 03/18

Community Grievance Mechanism

Some community members appear to be concerned about potentially being victimized if they raise a grievance.


PS1 Eni Ghana to reinforce the ‘message’ of the impartiality of the grievance mechanism, with examples of the successful ‘close-out’ of grievances, at every opportunity in future engagement activities with DAoI communities (and other stakeholders).

Minor



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009_ 03/18

Community Grievance Mechanism

Four (4) grievances related to fisheries are not closed.


PS1 Eni Ghana to increase efforts to assist the FMCC to find resolutions for these grievances and then rapidly implement the required action/s so that they can be closed out as soon as possible.

Moderate

010_ 03/18

Emergency response exercises

Following a Level 3 emergency response drill it was observed that various parties were invited as observers rather than active participants.

The IESC agrees with the post exercise findings that future Level 3 drills should include more active involvement of response partners/other relevant parties.

Operations PS1 Level 3 drills should include active participation of third parties that would potentially be involved in an actual incident.

Minor

011_ 03/18

TTIP HSE risk assessment

Eni Ghana and Vitol to perform an environmental, health and safety risk assessment at the existing facilities and along the existing 1.5km pipeline, as per Eni Ghana GIIP.

It is understood that Eni Ghana and Vitol have not provided WBG with an overall HSE risk assessment for the TTIP facilities that fall under the Project’s scope

Construction PS1/WBG request

Eni Ghana and Vitol should provide WBG with a risk assessment for the TTIP facilities that fall under the Project’s scope.

Minor

012_ 03/18

TTIP - Land use along the 1.5km RoW

The IESC found the report including land acquisition/compensation along the 1.5km section of the TTIP to be confusing because the report addressed

Construction and operations

PS1 and PS5

The report should be restructured to enable a clear presentation of its conclusions with respect to the 1.5km section of interest to the Project/WBG.

Minor



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the entire pipeline right-of-way from Atuabo to Takoradi.

013_ 03/18

Management of Change

A number of potential design changes are expected, including erection of new fencing around the ORF and the drilling of an additional 4 wells.

Construction PS1 Eni Ghana needs to ensure material design changes are captured at the appropriate time by the MoC Procedure. If materiality thresholds are reached, WBG should be notified accordingly in accordance with the MoC Procedure.

NA (included only as a reminder)



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7. PERFORMANCE STANDARD 2: LABOR AND WORKING CONDITIONS

7.1 Introduction

There are no outstanding ESAP items, applicable to Eni Ghana, that refer to labour and working conditions.

While the IESC March 2018 monitoring visit was taking place, a major labour dispute was in progress with the ORF site experiencing 9 days of worker strikes and being shut down for 5 days. Thus, the planned focus and itinerary for the monitoring visit was amended to allow for time to be spent on an investigation of the labour dispute. The results of this investigation are presented below in Section 7.3.

7.2 Management of labour and working conditions

As reported in September 2017 IESC monitoring report, Eni Ghana prepared, approved, and issued revised versions of the two key plans that relate in different ways to labour and working conditions:

Workers Management Plan24; and the

Recruitment, Employment and Training Plan25

Both revised plans became effective in September 2017 and apply not only to Eni Ghana, but also to contractors and, also, they are a guide to ‘main suppliers’ (referred to in the Recruitment, Employment and Training Plan) which are hiring workers. These plans were updated to take account of two factors:

Recommendations made by the IESC, in the first monitoring visit report (February 2017) to improve compliance of the plans with PS2 requirements; and

To reflect the changing project situation with construction now being underway and with first oil occurring in May 2017 and first gas planned for June 2018.

After reviewing both these plans, the IESC confirmed that these Plans, in the main, had taken the IESC recommendations into account. However, some additional detailed observations were made in the September 2017 IESC monitoring report.

In November 2017, the revised Local Hiring Procedure was approved (SUST-PRO-008). This includes references to PS 2 requirements including implementation of a Workers’ Grievance Mechanism. A review of this revised Procedure was not undertaken due to time constraints.

7.3 Local labour dispute

7.3.1 Context

Labour issues have occurred periodically since the ‘early’ demobilization of workers (August 2016) by DeSimone Ltd and the issue of their re-hire by other contractors such as Technip under potentially differing terms and conditions (see IESC’s first Monitoring Report, 5 May 2017). There were some labour disputes in 2017 (July and then in Q4 2017 just before Christmas); with the pre-Christmas disputes continuing into January 2018. Subsequently, a more serious dispute occurred in early March 2018 which resulted in 9 days of worker strikes and 5 days when the ORF was shut down. A trend is discernible consisting of both an increase in the number of disputes,

24 Document reference: SUST-PLAN-003 rev01 (September 2017). 25 Document reference: SUST-PLAN-001 rev01 (September 2017.



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and their relative significance, in terms of number of workers involved/affected and the adverse effects on the construction schedule and attendant costs.

To understand the recent labour disputes, it is useful to consider some key background details. First, the ORF construction period is coming to an end. Demobilization of workers has occurred, already, and will accelerate toward the end of Q2 2018. Actions to manage demobilization have been underway in Q1 2018. For example, a meeting with community leaders, followed immediately by a second meeting with workers’ representatives, both focusing on demobilization of workers employed by Consar (a sub-contractor to Technip - one of the two main contractors at the ORF site), were held on 21 February 2018.

Technip and SRI/EMAS are the two main contractors at the ORF site. Technip has two sub-contractors: Orsam and Consar. In turn Orsam has 15 sub-contractors; while Consar has none. All apply the Eni Ghana Workers Grievance Mechanism (or an equivalent). All contracted workers are paid monthly by direct payment into bank accounts. However, there is no single practice for overtime payments; for example, Consar pays weekly in arrears, and in cash, to its workers on a Friday, but this does not apply to all contractors. Each contractor and sub-contractor issues a contract to its workers, allowing for variation in terms and conditions except for those that are mandated by law and/or Eni Ghana HR requirements.

Third, a sizable proportion of the Orsam (including sub-contractors) and Consar workforces are unionized (with Collective Bargaining Agreements in place or under negotiation) and many are permanent employees who are, temporarily, working at the Sanzule site. The remaining workers are recruited from the DAoI villages plus, more recently, some neighbouring villages close to the DAoI ‘boundary’, and these workers are not unionized. An opportunity to join a union was available to these local workers, but they decided not to join. Many of these workers had no experience of formal employment practices and procedures in an industrialized setting; in particular, working under contractual terms and conditions some of which involved application of specific procedures such as the Workers’ Grievance Mechanism.

Recently, recruitment of local workers has increased to enable the ORF construction schedule to be met. The IESC investigated with the main contractors whether the amount of employee overtime was increasing. The contractors all gave a similar answer - there was no trend of increased overtime hours. It appears that the main means of increasing hours worked is to recruit more workers and not to increase the number of hours worked by each employee. This finding is relevant as it precludes one potential underlying cause of worker dissatisfaction - working longer hours.

In addition, the IESC asked contractors whether there had been, recently, an increase in labour disputes in the oil and gas sector in the Western Region. The responses indicated that such an increase had not occurred. Again, this removes any ‘copy-cat’ rationale for the recent increase in labour disputes at the ORF site. In fact, some contractor representatives considered that experience/knowledge of labour disputes in the longer-established mining sector was a more likely ‘inspiration’ for initiating disputes as some unionized workers had work experience in the mining sector.

7.3.2 Causes of the Disputes: Q4 2017 and Q1 2018

The issues behind the pre-and post-Christmas disputes were varied, but all related to ways of increasing income from employment, except for a desire for enhanced training opportunities, by means of payment of:

A Christmas bonus (considered by many workers to be paid by one Contractor and not another);

Salary increments;



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A risk allowance;

Travel allowances;

Notice in lieu amounts (if a worker is demobilized early and is not told in advance then a payment is made by way of compensation, for example, 2 weeks of basic salary); and

Demobilization bonuses (with a focus on the amount/s to be paid).

Overall, it appears that the issue of uncertainty regarding the payment of demobilization bonuses was a key factor behind the March 2018 dispute.

The desire for more training for unskilled and/or semi-skilled workers so that these workers can achieve placement in jobs with higher skills and remuneration was a common theme in several of the disputes relating to specific groups of workers.

7.3.3 Dispute management

There were two key elements to dispute management:

Increase in security provision; and

Mobilization of a Grievance Committee.

Both local police and army personnel were deployed (including the Western Region police SWAT team which includes members who are specialists on crowd dispersal) to assist the existing private sector security providers. Police/military presence was reported, by the Security Manager to be low key, which helped to calm the situation; for example, the military personnel kept weapons in their vehicles and engaged with the workers verbally.

To try to manage the dispute and bring it to a swift conclusion to be followed by an immediate return to work, the issues /concerns/demands of the workers were treated as grievances and Eni Ghana mobilized a Grievance Committee (consisting of two key Eni Ghana personnel, one of whom acted as chairperson (Accra-based, and the Sanzule-based Community Labour Relations Officer); plus village chiefs (Sanzule and Bakanta) or chiefs’ representatives (Eikwe and Krisan) and the District Labour Officer to consider and try to resolve then ‘close-out’ the issues raised by differing groups of workers. Adherence to the Workers’ Grievance Mechanism occurred despite a perception among some workers, particularly those from the DAoI communities, that the Workers’ Grievance Mechanism is slow in reaching a conclusion and, therefore, they do not invoke it prior to taking collective actions that involve a withdrawal of labour.

In total there were 9 grievances considered by the Committee. The Committee met constantly over several days hearing submissions from all key participants. Following its deliberations all grievances were resolved and, by the final day of the IESC’s monitoring visit (Friday 16 March), some of grievance close-out forms had been signed, by all parties, and work had resumed at the ORF site. The IESC notes the speedy and peaceful resolution of the March 2018 dispute.

7.3.4 Post - Dispute actions

Technip has initiated regular discussions (one had already occurred prior to the IESC’s meeting with Technip representatives on 15 March 2018) with Orsam and Consar to identify emerging worker issues/concerns and actions that might be taken to prevent the issues/concerns escalating to disputes. Also, it is intended to organize a ‘durbar’26 of all ORF workers in relation to demobilization. A report on the outcome of the ‘durbar’ has been requested by the IESC, but it is

26 A ‘durbar’ is a ceremony held on special occasions, for example, when rulers are installed or in relation to a range of social

occasions requiring rulers/ruled to come together to celebrate an event or date.



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not yet available.27 Finally, a range of meetings with other key stakeholders will follow the ‘durbar’ meeting. These will include meetings, focusing on, but not necessarily limited to demobilization and security issues, with Traditional Authorities and the District Council, all to be held by the end of March 201828.

A revised security risk assessment will be undertaken, by the Security Manager, following the March labour dispute and the Project Security Management Plan will be amended /updated accordingly. This update will not only be based upon the results of the revised security risk assessment, but will also include matters relating to deployment of police and military personnel and the rules of engagement to be followed (to be based on a proposed MoU between the Project and the police and the military).

In relation to security, work has started to increase fencing in key locations in the ORF vicinity. Increasing fencing is a potentially sensitive issue and requires careful management. Eni Ghana is committed to maintaining access for local people between places of residence and agricultural areas and, also, other localities where they can access natural resources and social/physical infrastructure and attendant services (see also Section 9.3, Security).

7.3.5 IESC observations

These observations are divided into those that have an immediate and short-term ORF focus and those that are longer-term and broader in scope.

Short-term and ORF focused

It was known that the end of the construction phase and demobilization of workers were approaching. It is a relatively common feature, in such situations, that there is an increase in disputes – usually relating to remuneration/monetary benefits. With hindsight, it appears that the ORF dispute was a typical example of this widespread labour dispute pattern. To try to avoid a repeat of the labour unrest, it is suggested that Eni Ghana:

Mobilizes on-site contractor human resources staff to implement ‘early warning’ actions, for example, daily checking of community-level and worker grievances and/or random, informal meetings with individual workers or small groups of workers;

Requires key contractor human resources staff to share intelligence daily with each other and with a designated Eni Ghana senior manager;

Devises and implements preventive actions should intelligence indicate that a concern, shared by several workers, might lead on to a dispute/withdrawal of labour; and

Undertakes an audit, focusing solely on the timescale/s taken to close-out grievances submitted via the Workers’ Grievance Mechanism, and based upon the results, amends the procedure to ensure that resolution and close-out is reached as quickly as possible while maintaining the operational principle underpinning the Workers’ Grievance Mechanism.

Random, informal meetings with individual workers or small groups of workers might alert contractors to the concerns of their workers and, also, identify any trends in concerns (such as a growing momentum in terms of number of workers sharing the same concern/s and the strength of their feelings) that might lead on to a dispute.

The staff deployed to manage the dispute are all members of the SLC department (except for the Security Manager who is a member of the Personnel department). The IESC is not aware of any other Personnel department staff members that were deployed to the ORF site during the

27 Post visit note. The IESC has been informed that the Durbar is on hold. To date demobilisation issues have been relayed to workers

via their representatives. 28 Subsequent to the March 2018 monitoring visit, the IESC was informed that all these meetings were held with the last one

occurring on 7 April 2018 in Eikwe village.



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dispute. While it is true that the SLC personnel complement includes a Sanzule-based Community Labour Relations Officer, it is understood that the role of this Officer is not one of personnel management; rather it relates to the wider issues of how local workers are recruited and managing community-related concerns about this process and equity issues regarding ‘fair’ shares of jobs between communities. Even if this post does include an element of ‘personnel management’, the Officer is not a senior member of the SLC department.

Given the importance of avoiding a recurrence of the March 2018 dispute, it is recommended that Eni Ghana deploys, as soon as possible, a senior member of Eni Ghana’s Sustainability & Local Content (SLC) department to be based at the ORF site until the end of the construction phase. Regular communication on labour issues should be held between this SLC staff member and a senior Ghanaian staff member of the Human Resources/Personnel department. This person would be available to advise, quickly, Contractor human resource personnel and, as necessary, lead dispute management actions early in the process.

Finally, as a means of reducing the risk of any last-minute workforce and community unrest, it is recommended that Eni Ghana implements a labour audit to confirm that all contractors have met their contractual obligations to their workers and, in particular, have paid their workers in full at the end of the construction period.

Longer-term and broader focus

Several of the demands /concerns of workers were based on incorrect information, misunderstandings or lack of knowledge of labour law. Clearly, different terms and conditions and/or different wording of similar terms and conditions, as interpreted by individual workers were the source of several concerns/complaints that resulted in disputes.

Thus, it is suggested that there is a need to ensure that all workers, especially, those with no previous experiences of formal working arrangements, are clearly informed of the terms and conditions of their employment and their rights and responsibilities. This is best done during recruitment process, during induction and periodically during the period of employment. The Recruitment, Employment and Training Plan requires that workers are informed of the terms and conditions of their employment and their rights and responsibilities during induction, but there is no provision for repeat ‘refresher’ awareness sessions. Also, the issue of worker terms and conditions of employment and worker rights and responsibilities is not mentioned in the ‘companion’ Worker Management Plan. It is recommended that Eni Ghana amends the Worker Management Plan to contain a requirement for repeat refresher training on worker terms and conditions of employment and worker rights and responsibilities (as provided to new recruits during induction) and then implement the refresher training according to the schedule set out in the revised Worker Management Plan.

Given that the construction phase will be completed, substantially, by end of June 2017, attention must be paid to the reality of impending demobilization and the need to remind workers, in this context, of their rights and responsibilities and the importance of the Workers Grievance Mechanism and the need for time to allow this procedure to be implemented in a way that will lead to acceptable outcomes (contractor personnel were almost unanimous that local workers wanted instant decisions and did not accept the need for time to respond to their demands).

It is also suggested that effort is expended to ensure clarity in contract terms and conditions. Contracts will remain different (and this will continue to be a source of disputes as one set of workers finds out about the terms and conditions of other workers), but removing ambiguity and uncertainly about rights and responsibilities will be beneficial (for example, one contract seen by the IESC states that a demobilization bonus will be paid, but does not state the amount or how it



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will be calculated). This leaves uncertainty in the minds of a worker especially if he/she hears other workers talking about a specific amount that they are expecting.

7.4 Workers’ accommodation

Two topics are considered below: Accommodation Policy and the SINOPEC Workers Accommodation Camp.

7.4.1 Accommodation Policy

The September 2017 Workers’ Management Plan contains clear commitments to apply the IFC/EBRD (2009) Guidelines on Worker Accommodation when siting, designing, constructing and managing workers’ accommodation. In the first IESC monitoring visit report (February 2017), it was recommended that Eni Ghana prepare an accommodation policy that provides a set of high-level commitments in terms of provision of accommodation to workers. This policy has not yet been prepared (as also mentioned in the previous IESC monitoring report (September 2017 visit).

7.4.2 SINOPEC Workers Accommodation Camp.

During the September 2017 IESC monitoring visit, the SINOPEC camp29 was inspected. It was found that the female workers who are employed to provide services such as cleaning had no access to a female toilet/washroom and had to wait until the ‘resident’ workers (all male) had left for the construction site, before being able to us a toilet/washroom. A return inspection of the SINOPEC camp was not possible during the March 2018 monitoring visit. Instead, the IESC was advised that a female toilet/washroom facility had been provided and photos were supplied as ‘evidence’. The IESC notes the prompt remedial action taken by Eni Ghana to address this issue.

7.5 Occupational health and safety

Performance Standard 2 also includes consideration of workers health and safety, including the objective to promote safe and healthy working conditions and the health of workers. The health and safety performance of Eni Ghana certain contractors on the Project was assessed during meetings with main Contractors, review of documentation and during the walk over inspection of the FPSO and GNGC TRMS. The IESC’s observations in this respect are provided in:

Section 6.2, HSE and Sustainability Responsibilities and Resources;

Section 6.3.3, Saiwest, HSE Minimum Requirements; HSE Management System; HSE training, safe working procedures/Permit to Work; and site walkover observations.

Section 6.3.4, Yinson (FPSO Contractor);

Section 6.3.5, Technip (Orsam and Consar);

Section 7.4, Workers’ accommodation.

The IESC reiterates its findings reported in previous monitoring visit reports that Eni Ghana and its main Contractors have robust and compatible HSE and SLC Management Systems in place. Eni Ghana works closely with its Contractors to ensure a consistent approach and standard of H&S management across of the Project. There is a strong Health and Safety culture which is reflected in positive Project H&S metrics.

29 The camp is referred to as the ‘SINOPEC camp’ by the Project and Contractors as it was built and used by SINOPEC during the

construction of the nearby GNGC facility. SINOPEC is not a Project Contractor.



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Labour management

Early warning of potential labour disputes

Construction PS2 Eni Ghana to:

Mobilize on-site contractor human resources staff to implement ‘early warning’ actions, for example, daily checking of community-level and worker grievances and/or random, informal meetings with individual workers or small groups of workers;

Require key contractor human resources staff to share intelligence daily with each other and with a designated Eni Ghana senior manager;

Devise and implement preventive actions should intelligence indicate that a concern, shared by several workers, might lead to a dispute/withdrawal of labour; and

Undertake an audit, focusing solely on the timescale/s taken to close-out grievances submitted via the Workers’ Grievance Mechanism, and based upon the results, amends the procedure to ensure that resolution and close-out is reached as quickly as possible while maintaining the operational principle underpinning the Workers’ Grievance Mechanism.

High

015_ 03/18

Labour management

There is no senior Eni Ghana manager present at the ORF site with expertise and experience of personnel/human resources management in the run-up to the

Construction PS2 Eni Ghana deploys, as soon as possible, a senior member of Eni Ghana’s Sustainability & Local Content (SLC) department to be based at the ORF site until the end of the construction phase.

High



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completion of a construction phase in a West African context.

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Labour management

Reducing risk of future labour and community unrest

Construction PS2 Implementation of a labour audit to confirm that all contractors have met their contractual obligations to their workers and, in particular, have paid their workers in full at the end of the construction period.

Moderate

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Labour management

Ambiguity and uncertainly about workers’ rights and responsibilities in different contractors’ contracts


PS2 Ensure clarity in contract terms and conditions. Contracts will remain different, but ambiguities and uncertainly about rights and responsibilities, in contracts, should be minimized to the extent possible

Moderate

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Labour management

Reinforcement of induction training on worker terms and conditions of employment and worker rights and responsibilities


PS2 Amend the Worker Management Plan to contain a requirement for repeat refresher training on worker terms and conditions of employment and worker rights and responsibilities (as provided to new recruits during induction) and then implement the refresher training according to the schedule set out in the revised Worker Management Plan

Moderate



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8. PERFORMANCE STANDARD 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION

This section considers the management and monitoring of key environmental impacts associated with the Project and the Project’s commitments to the prevention of pollution and resource efficiency. Key aspects relevant to the Project include:

air quality;

noise;

surface water;

waste management;

greenhouse gas emissions

These are discussed in turn below. Other environmental aspects have been considered in previous monitoring visits/reports and are not revisited in this report.

8.1 Air quality

The ESAP includes a requirement for Eni Ghana to ‘update and refine the air emission dispersion modeling during production facility final design to inform the identification and development of a package of air emission reduction measures’. The due date was 31 October 2017 and therefore subject to IESC consideration during the monitoring visit.

The IESC was informed that the updated modelling work was submitted to the WBG in accordance with the delivery deadline. The IESC has subsequently reviewed the air dispersion modelling report prepared by ERM30

The revised modelling uses input data based on the final ORF design and considers the impacts of any deterioration in air quality against established air quality standards for human and vegetative receptors. In both cases, the study concludes that emission from the ORF will have a small effect on current baseline concentrations, with maximum contribution of NO2 and PM10 amounting to a small percentage of the applicable limits.

The IESC notes that background SO2 concentrations were found to exceed air quality limits, however this was believed to be a result of smoke from cooking and wood burning. The contribution from the ORF will be negligible because the gas has a negligible sulphur content.

8.2 Noise

8.2.1 Noise modelling

Item 6 of the ESAP has the requirement that ‘Eni Ghana will update and refine the ……… noise propagation modeling during production facility final design to inform the identification and development of a package of air emission reduction measures’ by 31 October 2017.

The noise propagation modelling study was performed by ERM31. The study includes consideration of national and WBG noise standards. The study identifies most significant operational noises source to be located 1200 and 850 m from Sanzule and Anwolakrom respectively. Additional baseline data was collected at these residential locations, reporting high baseline noise levels attributable to breaking waves and occasional music and vehicles movements. Ecological sensitivities are also identified and considered in the study.

30 Ref. rep ms hse eni ghana - Air Dispersion Modelling Study for ORF Operation. Final ORF Project Design. 31 Ref. rep ms hse 020 eni Ghana r00 – Noise Modelling Study for ORF Operation Phase. Final ORF Project Design, dated 26 October

2017



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The study concludes that the contribution from the Project is well below the applicable limits for humans during day time and night time, and that the 3dB incremental criteria will not be breached with noise from the Project being unlikely to be perceived during operations. Impacts to avifauna are also considered to be insignificant.

The study concludes that overall residual significance of noise from the ORF is considered to be medium. This categorisation is heavily influenced by the duration of the noise emissions rather than the actual perceived noise i.e. a duration >10 years which in effect automatically results in a ‘medium’ significance.

The modelling methodology used in the assessment has been reviewed by an IESC acoustician who concluded that the modelling approach and noise propagation results where realistic, thereby confirming that impacts from noise during steady state operations will be negligible.

8.2.2 Noise monitoring

Noise levels are measured on a monthly basis and reported in the Quarterly and the Annual Monitoring Reports submitted to the WBG. Whereas the noise modelling study concludes negligible impact to nearby communities, the IESC notes that noise monitoring, as reported in the QMRs and 2017 AMR, does not include measurement of noise levels at the boundary of nearest communities. Monitoring and presentation of results at the nearest communities, supported with context/explanation of the results observed (e.g. high background noise), would help verify the modelling results.

8.3 Surface and groundwater

8.3.1 Hydrotesting

Construction of the 26” gas export sealine is underway with completion expected in May 2018 (see Section 3.1). Following its installation, the integrity of the pipeline will be pressure tested using a pressurised water (hydrotest) procedure.

Eni Ghana is in the process of obtaining a Hydrotest Permit for the gas export sealine and has submitted a Hydrotest Water Disposal Management Plan (HWDMP) as part of the permit submission process32.

IESC found the HWDMP to align with the mitigation measures specified in the ESIA. Importantly the plan commits to the use of chemical additives considered to pose little or no risk to the environment, and to discharge used hydrotest water at the Pipeline End Terminal (PLET) 63km offshore in deep water33.

The 2017 AMR provides the results from monitoring of liquid effluents from the Maersk Voyager and the FPSO which show exceedances of WBG and Ghanaian effluents standards for BOD5, COD, total nitrogen and total phosphorous at the Maersk Voyager, and exceedances of total coliform bacteria at the FPSO. The AMR states that the Company and Contractors are working hard to put measures in place to rectify the exceedances. Although this was not discussed during the monitoring visit, it is recommended that Eni Ghana provides the WBG and IESC an update on this issue, further describing remedial actions and current effluent quality. Additional monitoring to confirm the effectiveness of remedial actions is anticipated at the end of April 2018. This issue will be further revisited in forthcoming QMR reviews/September 2018 monitoring visit.

32 Ref. Plan ms hse 012 ei ghana – Hydrotest Disposal Management Plan 33 Chemicals to be used are either categorised as a PLONOR substance in the OSPAR List of Substances Used and Discharged Offshore

or determining to pose little or no risk based on completion of Harmonised Offshore Chemical Notification Format (HOCNF) forms.



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8.4 Waste management

8.4.1 Technip Waste management

During the September 2017 monitoring visit the IESC made a number of observations concerning Technip’s waste management practices, including the finding that:

The Waste Management Plan (WMP) prepared by Technip lacked the level of detail and specificity expected for an operationalised WMP and the procedure for disposal of hazardous wastes is unclear.

The IESC recommended that the WMP be revised to include characterisation and quantification of the types and volume of non-hazardous and hazardous wastes to be generated at the ORF. It was recommended that third-party waste contractors should be identified for the different hazardous waste types and the ability of the waste contractor to collect, safely transport and treat/dispose of the wastes should be assessed by Technip. Periodic audit of the waste contractor(s) by Technip and/or Eni Ghana was also recommended. It was recommended that the scope of the audit should include visual inspection of disposal facilities and the workers’ camp located close to Atuabo.

The IESC met with Technip HSE representatives to discuss waste management during the monitoring visit and was informed of a number of corrective actions triggered by the IESC’s earlier findings:

Eni Ghana quickly undertook an audit of Technip’s waste management practices (28 -29th September 2017);

Technip’s Waste Management Plan has been updated (24 January 2018) to take on board the IESC’s comments;

Technip has replaced its waste contractor34.

Technip has also audited its new waste provider35.

8.4.2 Waste-related community grievance

During the September 2017 site visit, the IESC was made aware of a letter from the Sanzule Secretariat that claimed Project waste from the ORF had been inappropriately disposed. The IESC is comfortable that the claim was investigated in accordance with the Grievance Procedure and that claimant was unable to provide any evidence of the inappropriate disposal of Project waste.

8.5 Greenhouse gas emissions (GHG)

Line 8 of the ESAP requires Eni Ghana to maintain a quantification programme for GHG emissions. The delivery milestone in an amended ESAP required ‘Quantification and minimization program for GHG emissions submitted to WBG, by 31st October 2017’, thus becoming a ‘due item’ since the preceding monitoring visit. The GHG emissions quantification programme was therefore a subject for discussion during the IESC third monitoring visit.

Eni Ghana’s approach to GHG Emission accounting is presented in Plan ms hse 021 Eni Ghana – GHG Accounting and Reduction Program, 25 October 2017. Eni Ghana uses a bespoke software, SHERPA36, for the collection of GHG emission data (and other emissions) under the direction of the Environmental Coordinator. The software was demonstrated to the IESC and found to be comprehensive in its collection of data. Data for each source of GHG emission is provided to Eni

34 Technip acknowledged that its original waste contractor was initially commissioned to manage chemical toilets and that the

contractor did not have the capability to manage the expanded scope. 35 OCTP-ORF Project – Sanzule Ocular Visit Pictorial Report, 12th February, 2018 36 SHERPA refers to Safety Health Environment Radiological Protection Data Acquisition developed at an eni corporate level to assist

with corporate reporting of GHG emissions.



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Ghana headquarters in Accra on a daily basis using daily production reports where it is then processed to calculate monthly totals. The data is presented as emissions from venting and flaring, stationary combustion, mobile combustion, indirect emissions and fugitive emissions37 as well as total CO2 equivalent. Conversion to CO2 equivalent for each gaseous emission is automated within the software.

The collection of GHG emissions data commenced for the FPSO on the 20th May 2017, coinciding with first oil. Thus, the first reporting of GHG emissions in the 2017 Annual Monitoring Report will be for a partial year. From 2018 onwards reporting will be for the calendar year, when detailed reduction measures, actions and targets will be developed based on the first full year of data. Additional sources of GHG emissions will be included in the GHG accounting as new plant at the ORF is commissioned. Figure 6 provides the content to be reported in Annual GHG Accounting Reports. Figure 7 is an example of the output available from SHERPA showing the contribution from different sources to the monthly GHG emission totals; flaring, combustion, fugitive. It should be noted that the Project is currently flaring associated gas as per limits required by Ghana EPA and reporting the quantity of gas flared on a monthly basis. Flaring will be eliminated and all associated gas reinjected as per requirements set by Ghana EPA following the commissioning of gas reinjection wells in mid-2018.

37 Fugitive emissions are estimated as a percentage of oil and gas production



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Figure 6: Content of GHG Emissions Accounting to be included in Annual Monitoring Reports



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Figure 7. Example output from SHERPA showing monthly GHG emissions

It is the IESC’s opinion that the elements of GHG quantification programme, including data collection processing and interpretation via SHERPA is in line with good practice. Measures to reduce GHG emissions will be the subject of future monitoring.

8.5.1 GHG emission associated with the TTIP

The IESC is aware that certain upgrade work at the GNGC TRMS was only possible following venting and purging of the GNGC Atuabo to Takoradi pipeline. Saiwest confirmed the pipeline was vented at the GNGC facility near Atuabo, however the works at the GNGC TRMS were purposefully planned to coincide with scheduled maintenance/evacuation of the pipeline by GNGC. Thus, Eni Ghana’s activities did not result in additional venting/release of hydrocarbons.



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Noise monitoring

Noise monitoring, as reported in the QMRs and 2017 AMR, does not include measurement of noise levels at the boundary of nearest communities.

Construction PS3 Monitoring and presentation of results at the nearest communities, supported with context/explanation of the results observed (e.g. high background noise), would help verify the modelling results and confirm applicable noise limits at the nearest residential receptors are being met.

Minor

020_ 03/18

Waste water discharge

The 2017 AMR reports:

exceedances of WBG and Ghanaian effluents standards for BOD5, COD, total nitrogen and total phosphorous at the Maersk Voyager; and

exceedances of total coliform bacteria at the FPSO.

Construction PS3 Eni Ghana should provide the WBG and IESC an update on this issue, further describing remedial actions and the results of any additional monitoring performed to confirm the effectiveness of remedial actions is anticipated at the end of April 2018. Minor



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9. PERFORMANCE STANDARD 4: COMMUNITY HEALTH, SAFETY, AND SECURITY

9.1 Introduction

Below the IESC’s analysis focuses on the following two topics:

Community health and safety; and

Security.

9.2 Community Health and Safety

A revised Community Health Management Plan has been prepared and approved (September 2017). It refers to the Project Security Management Plan which at the time of writing is being revised (see Section 9.3 below).

As mentioned above in Section 6.2, a new post, ‘Community Health Management’ has been created in the SLC department. Currently, the Social Projects Assistant Manager has responsibility for this Community Health Management post and for overseeing the implementation of the Plan. There are three ongoing separate initiatives which have a direct or indirect community health focus (all are at various stages in terms of design, planning and approval): implementation of the Community Health Management Plan, the Community Investment Strategy and the health component of the LRP’s Transitional Support38. Focused co-ordination is needed to ensure coherence is attained in implementation of these initiatives by:

Ensuring that implementation of an initiative does not compromise the ability of other initiatives to meet agreed objectives;

Maximizing the leveraging of synergies; and

Minimizing overlap and duplication.

The creation of the new post, ‘Community Health Management’ is a clear and positive sign that Eni Ghana is aware of the risks and, also, understands that community health improvement and promotion is an important feature in its long-term relations with DAoI (and wider) communities. A decision is needed, as a priority, to identify and then appoint a suitably qualified individual to occupy this post.

During the September 2017 IESC monitoring visit, two PS4-related issues were identified in relation to the SINOPEC workers’ accommodation camp, as follows:

Location: the camp is located close to small rural communities. No signs or notices about personnel/community H&S issues such as Sexually Transmitted Infection (STIs), including HIV/AIDS, were seen in the camp; and

Solid Wastes: not segregated yet. Uncovered mixed waste bins located within camp area close to the central waste storage area. The SINOPEC waste contractor is used and the disposal location was not known (at least by the Orsam HSE representative at the camp).

As these situations were considered, by the IESC, to be inherently hazardous and to increase the exposure of local community members and camp residents to adverse health and safety consequences, management actions were recommended to reduce the risk levels to both local communities and camp residents. Although the IESC was unable to revisit the SINOPEC camp during the recent monitoring visit, photographic evidence of signage at the camp was provided which is considered sufficient to close the first of these items.

38 This initiative is subject of a Notification of Change (dated 7 March 2018)



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Offshore the main community health and safety issue relates to the risks to fishermen posed by the offshore facilities and movement of support/other vessels. The presence of offshore Project-related vessels and activities, and fishermen in close proximity, poses a threat to offshore assets and operations (especially where fishermen appear to choose to disregard the exclusion zones). This health and safety issue is considered, in more detail, under ‘Security’ (Section 9.3 below).

9.3 Security

As presented above (Section 6.4), the Project SMP (effective 01 January 2018) is to be updated following the recent (March 2018) labour dispute. During a meeting between the IESC and the Security Manager, the Security Manager indicated that the revision to the Project Security Management Plan would be based on the (then) current security risk profile as determined by an updated post-labour dispute Security Risk Assessment. A key parallel activity described by Eni Ghana would be to reach agreement with government security entities (police and the army) on a Memorandum of Understanding (MoU), with Eni Ghana, covering the deployment of the police and/or army in support of Eni Ghana in relation to onshore facilities, especially at the ORF site. The MoU should present clear instructions on the rules of engagement to be followed in the event government security forces are deployed (these should be aligned with Eni Ghana’s existing ‘human rights and security’ commitments as set out in the current version of the Plan). An account of progress with respect to agreeing the additional MoU with the Ghana Navy is presented below.

It is recommended that Eni Ghana’s security function takes into account the advice and guidance presented in IFC’s Good Practice Handbook entitled ‘Use of Security Forces: Assessing and Managing Risks and Impacts: Guidance for the Private Sector in Emerging Markets’ (2017) with the aim of ensuring that the revised Plan is fully aligned with Lender requirements. Also, in drafting the revised Project SMP Eni Ghana should provide a clear presentation and explanation of the security-related powers of Eni Ghana and the Ghana Navy with respect to the various kinds of safeguarding zones and the protocols/procedures to be in place to manage interactions with all kinds of vessels that might be expected to enter the safeguarding zones (according to the current Project Security Management Plan, the Navy personnel would be unarmed). Finally, the revised Project Security Management Plan needs to be aligned with other Eni Ghana plans that impinge on security-related issues (such as the Fisheries Management Plan and the Marine Traffic Management Plan).

Other actions that Eni Ghana has already initiated, or intends to implement, include:

Erection of more security fencing at the ORF site as a consequence of the recent labour unrest; and

Appointment of a single security company for the ORF site (with an on-site single Security Officer reporting directly to the Security Manager’s deputy).

The erection of more fencing, while understandable, needs careful scrutiny. There is a commitment to ensure access for local people between their dwellings and land and other natural resources that play a part in maintaining their livelihood status. A prospective decision on erection of barriers that will restrict access, and potentially affect livelihood status adversely, needs to be checked to determine impacts on the ease of access and, appropriate avoidance or mitigation measures put in place to ensure that access remains at a level that is acceptable to those local people likely to be most affected by any potential restriction on access. Should the fencing materially change the access described in the ESIA/management plans, the Management of Change process may need to be invoked (see Section 6.12).

The appointment of a single security company will make management of security provision easier, especially in the event of further security incidents. Currently, there are two security



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providers: DFI security services and Real Life security services. A number of these guards were recruited locally. It is suggested that Eni Ghana assesses the implications of the consolidation of security provision and determines whether arrangements can be put in place to ensure that most, if not all, locally-recruited security guards (from the DAoI) retain their jobs. Should retrenchment be required then this must be managed in line with the provisions of the Workers’ Management Plan (SUST-PLAN-0030).

In the 2017 Annual Monitoring Report there is an account of an offshore incident in Q4 involving a fishing canoe. The fishermen came close to vessels inside the 500-m exclusion zone and started to shout at the crew members. After the canoe was ‘retrieved’ by a ‘security boat’, it is reported that the fishermen claimed that a net had been damaged by one of the vessels. No injuries or damage to the canoe or other vessels were sustained.

During the IESC monitoring visit, the IESC’s environmental specialist visited the FPSO for 1 day. During the visit, it was clear that, despite the existence of a 500-m exclusion zone around the FPSO and the presence of a guard vessel, incursions by fishermen were occurring on a daily basis with fishermen present within the 500-m exclusion zone for the entirety of the IESC’s time aboard the FPSO. (Appendix 5 Photo Log: 8 and 11 showing fishing boats moored to the FPSO anchor chains and use of open flame to cook).

It was noted, also, that the guard vessel was present, but stationed outside the 500-m exclusion zone (it requires permission from the FPSO Offshore Installation manager (OIM) before it can enter the zone). In this instance there did not appear to be any concerted effort to enforce the exclusion zone. This incursion ‘example’, observed by the IESC, is understood to be relatively typical. Discussions on the FPSO and, later, onshore with the Security Manager indicated that such excursions are a common, persistent and severe problem. There seems to be a de facto acceptance of the incursions, at the FPSO, except when specific high-risk activities are underway, in which case greater efforts are made to at least move fishing vessels from the immediate vicinity of such activities. For example, if an activity is taking place on the FPSO port side, fishermen would be moved away from the ongoing activity, but most likely remain in the 500m exclusion zone on the starboard side of the FPSO. There are significant risks to both fishermen and Project assets associated with the continual incursions and Eni Ghana’s inability to fully enforce the exclusion zone.

Apart from the FPSO exclusion zone, there are exclusion zones, to be in force for varying time periods and locations, around the drillship and pipe-laying vessel (based on a 500m radius). In addition, the gas export sealine will have an exclusion zone of 500 m either side of the pipeline route during its construction. The IESC has no direct experience of the situation regarding the frequency and type of incursions that have occurred/are occurring with respect to these zones. The AMRs include an account of ‘ship collisions’ (to date, these types of incidents only involve fishermen) and, also, present information on such incidents under ‘Assessment and Management of Environmental and Social Risks and Impacts’. Individual incursions that do not lead to a recordable incident are not reported. Anecdotal evidence suggests the number of fishing vessels has decreased compared with earlier months, however formal data collection would be beneficial to identify repeat incursions by vessels/record incursion trends and thereby assess the effectiveness of Eni Ghana’s efforts to deter incursions.

Eni Ghana has initiated several measures (both offshore and onshore) to try to prevent incursions into the exclusion zones:

Presence of a guard vessel with at least one Fishery Liaison Officer on board;

Conducting negotiations with the Ministry of Defence (Ghana Navy) with the aim of signing a MoU on collaborative efforts to enforce adherence to the exclusion zones. At the time of the



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IESC’s March 2018 monitoring visit, Eni Ghana was waiting for a response from the Ministry of Defence to enable negotiations to progress;

Deployment of 5 Fishery Liaison Officers, one in each of the 5 communities located in the DAoI with the aim of sensitizing fishermen of the risks of entering the exclusion zones;

Continuing negotiations with representatives of those dependent on fishery-based livelihoods in 6 coastal Districts (these are all the Districts, of the Western Region, which have a coastline) with the aim of signing of an MoU to manage offshore risks to the mutual benefit of the fishermen and the Project (the IESC understands that the MoU has been signed by certain of the parties, but not yet all of them). Eni Ghana believes that most of the fishermen that are active in the area where offshore Project vessels operate originate from these Districts, although some are known to come from more distant locations. In addition to the MoU discussions, there are separate consultations with fisheries representatives from these districts to explain the need for the exclusion zones to be observed (for example, a meeting on 27 October 2017 involving fisheries representatives from Ahanta-West, Sekondi Takoradi Metropolitan Assembly and Ellembelle Districts following the incursion incident described above); and

Community-based meetings, focusing on a range of fisheries-related issues, which include information, advice and guidance on the importance of respecting the exclusion zones as a way of reducing risks to fishermen.

Efforts leading up the potential signing of the 2 MoUs have been continuing for many months and progress has been slow (see above). In the interim, incursions have continued and will most likely continue unless a new strategy is devised and implemented. Also, there remains a distinct possibility that these MoU-related efforts will not be successful.

Given the lack of progress with stopping the incursions offshore, primarily by community-level sensitization, further effort is required to manage this issue. Options that might be considered include:

A high-level meeting is held with GMA, Ghana Navy and the PC to agree measures that can be taken offshore to enforce respect for the exclusion zones (for example, deployment of smaller vessels such as Zodiacs to enable easier communication with fishermen in order to persuade fishermen not to enter zones and/or remove vessels from zones);

Eni Ghana tries to identify the identity and home port of the fishermen that are causing most of the incursions and mobilize community-level sensitization meetings in these localities to a) explain the risks of incursions and b) inform fishermen that, should they try to enter the zones, the consequence for doing so in terms of lost fishing effort will make the attempt to breach the zone a self-inflicted economic/livelihood penalty. The negative effects arising from incursion could be counterbalanced by presenting some incentives that would benefit the fishermen while at the same time reducing willingness to risk making incursions into the exclusion zones; and

Eni Ghana should consider liaison with other O&G operators in the region to understand whether they have experienced similar issues, and if so, what measures have been used to enforce exclusions zones.

The issue of the Project’s relation to fisheries is entering an important phase with three key current issues, as follows (See Section 10.3):

The scope of entitlements in the Fisheries Management Plan (payments for loss of income, ‘disturbance’, are not envisaged for fishmongers or offshore canoe fishermen);



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Fisheries Management Plan implementation especially in terms of the calculation and then payment of the ‘disturbance’ payment for short-term (estimated as 16 days) closure of a section of the beach to beach seine fishing; and

The number of outstanding fisheries-related grievances (See section 6.8).

As described in Section 6.2 the representatives of DAoI villagers who were interviewed and are dependent upon fisheries for their livelihoods, expressed some concerns regarding the Project’s adverse impact on their interests and the way they will be compensated.



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021_ 03/18

Community health and safety

The creation of the new post, ‘Community Health Management’ is a positive sign that Eni Ghana understands the importance of community health improvement and promotion. However, this post is not yet filled.


PS4 A decision is needed to identify and then appoint a qualified individual to occupy this post.

Moderate

022_ 03/18

Community health and safety

Actions to improve health status and health care access may be devised and implemented under three separate initiatives. There is risk of overlap and duplication.

Operations PS 4 Eni Ghana to ensure coherence is attained in implementation of these initiatives by:

Ensuring that implementation of an initiative does not compromise the ability of other initiatives to meet agreed objectives;

Maximizing the leveraging of synergies; and

Minimizing overlap and duplication.

Minor

023_ 03/18

Project Security Management Plan

Following the recent labour unrest and the IESC finding that offshore security provisions are not effective in terms of preventing canoe (fishermen) incursions into the FPSO exclusion zone, the Project SMP requires revision.


PS4 A revised and updated risk assessment is to be undertaken and the Project SMP amended accordingly, and re-issued. This revision needs to take account of all pertinent international and O&G sector guidance on managing security and be aligned with other Eni Ghana plans that impinge on security-related issues (such as the Fisheries Management Plan and the Marine Traffic Management Plan).

High



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A MoU to be reached, as soon as possible on the use of State actors (police and military) in the protection of assets and personnel. MoU to be based, to extent practical, international and O&G sector guidance; such as IFC’s (2017) Good Practice Handbook entitled ‘Use of Security Forces: Assessing and Managing Risks and Impacts: Guidance for the Private Sector in Emerging Markets’.

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Project Security Management Plan – fishing vessel incursions

Incursion of fishermen into exclusion zones


PS4 Efforts to enforce exclusion zones must continue/new initiatives must be sought. Eni Ghana should consider liaison with other O&G operators in the region to understand whether they have experienced similar issues, and if so, what measures have been used to enforce exclusions zones. Efforts to be renewed to try to progress reaching agreement on an MoU with the Ghana Navy with regard to mutual and shared responsibilities for preventing incursions and resolving them promptly when they occur.

High

025_ 03/18

Severance The erection of additional fencing at the onshore project site might impede access of local people to land and resources that are a part of their livelihood strategy.


PS 1. PS 4 and PS 5

Eni Ghana checks the potential impacts of the additional fencing on access routes (with reference to ESIA commitments) and, depending on the results, implements design/location changes to avoid impeding access and/or actions that reduce the

Moderate



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adverse impact/s to an acceptable level.

026_ 03/18

Consolidation of security provision at the ORF site

The future appointment of a single company to provide security may mean that some, or indeed all, of the locally-recruited security guards (from the DAoI) lose their jobs - effectively being retrenched for business reasons. This situation may lead to labour unrest.


PS 2 and 4 Eni Ghana to assess the implications of the consolidation of security provision and determine whether arrangements can be put in place to ensure that most, if not all, locally-recruited security guards (from the DAoI) retain their jobs. Should retrenchment be required then this must be managed in line with the provisions of the Workers’ Management Plan (SUST-PLAN-0030).

Minor



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10. PERFORMANCE STANDARD 5: LAND ACQUISITION AND INVOLUNTARY RESETTLEMENT

10.1 Introduction

The Project is currently occupying land and nearshore/offshore marine areas and will continue to do so. Both a Livelihood Restoration Plan (LRP), focusing on land-based livelihoods (the non-monetary compensation element of this Plan is referred to below as the Livelihoods Restoration (LR) Programme), and a Fisheries Management Plan have been prepared. Thus, the Project is managing land and fisheries-related economic displacement in separate, but linked procedures. The LR Programme is supported by 4 SLC staff; whereas the Fisheries Management Plan implementation is supported by 7 staff (includes 5 Fishery Liaison Officers); all 11 staff members are based in Sanzule. Also, there is a Community & Fishery Liaison Supervisor, based in Sanzule, who has a role in managing the relations between the Project and fisheries- dependent community members.

This section presents findings for both land- and fisheries–focused economic displacement separately.

10.2 Land - focused economic displacement

Transitional Support – Food Aid

The time-bound ‘Transitional Support Food Aid’ component (monthly distribution of food) of the LR Programme continues to be the key ‘bridge’ between payment of compensation and the delivery of livelihood benefits to the PAPs from the LR Programme ‘Support Services’ component. Following the completion of the ‘testing’ period, the ‘Transitional Support Food Aid’ started on 22 September 2016 and has continued since; however as of April 2017 the number of households in receipt of food aid reduced to 204 (from 417), being those identified as ‘project-affected households’ (previously all Sanzule households were in receipt of food aid). The contractor tasked with distributing food aid is Safezone Company Ltd. Eni Ghana produces monthly reports on each distribution. At the beginning, food aid distribution was the subject of approximately 20 grievances, but the numbers have declined since then except for September 2017 when the food aid was not distributed due to a delay in renewing the contract with Safezone Company Ltd. The recipients agreed with Eni Ghana’s suggestion (in response to a ‘community-level’ grievance) that an extra month of food aid would be added to the final month of the Transitional Support Food Aid’ component.

Since the time of the first IESC monitoring visit (February 2017), Eni Ghana has been considering the issue of an appropriate date for terminating ‘Transitional Support Food Aid’ distribution. In September 2017, the intention was to terminate it 21 months after the date of mobilization of the contractor (Technoserve) responsible for delivery of the ‘Support Services’, by which time it would be expected that flow of benefits will be sufficient to enable the food aid to be withdrawn. In March 2018, the IESC was informed that Eni Ghana wished to terminate food aid in the period end December 2018 to end February 2019 (with the ‘missing’ September 2017 food aid being delivered the month following the ‘termination’ month).

At a meeting between the IESC and a small group of farmers from Sanzule, participants responded to questions about the food aid component by stating that all received it and they had not experienced any problems and had no complaints about it. All knew that the Transitional Food Support would end, but did not know when this might occur.

This ‘target’ date for initiating the termination the food aid support is based on Technoserve’s estimation that, by the end of 2018, the livelihood status of some of the participating households will be at a level that will allow for the cessation of the food aid component to such households.



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Technoserve has estimated the time periods taken for specific components of the ‘Support Services’ (options) to begin to make a difference to the livelihood status of those who are participating in the different components; for example, the period for those participating in poultry (broiler) production will start to experience livelihood benefits as early as 8 -10 weeks after their entry into the poultry production component. For others the periods will be longer, for example, those who have selected pig rearing, but some households should be benefitting by end 2018 (partly due to Technoserve’s attempts to encourage each household to select a mix of options enabling some benefits to be received early followed by others coming ‘on stream’, to boost the initial benefits, resulting in a relatively smooth trajectory of increasing receipt of benefits until livelihood restoration is achieved, and livelihood enhancement is a reasonable expectation). To try to ensure a sustainable and increasing delivery of benefits, Technoserve has undertaken a risk assessment reviewing specific risks that might adversely affect delivery of benefits and the results have been factored in to the estimates of timescales for achieving a sustainable delivery of benefits from the individual components of the Support Services and from the ‘Support Services’ as an integrated package (where there will be synergies from increasing per capita incomes/wealth via the multiplier effect).

Eni Ghana is aware that terminating the food aid will be an economic ‘shock’ to the affected households and is engaged in planning for its termination via community sensitization and other actions (the community is aware that it will cease, but not when) as part of a food aid termination strategy. Eni Ghana will use an evidence-based approach, using household survey data, to determine the date when food aid will cease so it is possible that food aid will terminate after December 2018; it is unlikely to terminate earlier. Using an evidence-based approach in this context is an important principle, and it is important that Eni Ghana/Technoserve ‘get it right’ by ensuring that the evidence base is robust, credible and justifiable. This will require careful examination of the method to be used to acquire the needed data. In addition, a key factor, is community agreement to the termination strategy and approach, for example, the indicators to be used for households, following a particular mix of livelihood options, which when met will result in termination. Trigger points (in terms of indicator status) should be agreed in advance establishing the timing for putting households on notice that termination of their food aid will occur in, for example, 2 or 3 months after receipt of the ‘termination’ notice.

Health and Educational Support

As mentioned in the September 2017 IESC monitoring report, and subsequently considered at greater depth in the IESC’s Q3 2017 Quarterly Report (December 2017), those eligible for transitional support food aid are eligible for health and educational support, including payment of costs associated with the National Health Insurance Scheme and fees required for school enrolment. Throughout most of 2017, Eni Ghana reported that these two measures had not started as a management decision ‘approving’ them had not been made.

During the March 2018 IESC monitoring visit, the IESC was informed that these two measures had been separated from the LR Programme (that is, no longer focused only on the project-affected households) and that alternative measures with a wider community focus (but still within the DAoI) were planned instead. A ‘Notification of Change’ was under preparation prior to its submission to IFC (subsequent to the IESC monitoring visit, a copy of the ‘Notification’ was provided to the IESC). With respect to the educational measure, a recent change in the law has made support for fees unnecessary. Instead, a ‘Quick Impact Project’ focused on the education sector is planned for implementation under the Community Investment Strategy (Section 6.5). Regarding the health component, work is underway to develop an initiative that would be under the ‘umbrella’ of the Community Health and Safety Management Plan and would link, to the extent feasible, with Plan initiatives and past actions, by the Eni Foundation, to improve health status and access to health services locally. These two ‘replacement’ initiatives have received



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management approval, in principle, to enable work to progress to the point that a decision is required to proceed to implement the projects.

The IESC received the ‘Notification of Change’ shortly before preparation of this March 2018 monitoring report. Within this context and based on the information available to it, the IESC has two key concerns about the changes outlined above. First, the recipient of the changes will no longer only be the project-affected households; the benefits will accrue more widely to a range of community members and it is not clear how the project-affected households will retain an equivalence in terms of the ‘benefits’ they would have received if the original actions were implemented. Secondly, as the ‘new’ initiatives will be funded under two other budget lines (for example, the Community Investment Strategy and Community Health and Safety Management Plan implementation), separate from the ‘Transitional Support’, then there are funds in the Transitional Support that would appear not be used, directly, to assist the project-affected households. This situation may be interpreted, rightly or wrongly, by third parties as a mechanism to reduce the overall costs of providing benefits to both the project-affected households and the wider DAoI communities. There may be a reputational risk here for the Project and the Lenders.

Financial Management Training

In March 2017, the first phase (essentially, a 10-day training course) of the ‘Financial Management Training’ was delivered. The provider was the DEQ Change Foundation (DEQ) which, subsequently, prepared two reports: a report (April 2017) focusing on design and delivery of the training course; and a later ‘Monitoring Report’ (June 2017) focusing more on the characteristics and views of the participants.

One notable outcome, which DEQ links to the training, was the formation of 2 co-operatives in Sanzule and Anwolakrom: one of traders and the other of fishermen, respectively. The implementation of the planned follow-up ‘Financial Management’ refresher training course (5 days) occurred during the period 6 to 10 November 2017. Again, a monitoring report will be prepared by DEQ and issued by July 2018. The performance of the 2 co-operatives, and any other similar initiatives that can be linked to the training, will be assessed.

‘Support Services’ LR Programme

With respect to the ‘Support Services’ LR Programme component, Technoserve was appointed and began work in August 2017 to implement a ‘co-design’ study to determine the development options to be incorporated into the Support Services’ LR Programme. A wide range of options (29 in September 2017) were identified and assessed for their feasibility in terms, primarily, of generating sustainable revenue streams for key target groups of PAPs. In addition, a monitoring and evaluation framework for tracking and assessing the overall outcome of the ‘Support Services’ LR Programme was included in the co-design study work. Knowledge of, and participation in, the co-design study was discussed during the meeting between the IESC and the small group of farmers from Sanzule. All farmers were aware of Technoserve’s co-design work and had selected their preferred options for livelihood restoration (for the women these included pig rearing; sheep rearing; poultry rearing; soap-making; cold room storage for fresh products such as fish; agricultural production; and trading agricultural products). The two men selected aquaculture as they both had prior experience and expertise in this activity.

Originally, as stated in the September 2017 IESC monitoring report, the intention was for implementation of the ‘Support Services’ LR Programme to begin in October 2017 immediately after the submission and approval of the co-design study work. This timescale was not met and there was a delay until 12 February 2018 when a contract was signed appointing Technoserve to implement this Programme over a 3-year period (supported by specialist sub-contractors). Subsequently, events have progressed speedily with a ‘Kick-Off’ meeting held on 21 February



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and Technoserve began mobilization to Sanzule (to be its operational base) on 26 February 2018. At the time of the September 2017 IESC monitoring visit, Eni Ghana informed the IESC that consultation on Technoserve’s mobilization had been initiated with the Paramount Chief and Ellembelle District, but had not yet occurred at community level. This was borne out by comments made at the meeting between the IESC and the small group of farmers from Sanzule. The participants were aware that Technoserve would be starting to implement the livelihood restoration measures soon, but did not know the start date (also, the participants did not know, clearly, the duration of Technoserve’s activities; there was mention of 5 years).

As mentioned above, Technoserve began mobilization of its team to Sanzule toward the end of February 2018. Unfortunately, the designated Technoserve Project Manager resigned and at the time of the March IESC monitoring visit, no replacement had been appointed. The Project Manager plays a key role in both day-to-day management of the work and ensuring that the objectives of the LR Programme ‘Support Services’ are achieved. It is a matter of urgency, as Technoserve and Eni Ghana are aware, that a replacement Project Manager is appointed and deployed as soon as possible to ensure maximum management continuity over the 3-year period.

During the March IESC monitoring visit, Technoserve stated that their main tasks, with intended timings, were as follows:

Deployment of 2 business advisors (by 6 March);

Community ‘durbar’ to signal Technoserve’s re-entry into Sanzule (22 March);

Holding interviews and then appointment of 4 Community Ambassadors (for a start date in first week of April) and an Office Assistant;

Selection and mobilization of locally-based suppliers (contracts issued and signed by end June);

Design and delivery of tailored financial training (building on, but not repeating the more general financial training provided by DEQ) and specialist training to target groups depending on the development options selected (initial training programme to be completed by end July; refresher and hands-on training expected to continue beyond July); and

Installation of ‘start-ups’ (related to selected options) following the distribution of the ‘starter packs’ (from August/September).

Following the installation of the ‘start-ups’, work progresses to ensure that sustainable delivery of benefits to the target groups, which as indicated above depends very much on the mix of options selected with poultry (broiler) production expected to initiate an income stream after 8 weeks. Technoserve estimates that delivery of benefits for all participants in the ‘Support Services’ programme will be experienced over an 8-month period from end September 2018 to May 2019.

The Technoserve schedule is ambitious and it is encouraging to know that it has considered risks which may prevent or delay achieving the objectives of the ‘Support Services’ programme. Despite this careful planning, there are both residual risk and some risks that are entirely outside Technoserve’s control, for example, the ongoing Sanzule chieftaincy dispute. Any delay in achieving the objectives of the ‘Support Services’ programme will result in the need to extend food aid delivery beyond the currently foreseen period when it will be terminated (end December 2018 to end February 2019).

10.3 Fisheries-focused economic displacement

Progress has been made, since the September 2017 IESC monitoring visit, for management / mitigation of fisheries-related economic displacement. First, the Fisheries Management Plan has been supplemented by a Fisheries Management Action Plan. This Action Plan takes the form of an Excel spreadsheet with 25 specific actions to be implemented, responsibilities, start dates,



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monitoring indicators (as applicable) and action status (such as ‘completed’, ‘ongoing’ etc). The version of the Action Plan, seen by the IESC, was presented in the Q4 2017 QMR. Therefore, no specific IESC comments are provided, but it is pleasing to see that this Action Plan exists and is being used (some actions have their status indicated and a few are ‘completed’). The implementation of the Action Plan will be subject to a performance review during the forthcoming IESC monitoring visit planned for Q3 2018.

Secondly, the Terms of Reference (ToR) for the Fisheries Management Coordination Committee (FMCC) have been proposed and approved (OCTP Fisheries Management Coordination Committee Terms of Reference, approved 31/10/2017). The ToR establishes the membership and the functions of the FMCC plus the roles/responsibilities of the chair and individual committee members. Also, the ToR establishes procedural rules such as numbers required for a quorum, voting, use of proxies and frequency of FMCC meetings. According to the ToR, the chairperson is the SLC Manager (not listed as a FMCC member) and there are two Eni Ghana employees who are FMCC members (the Regulatory Affairs and Stakeholder Engagement Co-Ordinator and the Community & Fishery Liaison Supervisor). However, during the IESC’s February 2018 monitoring visit, the IESC was informed that, in fact, the chairperson was the Regulatory Affairs and Stakeholder Engagement Co-Ordinator while the Community & Fishery Liaison Supervisor acted as Secretary. It is suggested that the ToR is updated to reflect these changes and, also, the procedural changes that have been agreed by the FMCC.

One of the responsibilities of the FMCC is:

“Compensation negotiations: Oversee eligibility criteria for compensation and disbursement mechanisms and negotiate compensation packages (‘disturbance allowance’) on behalf of affected beach seine fishers during the 1 week construction of the near shore section of the pipeline. Coordination with the LRP Livelihoods Restoration Steering Committee is expected.”

In its September 2017 monitoring report, the IESC commented upon the potential conflict of interest arising from the presence of two Eni Ghana employees serving on a Committee that will negotiate with Eni Ghana about compensation. This issue was raised during the February 2018 monitoring visit and the IESC was informed that it is necessary to have Eni Ghana employees as FMCC members to help ensure that the FMCC functions effectively (for example, Minute taking, setting agendas, and sending of invitation letters). As it is a Committee established by Eni Ghana, to assist in minimising the impacts on fishery-dependent livelihoods, this approach is understandable as it will help ensure that it performs effectively. Eni Ghana is aware of the sensitivity of its ‘presence’ in terms of the FMCC’s negotiation function and has taken measures to ensure that the Eni Ghana employee members are absent during key activities and decision-making related to negotiations on compensation. The IESC considers that it would be beneficial if the ToR were to be amended to make it clear that there is a mechanism in place to avoid the conflict of interest issue.

Following the approval of the ToR, the inaugural FMCC meeting was held on 10 November 2017. The discussions were mostly procedural in nature. It was agreed that FMCC meetings would occur monthly with a proviso that ‘emergency’ meetings could be held as and when necessary. Most meetings are held in Sanzule, but a meeting has been held in Eikwe. To date, deliberations at FMCC meetings have focused on:

Disclosure of results from the outcomes Fish Landing Survey; serving as the basis for calculation of Fisheries Disturbance Allowance;

Issues around the payment of the disturbance allowance for closing of a section of the beach; and

Outstanding grievances and how to resolve them (with eventual close-out).



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An FMCC meeting was scheduled for the week following the IESC’s February 2018 monitoring visit.

There has been one important Project-related change that affects, primarily, the beach seine fishers (men) who use the beach between Sanzule and Anwolakrom and the fishmongers who buy the fish from the fishermen and then sell the fish locally or in nearby settlements outside the DAoI. Originally, during the design phase for the use of HDD to lay the pipeline at the landfall (involves traversing the beach) it was estimated that there would be restrictions on the use of an area of beach for a period of 7 days. However, due to unforeseen challenges caused by nearshore sand viscosity issues, HDD progress is now much slower and, consequently, the period when the beach area cannot be used for fishing has extended to 16 days. At the time of the IESC February 2018 monitoring visit, the dates in which the beach would be closed was unknown. The SLC department is seeking at least 1 weeks’ notice so that key stakeholders (particularly the fishermen/fishmongers) can be informed in advance of the beach closure. The closure will be soon because pipeline installation is planned to be completed by end May 2018 with first gas by the end of June 201839.

Eni Ghana is trying to devise a ‘formula’ to calculate the disturbance allowance for the loss of beach seine fishing effort using local fish catches as a means of determining ‘typical’ catch sizes and values which can then be used as a basis for determining the value of the allowance to be paid (taking into account the impact and level of loss). To obtain these data, Eni Ghana has hired a Fisheries Consultant and Friends of the Nation (an NGO which provides enumerators), to undertake a study, under ERM’s direction, entitled ‘Participatory Fish Landing Survey in Project Affected Communities’. The data were obtained from each of the 5 DAoI villages over the period October to December 2017.2017. The scale of the study can be seen from the data, as of 18 November 2017, that 373 landings had been recorded and analysed. The fishermen, generally, co-operated although there were some complaints about selection of enumerators and lack of payment for their time spent assisting with the survey.

During the IESC’s February monitoring visit, a meeting was held with a small group of individuals representing fishery interests (beach seine and offshore fishing and, also, fishmongering) from all of the DAoI villages. The meeting focused on the likely impact of the Project on fisheries-dependent households, the work of the FMCC and the understanding of the participants regarding the measures to be taken to mitigate the livelihood impacts. The meeting was attended by about 10 fishermen from the DAoI villages, the Chief Fisherman of Bakanta and, also, member of the FMCC, plus 1 fishmonger. Fishermen included both beach seine fishermen and offshore fishermen.

During the meeting, it was clear that all know that the beach seine fishery will be disrupted for a maximum of 16 days. According to the fishermen, the best fishing season finishes in April so there is a possibility that the beach seine fishery disruption comes at a time when fishermen/fishmongers’ incomes may be close to their highest point in the fishing year. All know that there will be compensation for the beach seine fishery disruption and the principles on how it will be calculated, but there was considerable concern and disquiet about compensation mechanism. Participants were aware, also, that compensation will depend on outcome of negotiations between FMCC and Eni Ghana. All knew about the planned MoU regarding the management of offshore interaction between local fisheries and project-related vessels, but they were not aware if it had been signed by all parties. The fishmonger was concerned about loss of income and compensation and the fact that fishmongers were not in the compensation

39 Between the completion of the monitoring visit and drafting of this final monitoring report, the IESC was informed that Eni Ghana

had decided to implement a “simplified trenching” method for laying the pipeline. The implication for fisheries-related economic displacement is not yet known.



707070707070

framework. The fishmonger did not think she would be able to source fish from other unaffected fishing communities as there would be ‘too many others’ with the same idea.

After the meeting was formally closed, the fishermen started to raise complaints about the effects of, primarily, project-related offshore activities on the fishery; for example, damage to nets. In the IESC’s experience of meetings with local community members, raising issues of concern after a meeting is closed, often, is a sign of underlying discontent especially if the focus and structure of the meeting have not enabled participants to raise all their issues of concern. In addition, the IESC observed, from certain statements made by different participants, that there were signs of stakeholder fatigue. In general, Eni Ghana has undertaken effective consultations as the participants had been both informed and consulted about key actions and issues; however, the fishermen (in particular) are experiencing some problems in their offshore fishing activities and expect beach seine period of disruption to occur soon and, essentially, they are not content about what is happening now and concerned that their interests may not be safeguarded in the future. The situation regarding the 4 fisheries-related grievances (all from 2017), and their non-closure, is probably a factor behind the expressions of dissatisfaction.



717171717171

Table 7: Summary of Compliance Findings, PS5

ID Aspect Issue Description Phase Standard IESC Recommendation Significance

027_ 03/18

Livelihood Restoration Transitional Support Food Aid

Decision/s on terminating food aid needs to be based on credible and shared evidence of livelihood restoration progress.


PS 5 Eni Ghana to ensure that the evidence base to be used to assist determining the date for food aid termination is robust, credible and justifiable. Requires careful examination of the method to be used to acquire the needed data and community agreement to the key features of the method such as indicators of livelihood status to be used and ‘notice periods’ prior to food aid termination.

Moderate

028_ 03/18

Livelihood Restoration Transitional Support

Those eligible for transitional support food aid are eligible for health and educational support; including payment of costs associated with the National Health Insurance Scheme and fees required for school enrolment. It is proposed that these two measures be separated from the LR Programme (that is, no longer focused only on those eligible for Transitional Support) and that alternative measures with a wider community focus (but still within the DAoI) are planned instead The funding for the proposed changes are not clear This proposed change is subject to a ‘Notification of Change’ procedure.


PS5 Eni Ghana to ensure that: Those eligible receive an equivalence in terms of ‘benefits’. Funding sources are clarified so that there can be no perception that funding available to those eligible for transitional support has been reduced.

High

029_ 03/18

Livelihood Restoration (LR) Programme

Technoserve’s Project Manager for delivery of the LR Programme ‘Support Services’ resigned and at the time of

PS5 Eni Ghana to work closely with Technoserve to ensure that a replacement Project Manager is

Moderate



727272727272

ID Aspect Issue Description Phase Standard IESC Recommendation Significance

‘Support Services’

the March IESC monitoring visit, and no replacement had been appointed.

appointed and deployed as soon as possible.

030_ 03/18

Fisheries Management

The current membership of the Fisheries Management Coordinating Committee (FMCC) and certain procedural rules have changed since the FMCC’s Terms of Reference (ToR were drafted by Eni Ghana.


PS5 Eni Ghana updates and re-issues the ToR to reflect membership changes and, also, procedural changes that have been agreed by the FMCC.

Minor



737373737373

11. PERFORMANCE STANDARD 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES

11.1 Introduction

Biodiversity matters, including development/implementation of biodiversity related management plans and ecological monitoring have been addressed in detail in previous Monitoring Visit reports. In this report, this section primarily captures only biodiversity issues in so far as they are addressed in the AMR and/or they relate to deliverables specified in the ESAP with due dates arising since the previous monitoring visit.

11.2 ESAP biodiversity requirement

Item 12 of the ESAP requires ‘Evidences of implementation of the BMP / BAPs included in the Annual Monitoring Report’ in the 2017 AMR.

The AMR includes a section addressing Biodiversity Conservation and Sustainable Management of Living Natural Resources. Within this section reference is made to plankton surveys, avian species surveys and sea turtle surveys. The IESC has not reviewed the survey reports referenced in the AMR in detail, however the IESC is aware of the engagement of GWS to undertake actions identified in biodiversity management/action plans and the IESC is familiar with the work being undertaken by GWS and has reported on their appointment and scope of work in the September Monitoring Visit Report. The findings of a preliminary review are provided below.

The IESC was provided with a number of GWS reports after the monitoring trip, including:

MMSTPPP-1.1: Marine Mammals and Sea Turtle monitoring report, December 2017

TUAP 1. 2: Sea Turtle Monitoring Report, January 2018

BIAP-2.4: Monitor estuary shorebird roosting sites to ensure no direct or indirect disturbance, December 2017

BIAP-2.5: Conduct standard disturbance surveys, December 2017

BIAP-3.4: Monitor Vulture populations and site usage, nesting and use of feedings areas, December 2017

BIAP-5.2: Monitor and report IBA state, pressure and response annually, December 2017

With regards to Sea Turtles, the key objectives outlined in the Sea Turtle Biodiversity Action Plan40 for managing identified impacts include inter alia:

1. Use of trenchless beach crossing;

2. Support to local beach patrols through collaboration with local NGOs; and

3. Communication with the community, with contribution to existing community-based turtle conservation programmes and support in the establishment of a biodiversity committee between relevant development projects in the district.

The IESC notes that a simplified trenching option is now being considered (see Section 3.2.1, Material Design Changes) which may affect the Sea Turtle BAP. Furthermore, whereas the reports provide useful monitoring information, they do not address objectives 2 and 3 above.

Further discussion is required between the IESC, Eni Ghana and its consultants (GWS) to better understand what actions have been taken/are planned in respect of objectives 2 and 3. The

40 Plan ms hse 019 eni ghana r01 – Biodiversity Management Plan. Sea Turtles Biodiversity Action Plan, Appendix B, 31st August

2017.



747474747474

implications of the simplified trenching option also need to be understood by the IESC. It is recommended that implementation of the BMP and associated BAPs, and in particular Eni Ghana’s conservation actions, is a key focus during further IESC monitoring effort.

11.3 Site drainage

During the September 2017 monitoring visit the IESC expressed a concern relating to the ORF’s surface water drainage, specifically that all site surface water is discharged directly to the swamp area via three discharge points posing the risk of sedimentation of the swamp with negative impacts to the swamp ecology. The IESC recommended construction of sediment traps to minimise discharge of sediment and thereby protect the swamp natural habitat.

During the March 2018 monitoring visit the IESC was informed that Eni Ghana has commissioned Technip to undertake design of the sediment traps. The IESC has been provided with documentary evidence of Eni Ghana’s efforts in this respect41.

11.4 Top soil management

The IESC was unable to revisit the ORF site to inspect top soil stockpiles/management. However, the same good practices for top soil management were observed at the GNGC TRMS site.

41 Letter from Eni Ghana to Technip dated 13 January and Company Instruction (CI-010 Rev 01) requesting that Technip submit a

Variation Order for the construction of the sediment traps.



757575757575

12. PERFORMANCE STANDARD 8: CULTURAL HERITAGE

In the IESC September 2017 monitoring report, the IESC noted that the Cultural Heritage Management Plan (CHMP) was not contained in the list of SLC management plans that a contractor is obliged to take into account (if applicable to its activities) when preparing its ‘Sustainability & Local Content Program’ for submission to Eni Ghana for approval. This was considered to be an omission. The IESC was unable to check the current situation during its March 2018 monitoring visit, but will do so in the next monitoring visit planned for Q3 2018.



767676767676



031_ 03/18

Cultural Heritage

The Cultural Heritage Management Plan (CHMP) is not contained in the list of SLC management plans that a contractor is obliged to take into account (if applicable to its activities) when preparing its ‘Sustainability & Local Content Program’ for submission to Eni Ghana for approval.


PS1 and PS8

The CHMP to be added to the list of SLC plans which are referenced in Appendix Y as being the source of all requirements to be incorporated by contractors into their own SLC Program/suite of plans to be submitted to Eni Ghana for approval.

Minor



APPENDIX 1 ENVIRONMENTAL AND SOCIAL ACTION PLAN - UPDATED



Updated ESAP - 01 February 2018 to replace the version updated 16 June 2017 - revised timeframes highlighted yellow. Text highlighted green indicates action due within the reporting period

Task Indicator of Completion Timeframe 1 Eni Ghana with support from Vitol will develop a construction/ development phase

Environmental, Social, Health Management Plan (ESHMP) and the relevant management plans and programs in advance of development drilling and construction, followed by a production/operations ESHMP which will be developed before first oil, with gas-related elements integrated as needed before first gas. The ESHMP will be updated as required, such as in the event of any significant changes to the project and its environmental and social risks and impacts occur, following a Management of Change process. The ESHMP will include social management plans and procedures to meet the objectives of the Performance Standards, and those plans and procedures will be incorporated into an integrated Environmental and Social (E&S) Management System for the OCTP project.

Plans and procedures submitted to WBG: a) Development drilling and construction phase: ESHMP, Procurement Plan, Grievance Mechanism, Waste Management Plan, Security Management (Offshore) Strategy by November 15, 2015 b) Recruitment, Employment and Training Plan, Local Content Development Plan, Workers Development Plan, Marine Traffic Management Strategy, Commitment Register by end of November 2015 c) Development drilling and construction phase: all management plans (others than the plans specified in the action items below) approved by end of December 2016 d) Phase-1 commissioning and production operations: by end of August 2017 or one month prior to commissioning / production operations whichever comes first e) Phase-2 commissioning and production operations: by end of July 2018 or one month prior to commissioning / production operations whichever comes first.

a) 11/15/2015 – Complete b) 11/30/2015 - Complete c) 12/31/2016 Complete d) 08/31/2017 or one month prior to commissioning / production operations whichever comes first - Complete e) 07/31/2018 or one month prior to commissioning / production operations whichever comes first

2 Eni Ghana will require that contractors adopt measures and bridging documents to ensure that their management systems are compatible with HSE Policy, guidelines and procedures and the project ESHMP.

Evidences (i.e., approved bridging documents) collected and submitted to WBG.

12/31/2015 – Complete and ongoing

3 Eni Ghana will implement well integrity and control strategies and develop specific Well Control Emergency Response Plans for each well drilled. All drilling programs will be approved by eni headquarters (that will act as independent, expert third party in charge of verification/review).

a) WCEMP applicable to the first three wells drilled approved by eni headquarters and submitted to WBG by September 2015, and evidences of implementation of the third party verification/review of the drilling programs by October 15, 2015 b) Auditable evidences of implementation provided to WBG in the Annual Monitoring Report.

a) 10/15/2015 - Complete b) 12/31/2017

4 Eni Ghana will develop the specific E&S monitoring plans. A number of pre-construction surveys will be implemented, including: (i) preconstruction fish catch surveys at Sanzule and in the project area of influence, with specific focus on beach seine fishing activities; (ii) phyto- and zooplankton surveys (near the same time as the catch surveys and focusing on fishing grounds); (iii) ambient air quality and noise monitoring in the area of influence of the ORF; (iv) preconstruction survey of sensitive

a) Terms of reference of the time sensitive surveys (birds and sea turtles) submitted to WBG by end of October 2015 b) Pre-construction surveys and monitoring plans submitted to WBG.

a) 10/31/2015 - Complete b) 06/30/2016 - Complete



Task Indicator of Completion Timeframe avian species that may be present, particularly during the boreal winter.

5 Eni Ghana will report on their best efforts to engage other developers, local institutions and government, and other stakeholders in designing coherent management strategies to mitigate cumulative impacts.

a) Cumulative impact mitigation strategy submitted to WBG b) Evidences of implementation provided to WBG as part of the Annual Monitoring Report


6 Eni Ghana will update and refine the air emission dispersion and noise propagation modeling during production facility final design to inform the identification and development of a package of air emission reduction measures.

Modeling updated and submitted to WBG during production facility final design and by anticipated completion date.

10/31/2017 - Complete

7 Eni Ghana will develop and enforce a policy and relevant procedures to ensure that operations of drillship, support vessels and helicopters minimize disturbance to marine mammals and turtles.

Policy and procedures submitted to WBG. 12/31/2015 - Complete

8 Eni Ghana will maintain a quantification program for GHG emissions, according to an internationally recognized emissions estimation methodology, and will establish annual review programs to identify areas of improvement and GHG emission reduction. Eni Ghana has committed to implement a Zero-Permanent Flaring policy, and will implement measures for minimization of venting and flaring (consistent with the Global Gas Flaring and Venting Reduction Voluntary Standard) and minimization of fugitive emissions.

a) Quantification and minimization program for GHG emissions submitted to WBG b) First annual report by anticipated completion date.

a) 10/31/2017 - Complete b) 12/31/2017

9 Eni Ghana will include an environmental lead as part of the oil spill response team and will develop a clear mechanism of escalation of response effort based on coastal and biodiversity sensitivity. Mutual aid agreements with other operators in Ghana will be established.

Evidences of implementation (i.e., approved revised OSCP) submitted to WBG.

12/31/2015 - Complete

10 Eni Ghana with the support of Vitol will develop and implement a Livelihood Restoration Plan (LRP) for affected people in the community of Sanzule. Once all mitigation measures have been substantially completed and displaced persons are deemed to have been provided adequate opportunity and assistance to sustainably restore their livelihoods, eni Ghana will undertake a completion audit comparing outcomes against objectives of the plan and current living conditions against living conditions prior to the start of the project. eni Ghana will develop a Land Acquisition and Compensation Framework for any potential additional land acquisitions that may be required for the project or future expansions.

a) LRP workshop held b) Draft final LRP submitted to WBG c) Final LRP submitted to WBG d) Update report by Eni Ghana/Vitol on actions taken (e.g., financial training, food aid, education and health support, stakeholder engagement, feasibility studies by the 4 NGOs). The report will also summarize implementation issues faced in 2016-2017 and lessons learned. e) Evidences of implementation included in the periodic E&S progress reports and Annual Monitoring Report

a) 10/31/2015 - Complete b) 11/30/2015 - Complete c) 12/31/2015 or six weeks prior to construction early works whichever comes first - Complete d) 02/28/2018 e) Based on LRP f) 03/31/2019 g) Finalization report: at the completion of the LRP



Task Indicator of Completion Timeframe f) Interim Implementation Audit carried out by an external competent resettlement professional and report submitted to WBG g) Finalization report by implementing organization submitted to WBG and Completion Implementation audit carried out by an external competent resettlement professional and report submitted to WBG

Completion audit: One year after the completion of the implementation of the LRP

11 Eni Ghana with the support of Vitol will develop a Fisheries Management Plan (FMP) to ensure fishermen are compensated appropriately and assistance for improving or at least restoring their living conditions is provided. The FMP will be monitored throughout its implementation to its completion. A participatory monitoring program will be developed with the involvement of local fishermen. The plan will also include a compensation framework in line with PS 5 in case fishers are adversely impacted by an oil spill.

a) FMP strategy submitted to WBG. b) FMP submitted to WBG. c) Evidences of implementation of the FMP and participatory monitoring program included in the Annual Monitoring Report.

a) 12/31/2016 Complete b) 5/31/2017 or 2 months prior to construction sea pipeline whichever comes first - Complete c) 12/31/2017

12 Eni Ghana with the support of Vitol will develop a Biodiversity Management Plan (BMP and relevant Biodiversity Action Plans) and will implement it, in collaboration with recognized species specialists. Seasonal constraints, associated with peak turtle nesting season between October and February and with dwelling season of the IBA triggering species, will be incorporated in the construction and operation management plans.

a) BMP submitted to WBG, including identification of opportunities to enhance conservation of priority bird species (including specific focus on the hood vulture) and/or habitat in the project area b) BAPs for sea turtles and for birds submitted to WBG c) Evidences of implementation of the BMP / BAPs included in the Annual Monitoring Report.

a) 07/31/2016 - Complete b) 11/30/2016 - Complete c) 12/31/2017

13 Eni Ghana will ensure that support helicopters will routinely avoid flying over the sensitive areas of Amansuri wetland and that, if avoidance is not feasible due to weather conditions, a minimum altitude will be specified, according to international good practice, when flying over this area to minimize disturbance to wildlife.

Evidences of avoidance (i.e., helicopter flight plans and relevant language on flights associated with emergency/oil spill response drills in the revised BMP - see Action Item 12) provided to WBG.

05/31/2016 - Complete

14 Eni Ghana and Vitol Ghana, as partner of the OCTP project, will develop and implement a community investment strategy for the area of influence of the project by identifying areas of potential social investment based on community assets and needs. The community investment strategy will be developed in consultation with local and regional stakeholders.

a) Community investment strategy submitted to WBG b) Final Community Investment Strategy submitted to WBG c) Updates and evidences of implementation of the strategy included in the Monthly E&S Reports and Annual Monitoring Report.

a) 12/31/2015 - Complete b) 10/31/2017 - Complete c) 12/31/2018

15 Eni Ghana and Vitol Ghana, as partner of the OCTP project, will hire an independent E&S consultant (IESC) to monitor and report on implementation of this E&S Action Plan and compliance with Performance Standards and E&S commitments. The monitoring visits will be carried out biannually (every six months) during development drilling and annually during production operations. The reports of the IESC will be

a) IESC's Terms of Reference submitted and approved by the WBG, and IESC hired b) First monitoring visit and report submitted.




Task Indicator of Completion Timeframe published.

16 Vitol Ghana will assign an E&S assurance manager to the OCTP project to oversee environmental, health, safety and social aspects, ensuring compliance with Performance Standards and project E&S commitments.

E&S assurance manager appointed.

10/31/2015 - Complete

17 Vitol Ghana will develop and adopt a Human Resource Policy. Human Resource Policy submitted to WBG.

12/31/2015 - Complete

18 Vitol Ghana will update its security policy to be aligned with the Voluntary Principles on Security and Human Rights.

Policy submitted to WBG. 12/31/2015 - Complete



APPENDIX 2 PROJECT DOCUMENTATION PROVIDED FOR REVIEW



Document Title Organisation

ESAP update – 01 Feb 2018 WBG/Vitol

2018-03-12 - World Bank Audit Project status meeting (presentation) Eni Ghana

Action plan for 2017 Surveillance Audit and ISO 14001 gap analysis Eni Ghana

Report on Land Acquisition and compensation for 1.5km Right of Way (RoW), April 2018

Eni Ghana

Pro ms hse 010 eni ghana – HSE Audit. Audit program for 2018 Eni Ghana

RINA SURVEILLANCE AUDIT REPORT-ISO 14001-2004 Rina

RINA SURVEILLANCE AUDIT REPORT-OHSAS 18001-2007 Rina

OCTP Integrated Project Security Management Plan Onshore/Offshore (SUST-PLAN-006), January 2018

Eni Ghana

plan ms hse 012 eni Ghana r02 - Hydrotest Water Disposal MP Eni Ghana

pln ms hse 021 eni Ghana- GHG Quantification and Reduction Program Eni Ghana

rep ms hse 013 eni Ghana – Air Dispersion Modelling Study for ORF Operation Phase (2)

Eni Ghana

rep ms hse 020 eni Ghana OCTP_Noise Modelling Study for ORF Operation Phase Final Orf Project Design

Eni Ghana

rep ms hse 021 eni ghana- Emergency Response Exercise 3rd Level Emergency Drill

Eni Ghana

2017 Annual Report on Grievance Redress Mechanism (SUST-REP-GMR-2), December 2017

Eni Ghana

OCTP Phase 3 Development Livelihood Restoration Plan Implementation Update Report (February 2018)

Eni Ghana

Community Investment Strategy (SUST-STRA-001-CIS-r02), 8 December 2017

Eni Ghana

SUST-PLAN-001 01 - Recruitment Employment and Training Plan Final. Sept 2017

Eni Ghana

OCTP Fisheries Management Coordinating Committee Terms of Reference Eni Ghana

Local Hiring Procedure (SUST-PRO-008) Eni Ghana

Q4 2017 Quarterly Monitoring Report Eni Ghana/ VUGL

2017 Annual Monitoring Report Eni Ghana/ VUGL

Notification of Change to Livelihood Restoration Plan – Transitional Support on Health and Education

Eni Ghana

Fisheries Management Action Plan Eni Ghana

Report on Land Acquisition and Compensation for 1.5 km Right-of-Way (TTIP) (February 2018)

Eni Ghana

Consar Ltd– example of a typical worker’s contract Consar Ltd

Sample of Grievance ‘Close-Out’ forms Eni Ghana

Grievance Register/Grievance Tracker – selected pages Eni Ghana

Livelihood Restoration Programme Co-Design Report (Technoserve) Eni Ghana

ESAP Monitoring and Evaluation Audit: Rigworld Maersk (SUST–REP-MR-07) Eni Ghana



Document Title Organisation

ESAP Monitoring and Evaluation Audit (SUST-REP-MR-02) Eni Ghana

TTIP Phase 1 – HSE Management of Vendors and Subcontractors, Oct 2017 Saiwest

HSE Training Program, Oct 2017 Saiwest

OCTP - Execution Plan for additional gas evacuation system Projects, 30 March 2017

Eni Ghana

TAKORADI-TEMA INTERCONNECTION PROJECT (TTIP) PHASE I - PROJECT SECURITY PLAN, February 2018 (front cover and ToC only)

Saiwest

TTIP EPA Permit issued 22 September 2017 EPA

TTIP Phase 1 Project HSE Plan, Jan 2018 Saiwest

Saiwest employment agreement Saiwest

Eni Ghana Readiness for assessment for transition to the Standard UNI EN ISO14001: 2015. Nov 2017

Rina Services

TTIP Risk Assessment for double block and bleed plug system Saiwest

Weekly Site HSE Inspection -GNGC 21-3-2018 Saiwest

Rigid pipeline Environmental Management Plan, 24 March 2017 Sri EMAS

Action Audit Plan, LTE Sanzule, March 2018 Sri EMAS

Waste Audit Report, January 2018 Sri EMAS

Monthly Environmental Monitoring Report, December 2017 Envaserv Research Consult

Sri EMAS audit schedule 2018 Sri EMAS

Drug and alcohol standard, Nov 2017 Technip

Waste Management Plan, 24 January 2107 Technip

Waste Management Plan JAK, 23 February 2017 Yinson

HSE Bridging Document -Yinson – operation and maintenance of FPSO, May 2017

Yinson

Ship Oil Pollution Emergency Plan – John Agyekum Kufuor Yinson

Training and drill debriefing (examples) – Pollution Drill, Fire on Deck 14 December 2017

Yinson

Joint HSE Inspection Exercise Yinson and Eni Ghana

PTW Weekly audit report, 8 March 2018 Yinson



APPENDIX 3 MONITORING VISIT ITINERARY



OCTP Site Visit Itinerary – IESC Monitoring Visit, 12th 16th March 2018

Participants: Ramboll, IESC

Vitol

Date Time Chris Halliwell Ron Bisset

Sunday 11th March

Fly to Accra

Monday 12th March

Location: Accra Eni Office

0900‐1000

Opening meeting (IESC present objectives of trip) Discuss itinerary for the week/logistics for FPSO

1000‐1100

Project status update (General) incl TTIP and LTE

1100‐1200

1200‐1300

Lunch

1300‐1400

Resourcing update – HSE and SLC teams

1400‐1500

Eni Ghana’s management of TTIP (HSE plus SLC)

1500‐1600

Cumulative impacts/influx management

1600‐1700

Livelihood restoration

1700‐1800

Community investment

Close– overnight in Accra (Movenpick Hotel)

Tuesday 13th March

0900‐1000

Fly to Takoradi Fly to Takoradi and transfer to logistics base

1000‐1100

Helicopter transfer to FPSO Meetings at Takoradi base by videoconference and skype links with:

Group of Farmers

Group of individuals dependent

on fisheries (fishermen,

fishmonger and member of

Fisheries Management

Coordinating Committee)

Briefing meeting on labour dispute

with Eni Ghana/Vitol personnel

0930 Meetings with FPSO HSE representatives/others to discuss: ‐ HSE induction ‐ Waste ‐ Haz materials ‐ Air emissions/monitoring ‐ Effluent

treatment/discharge ‐ Meet MMO/trained FPSO

rep ‐ Security/Fishermen ‐ PTW and HSE observations Walkover inspection Brief close out

1500 Helicopter return to Takoradi

Overnight in Planters Hotel



Wednesday 14th March

0900‐1800

TTIP – (Takoradi RMS) _ GNGC site Meeting with contractor’s (Saiwest) HSE and SLC ‐ Follow on issues identified during WBG visit in 2017. ‐ application of Project E&S MPs (general) ‐ site walkover ‐ land ownership/acquisition (with Amin and Maame) ‐ brief close out

Overnight in (Planters)

Thursday 15th March

1000 ‐1200

Management of HSE at the ORF

Technip/Osram and

Consar

Meetings to discuss labour unrest with:

Orsam

Technip

1200 ‐1300

Management of HSE at the ORF

Sri EMAS

Meeting to discuss labour unrest with:

Sri EMAS

Consar

Lunch

1400 – 15.30

Security management (meeting with Security Manager) to discuss recent ‐ labour unrest ‐ fishermen and exclusion zones

Return flight to Accra

Friday 16th March

Eni Ghana offices, Accra 0900‐1000

Operational readiness planning Local Recruitment Procedure (status of procedure and its implementation)

1000‐1100

GHG Emissions/reporting Stakeholder Engagement

1100‐1200

Management of Change Fisheries Management Action Plan Meeting with Technoserve on Livelihood Restoration Programme delivery

1200‐1300

Lunch

1300‐1400

Wrap up any outstanding environmental issues from Sept 2017 report

Community Grievance data: analysis of grievances for the Project in general; and contractors’ understanding/implementation of the grievance procedure

1400‐1500

IESC Prep time

1500‐1630

Close out meeting

Depart on evening flight to London



APPENDIX 4 STATUS OF ISSUES IDENTIFIED IN PRECEEDING MONITORING VISITS



ID Aspect Issue Description Standard/

Phase IESC Recommendations Signifi-

cance Open/Closed

(IESC Opinion)

020 2/17

Security Management Plan

There is no Project Security Management Plan, consistent with ESHIA commitments, in place.

PS 4 Construction and Operation

Prepare a Security Management Plan which is aligned with good international industry practice (including the Voluntary Principles on Security and Human Rights and other international requirements and guidance).

Moderate CLOSED A final (signed) Security Management Plan has been provided (effective 1 January 2018). See Section 9.3 which provides an update on the security situation.

021 2/17

Contractor Management - security

The extent of the involvement of the Security Manager in the procurement of contractors is limited.

PS 4 Construction and Operation

Ensure that the Security Management Plan will contain minimum requirements to be met by contractors and that these requirements will be factored into procurement processes (and subsequent contractor management) with regards to security provision.

Moderate OPEN The Project Security Management Plan has been revised and approved and it includes the ‘minimum requirements’; however, it will be updated and revised; therefore, this remains an OPEN action. Appendix Q needs to be revised to reflect the final version of this Plan and then the revised Appendix Q needs to be incorporated into all documentation provided to potential contractors.

023 2/17

(Landless) Labourers

The LRP does not include (landless) labourers (recognized as potentially

PS 5

Consider undertaking additional work to revisit the most recent

Moderate OPEN



ID Aspect Issue Description Standard/ Phase

IESC Recommendations Signifi-cance

Open/Closed (IESC Opinion)

vulnerable in the Phase 2 ESHIA Report) in its categories of those people eligible for compensation/livelihood support activities (IESC recognizes that most, if not all, of them are receiving Transitional Support Food Aid, but this will cease soon for those people that are not included in the categories of eligible people).


census data to identify any (landless) labourers that should be classed as PAPs. Appropriate measures should be taken in line with PS 5 should this ‘review’ identify (landless) labourers that are classed as PAPs.

The IESC has been informed that an LR Programme Project-affected households survey has been conducted. However, it is unclear whether the survey results have triggered the need to identify and implement any additional measures and the action remains OPEN on this basis. Of note, Eni Ghana considers this action to be CLOSED. The IESC will confirm this conclusion during the next monitoring visit.

027 2/17

Influx Management

The potential effectiveness of the Influx Management Plan is threatened by the lack of progress in establishing a collaborative multi-stakeholder forum for managing influx (this is not the fault of Eni Ghana; rather the results of the practical institutional and political challenges of setting up such a forum from a range of disparate private sector and local government parties).

N/A Construction and Operations

Maintain its support to WB efforts to establish a collaborative multi-stakeholder forum while at the same time reviewing the outcomes of the local-level measures that it has been applying and considering whether there are any changes that might be needed to enhance their effectiveness (for example, local labour recruitment).

Moderate OPEN Progress has been made; however, the IESC believes this action remains OPEN until the Forum is fully established and functioning.

001 9/17

Audit records (Technip)

Paperwork relating to the closure of audit findings was overdue i.e. didn’t

Construction

Greater effort is required to ensure paperwork is up to date.

Minor CLOSED






reflect that audit findings had been closed.

PS1 Although unable to visit the ORF site, the IESC met with Technip. Based on the limited time available, documentary evidence appeared to be up to date and this issue can be considered closed.

002 9/17

Grievances (Technip)

During discussion with the Technip CLO there appeared to be confusion over the definition of a grievance and under what circumstances a grievance/complaint should be reported to Technip management and then passed on to the SLC team within Eni Ghana.

Construction PS1

Technip should clarify its management of community-related grievances within a formal procedure that ensures Eni Ghana is informed of all grievances. Some further training may need to be provided to Technip by Eni Ghana.

Minor

CLOSED

Eni Ghana has audited Technip (and other contractors) regarding a number of topics, including application of the community-level Grievance mechanism. Remedial actions were then implemented (see Section 6.8.2).

003 9/17

Helmet stickers Helmet stickers indicating date and type of training received by workers provides a useful and immediate visual check. However, the date of training/trainer’s signature had rubbed off the stickers in several cases.

Construction PS1

Technip should consider the use of indelible ink to improve the effectiveness of this system.

Minor

CLOSED

Technip has informed the IESC that indelible ink is being used. (Ref Technip HSES actions tracking register).

004 9/17

SRI/EMAS environmental monitoring

SRI EMAS is undertaking environmental monitoring that will supplement the monitoring programme conducted by ESL. SRI EMAS appear

Construction PS1

Eni Ghana should ensure methodologies and sampling approach used by SRI EMAS is compatible with monitoring undertaken by other entities. SRI

Minor

PENDING






to be reporting against Ghana standards.

EMAS should also report against the Project standards, including WBG standards.

IESC was unable to revisit this issue in the time available.

005 9/17

House-keeping at the LTE

A number of oil stains were noted around the generator and mobile lamps. The generator did not have secondary containment.

Construction PS1

Greater care is required when refuelling equipment at the LTE. The generator should be equipped with secondary containment.

Minor PENDING

IESC was informed that housekeeping has improved following inspections by Eni Ghana, however IESC was unable to revisit the LTE site to verify the improvement due to the labour dispute. The LTE site will be visited during the next monitoring visit.

006 9/17

Contractor management

Appendix Y refers contractors to an IFC website, by a link, to find ‘SLC’ management plans to be used to assist the drafting of equivalent contractor plans.

Construction and operations PS1

The ‘IFC’ link needs to be checked to ensure operability at all times and the SLC management plans need to be uploaded as and when approved and ‘signed off’; or an alternative method, such as a dedicated webpage on an Eni Ghana website, must be found to ensure that potential contractors can access the current ‘SLC’ management plans easily and reliably.

Moderate

CLOSED

The IESC understands that contractors do not rely on the ‘IFC’ link to access the plans.

007 9/17

Workers’ Grievance Mechanism

Not all Contractors are implementing the Workers’ Grievance Mechanism.


Check status of implementation of the Workers’ Grievance Mechanism by all current contractors and

Moderate OPEN (in progress)






PS1 initiate measures to rectify a situation where implementation is not aligned with contractual requirements.

Also, check implementation of the Workers’ Grievance Mechanism by all future contractors by the end of month 2 after initiation of on-site activities and rectify the situation as necessary.

Eni Ghana ‘ESAP Monitoring and

Evaluation’ audits of contractors (Q4 2017) found that contractors

are aware of the Workers’ Grievance

Mechanisms and they are mostly in place, but disclosure to workers

and their application is not yet satisfactory. Eni

Ghana recommendations to improve performance

are being implemented. This item remains OPEN

until confirmation is obtained that the

implementation of the actions is completed (Eni Ghana plans to

undertake a review of contractor

implementation of the actions in July 2018).

008 9/17

Human Resources Policy

Eni Ghana does not have a Human Resources Policy that is tailored to its operations in Ghana.

Construction and Operations PS2

Prepare, approve, disseminate and implement an Eni Ghana – specific Human Resources Policy. This policy to include explicit statements that child and forced labour will not be employed and trafficked persons will not be hired.

Minor OPEN






A policy is still required. It is recognized that the Recruitment, Employment and Training Plan and Worker Management Plan both cover the issues, mentioned in the column opposite, to varying extents.

009 9/17

Forced labour The Recruitment, Employment and Training Plan does not contain a clear commitment that forced labour will not be employed.


The Recruitment, Employment and Training Plan to be amended to contain a clear commitment that forced labour will not be employed.

Minor OPEN

No revised Recruitment, Employment and Training Plan incorporation the required commitment has been prepared.

010 9/17

Accommodation Provision

No Eni Ghana accommodation policy exists.


Prepare, approve, disseminate and implement an Accommodation Policy or incorporate it into a (combined) Human Resources and Workers’ Accommodation Policy.

Minor

OPEN

No Accommodation Policy of Human Resources Policy has been prepared.

A stand-alone policy or one combined with a Human Resources Policy is still required

(see 008 9/17 above)

011 9/17

SINOPEC camp The SINOPEC camp has no female toilet facilities.

Construction PS2

Female toilet and washroom facilities to be installed as soon as possible.

Moderate CLOSED






(photographic evidence provided of female

toilet)

012 9/17

Noise monitoring

ESL reports non-compliance with WBG noise limits. The IESC believes the levels may in fact be compliant and recommends careful interpretation of WBG noise limits when reporting compliance.

Construction PS3

ESL monitoring to take account of background noise levels and apply the WBG <3dB incremental noise limit where applicable.

Minor

OPEN

Based on review of the Eni Ghana Q4, 2017 Quarterly Monitoring Report, background noise was not being considered during the interpretation of noise monitoring data.

013 9/17

Water quality monitoring

The map indicating sampling locations in the ESL monthly monitoring reports has a poor spatial resolution making it difficult to pinpoint sampling locations (and therefore interpret the results).

Construction PS3

An improved map would be helpful.

Minor

OPEN

IESC did not review ESL monitoring reports during the site visit.

014 9/17

Waste Management – ORF (Technip)

The Waste Management Plan prepared by Technip lacks the level of detail and specificity expected for an operationalised WMP. In particular, the procedure for disposal of hazardous wastes is unclear.


The Plan should be revised to include characterisation and quantification of the types and volume of non-hazardous and hazardous wastes to be generated at the ORF. Third-party waste contractors should be identified for the different hazardous waste types and the ability of the waste contractor to collect, safely transport and treat/dispose of the wastes should be assessed by Technip. Periodic audit of the waste contractor(s) by Technip and/or Eni

Moderate

CLOSED

Eni Ghana followed its grievance procedure. The complainant was unable to provide any evidence to support the allegation. Closed on the basis that Eni Ghana applied the grievance procedure and no further action can be taken.






Ghana is also recommended. The scope of the audit should include visual inspection of disposal facilities and the workers’ camp located close to Atuabo.

015 9/17

Waste management

Segregation of wastes at the SINOPEC camp near Atuabo is poor.

Construction PS3

Instructions regarding waste management expectations should be reinforced.

Minor

PENDING

IESC has been informed that action was taken but was unable to visit the ORF and surrounding camps to verify, hence ‘pending’ status.

016 9/17

Completion Fluids

The pH in discharges completion/workover fluids has not been recorded in quarterly monitoring reports submitted to lenders. Eni Ghana confirmed this was an omission.


pH to be reported in future quarterly monitoring reports.

Minor

CLOSED

See IESC’s Q3 2017 monitoring report

017 9/17

SINOPEC Worker Accommodation Camp

The camp is located close to small rural communities. During an IESC inspection, no signs or notices about personnel/community H&S issues such as STIs, including HIV/AIDS, were seen in the camp.

Construction PS4

Notices to be displayed in all locations within the camp where workers can gather together/socialize.

Moderate CLOSED

Closed on the basis of photographic evidence provided

018 9/17

Security Management Plan

A draft Security Management Plan, consistent with the ESHIA Report and PS 4 commitments, is being revised for internal review and is behind schedule (ESAP).

Construction and Operation PS4

Finalize and approve the Security Management Plan as soon as possible. Work to revise the Security Management Plan must provide details on types, scales and

Moderate

SUPERSEDED






The draft Security Management Plan is imprecise regarding the types, scales and locations of exclusion and advisory/avoidance zones and legally enforceable powers of Eni Ghana and the Ghana Navy with respect to the different types of zones. It is, also, not consistent with the treatment of these zones as described in the Fisheries Management Plan. Finally, it does not reference the Marine Traffic Management Plan.

locations of exclusion and advisory/avoidance zones and the legally enforceable powers of Eni Ghana and the Ghana Navy with respect to the different types of safeguarding zones. Also, the Security Management Plan needs to be aligned with the Fisheries Management Plan and the Marine Traffic Management Plan with respect to details regarding the safeguarding zones and security provision.

The current Project Security Management Plan was prepared after the IESC’s September 2017 monitoring visit and the drafting of the recommendation opposite. The Plan is now being revised. The IESC has made an additional recommendation (see Table 4 above).

019 9/17

Contractor Management - security

Appendix Q is not always issued to all contractors.

Construction and Operation PS4

Appendix Q to be updated to reflect the approved and ‘signed off’ Security Management Plan requirements (approval and ‘sign off’ has not yet occurred) regarding application of the Voluntary Principles for Security and Human Rights to procurement and management of security providers. Once updated and revised Appendix Q to be issued with all ITTs/model contracts to prospective contractors (with a proviso that a contractor can seek Eni Ghana approval that security requirements are not applicable to its operations).

Moderate

OPEN

As the Project Security Management Plan is undergoing a second revision, Appendix Q will need to be updated accordingly.

020 9/17

Implementation of LRP Support Services

Delays in establishing the complete LRP delivery team (in Accra and in the

Construction PS5

Devote sufficient resources to its local partners to ensure that the Support Services component of the

Moderate OPEN






concession area) and in implementing the LR Programme have continued.

LR Programme continues according to schedule and that there are no more delays.

Furthermore, Eni Ghana should revise the LRP to include the current implementation schedule for the LR Programme Support Services.

Technoserve (the lead delivery partner) has been contracted and is currently mobilizing in the field according to its implementation plan. No more delays should occur. This element is considered closed.

The LRP has not been revised to include the current implementation schedule for the LR Programme Support Services. The IESC understands Technoserve is developing a detailed implementation schedule. Item 020 9/17 will be fully closed following receipt and review of the schedule.

021 9/17

Fisheries Management Coordination Committee

The Committee remit (objectives, functions and responsibilities) is not clearly expressed. There is a potential for a ‘conflict of interest’ to arise in terms of Committee composition and its stated function to negotiate compensation/disturbance allowance on behalf of potentially affected fishermen.


Clarify Committee remit prior to establishing its modus operandi. The Committee to be established and operational as a priority in advance of activities that could adversely affect fishermen.

Moderate

CLOSED

The Terms of Reference for the Committee have been approved and the Committee meets, at minimum, every month (see Section 10.3).






The Committee has not been established (The Fisheries Management Plan foresees it being established by the end of June 2017).

022 9/17

Influx Management

The potential effectiveness of the Influx Management Plan is threatened by the limited progress to date in establishing the collaborative Multi-Stakeholder Forum for managing cumulative impacts, including coordinated actions to manage influx.


Eni Ghana must continue to support WBG efforts to establish a collaborative Multi-Stakeholder Forum.

Establish whether the ‘influx management approach’ prepared by WRCF, is an appropriate basis for revising the Influx Management Plan by end of Q4 2017.

Moderate

OPEN

The Multi-Stakeholder Forum is not yet established and functioning (See comment above on item ID 027 2/17). Thus, this element remains OPEN

Eni Ghana confirmed that the WRCF the ‘influx management approach’ prepared by WRCF, was not an appropriate basis for revising the Influx Management Plan as the ‘approach’ related only to implementing the actions of the Influx Management Plan. Thus, the Influx Management Plan does not require a revision based on the WRCF ‘approach’.






This element is considered to be closed

023 9/17

Invasive species Invasive species have been identified on site by ESL.

Construction Eni to confirm what actions are being taken to prevent further spread of invasive species. Minor

PENDING

Issue will be revisited when IESC next visits ORF

024 9/17

Bushmeat Instructions relating to bushmeat given to workers during Technip inductions should be reinforced.

Construction Technip to implement measures to reinforce the bushmeat policy. This might be included as an item in a workers’ code of conduct - setting out minimum behavioural expectations, including those relating to bushmeat.

Minor

CLOSED

Although not included in a ‘code of conduct’ periodically bush meat related trainings / awareness programs are scheduled and delivered/reinforced (ref Technip HSES actions tracking register).

025 9/17

Flora Conservation Plan

Further survey effort is required along the onshore pipeline right of way to identify protected plant species.

Construction Eni Ghana should endeavour to undertake rapid survey of area along the route yet to be cleared. The FCP should be updated to reflect any additional survey effort.

Moderate

PENDING

IESC was unable to revisit this issue during the monitoring visit.

026 9/17

Site drainage Discharge of site surface water drainage to the swamp poses the risk that large amounts of suspended sediment will be discharged to the swamp with negative impacts to the swamp ecology.

Construction In addition to the planned environmental monitoring, sediment traps/settling ponds should be put in place at the three discharge points.

Moderate

OPEN/IN PROGRESS

Design and variation Order requested by Eni Ghana – see Section 11.3.






IESC has been informed that sediment traps will be installed. Design process is currently underway. This action will be closed once sediment traps are constructed.

027 9/17

Top soil The long-term storage (>6 months) of top soil should be avoided, particularly under plastic sheeting which may damage the natural seed bank.

Construction Eni Ghana should closely monitor stockpiled top soil quality and duration of top soil storage and consider alternatives to plastic sheeting, including seeding and possible use of a geotextile, such as geojute, where long term storage is required.

Minor

PENDING

IESC was unable to visit the ORF site to inspect top soil stockpiles.

028 9/17

Contractor management

The CHMP is not contained in the list of SLC management plans that a contractor is obliged to prepare (if applicable to its activities) and submit to Eni Ghana for approval.

Construction and Operations PS1 and PS8

The CHMP to be added to list of SLC plans which are referenced in Appendix Y as being the source of all requirements to be incorporated by contractors into their own SLC Program/suite of plans to be submitted to Eni Ghana for approval.

Minor

PENDING

The IESC was not able to verify the status of this recommendation during the March 2017 monitoring visit. It will be verified during the forthcoming Q3 2018 monitoring visit.



APPENDIX 5 PHOTOLOG

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Photo 1. Support vessel alongside FPSO to dewater a riser

Photo 2.

Localised bunding for a temporary activity (FPSO)

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Photo 3. Waste segregation at source

Photo 4. Permanent bunding around each module

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Photo 5. Guard vessel located outside the 500m exclusion zone

Photo 6. Plugs installed to prevent surface runoff to sea from FPSO deck

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Photo 7. FPSO anchor chains providing a mooring point for fishing boats

Photo 8. Fishing vessel moored to FPSO anchor chain

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Photo 9. Flexible offloading pipe connecting FPSO with shuttle tankers

Photo 10. Inspection of life rafts (in date)

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Photo 11. A second fishing vessel moored to PFPSO anchor chains. Fishermen seen to be cooking on an open flame.

Photo 12. Storage of 200 litre drums containing fuel and other hazardous materials. Isolated examples of unlabelled drums.

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Photo 13. Temporary waste storage awaiting transfer to shore. Segregation at source.

Photo 14. General image of FPSO taken from the accommodation block

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Photo 15. HSE notice board at entrance to site

Photo 16. Secondary containment for diesel generator

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Photo 17. Fixed ladder to roof of a container. Would benefit from signage to prevent unauthorised access.

Photo 18. Waste area – segregation of wastes evident

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Photo 19. Use of water bowser for dust suppression

Photo 20. Unmanned gate to active gas facility

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Photo 21. Good use of PPE and flagman in the background

Photo 22. View of the pipeline right of way taken from the GNGC TRMS

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Documents

OFFSHORE CAPE THREE POINTS ENVIRONMENTAL AND SOCIAL ...€¦ · this suggestion as it went some way to enabling work to be done with respect to achieving objective 6 of the site visit