SRK Consulting: 467328: PPC Barnet_Framework ESIA and ESMP Page 389. Appendix A: Gap Analysis

SRK Cnsulting: 467328: PPC Barnet_Framewrk ESIA and ESMP Page 389 Appendix A: Gap Analysis Anam/Brl 467328_PPC Barnet Framewrk ESIA/ESMP January 2014

Gap Analysis f the Envirnmental Impact Assessment fr the PPC New Sngll Cement Plant in DRC Reprt Prepared fr PPC Ltd Reprt Number 467328 Surce: PPC Pht Gallery Reprt Prepared by September 2013

SRK Cnsulting: Prject N: 467328 Page i Gap Analysis f the Envirnmental Impact Assessment fr the PPC New Sngll Cement Plant in DRC PPC Ltd PPC Building 1 180 Katherine Street Barlw Extensin Sandtn Jhannesburg PO Bx 787416 Sandtn 246 Suth Africa SRK Cnsulting (Suth Africa) Pty Ltd 265 Oxfrd Rd Illv 2196 Jhannesburg Suth Africa e-mail: jhannesburg@srk.c.za website: www.srk.c.za Tel: +27 (0) 11 441 1111 Fax: +27 (0) 11 880 8086 SRK Prject Number 467328 September 2013 Cmpiled by: L Brwn Principal Envirnmental Scientist Peer Reviewed by: D Kilian Partner Email: lbrwn@srk.c.za Authrs: L Brwn Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page i Table f Cntents Disclaimer... iii 1 Intrductin and Scpe f Reprt... 1 2 Backgrund and Brief... 1 2.1 Backgrund f the prject... 1 2.2 Nature f the brief... 2 3 Prject Objectives and Wrk Prgram... 2 3.1 Prgram bjectives... 2 3.2 Purpse f the Reprt... 3 3.3 Wrk prgram... 3 3.4 Statement f SRK Independence... 3 4 Overview f findings f the gap analysis... 3 5 Cnclusins and Recmmendatins... 6 5.1 Cnclusins... 6 5.2 Recmmendatins... 7 5.2.1 Apprach t addressing identified gaps... 7 5.2.2 Acceptance f prcess by preferred lenders... 7 5.2.3 Streamlining f baseline investigatins... 7 5.2.4 Scping and stakehlder engagement... 8 5.2.5 Timing f the ESIA update... 8 6 Prpsed next steps... 8 7 References... 10 Appendices... 11 Appendix A: Detailed Gap Analysis... 12 Appendix B: Prpsed Scpe f Wrk fr Specialists... 13 Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page ii List f Tables Table 4-1: Table captin...errr! Bkmark nt defined. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page iii Disclaimer The pinins expressed in this Reprt have been based n the infrmatin supplied t SRK Cnsulting (Suth Africa) Pty Ltd (SRK) by PPC Ltd (PPC). The pinins in this Reprt are prvided in respnse t a specific request frm PPC t d s. SRK has exercised all due care in reviewing the supplied infrmatin. Whilst SRK has cmpared key supplied data with expected values, the accuracy f the results and cnclusins frm the review are entirely reliant n the accuracy and cmpleteness f the supplied data. SRK des nt accept respnsibility fr any errrs r missins in the supplied infrmatin and des nt accept any cnsequential liability arising frm cmmercial decisins r actins resulting frm them. Opinins presented in this reprt apply t the site cnditins and features as they existed at the time f SRK s investigatins, and thse reasnably freseeable. These pinins d nt necessarily apply t cnditins and features that may arise after the date f this Reprt, abut which SRK had n prir knwledge nr had the pprtunity t evaluate. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 1 1 Intrductin and Scpe f Reprt PPC Ltd (PPC) thrugh the Barnet Grup S.P.R.L. (N. 01-93-N34963R) prpses develping a new cement prject at Sngll (hereafter referred t as the prpsed prject ) in the Lwer-Cng Prvince, Cataractes District, Sngll District f the Demcratic Republic f Cng (DRC). The prject area is lcated abut 200km frm Kinshasa (Figure 1). As PPC intends t apply fr funding frm internatinal lenders, it has decided t prepare an Envirnmental and Scial Impact Assessment (ESIA) that meets internatinal envirnmental and scial standards. SRK Cnsulting (Suth Africa) Pty Ltd (SRK) was cmmissined by PPC t review the Envirnmental Impact Assessment (EIA) undertaken in fulfilment f DRC envirnmental and scial legal requirements t identify any gaps in meeting the Equatr Principles III (June 2013) and the requirements f Equatr Principles Finance Institutins (EPFI) requirements, including the Internatinal Finance Crpratin (IFC) Perfrmance Standards (PS) n Envirnmental and Scial Sustainability (January 2012). This reprt presents the findings f SRK s gap analysis, and prpses an apprach t preparing an ESIA fr the prject that meets EPFI and IFC PS requirements, as set ut in SRK s prpsal dated 23 August 2013. Figure 1: Prject lcatin 2 Backgrund and Brief 2.1 Backgrund f the prject The area f prpsed prject is lcated near the Natinal Cement Plant (CINAT) n the utskirts f the twn f Kimpese, between the villages f Malanga and Zamba which are lcated at 5km and 8.5km respectively alng the Natinal Rad N.1. The N1 links the twn f Matadi t Kinshasa. A railway linking Matadi and Kinshasa is lcated apprximately 5km frm the prject site. The explitatin right fr the prject area was granted t the Barnet Grup in accrdance with Articles 47 and 137 f Law N. 007/2002 f July 11, 2002 relating t the Mining Cde and Article 281 Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 2 f the Mining Regulatins (Decree N. 038/2003) (EIA, 2010). The Barnet Grup applied fr and btained a Permanent Quarry Explitatin Authrisatin in 2011 (Certificate N. CAMI/CECP/6389/11) t quarry limestne. There are n ther land tenure, mining r quarry rights included in the prpsed prject area. The prject feasibility study anticipates an annual prductin f 900,000 tns f clinker based n a kiln supply f 1,440,000 tns f raw material at 77% f CaCO 3. It is estimated that the limestne reserve is apprximately 127 millin tns and is cvered by 45 millin tns f clay, laterite and verburden. This resurce will allw the cmpany t increase its prductin capacity 2,000 t 3,000 tns per day fr a perid f 30 years. In fulfilment f DRC Law N. 007/2002 relating t the Mining Cde and the Mining Regulatins (Decree N. 038/2003 f March 26, 2003), a lcal Cnglese cnsultant (name f cmpany t be prvided by PPC) was cmmissined t prepare an EIA fr the prpsed prject. The EIA was cnducted in December 2010 and apprved by the DRC Gvernment (DPEM). 2.2 Nature f the brief PPC s scpe f wrk based n discussin n 21 August 2013 invlves the fllwing tasks: Cnclude a Cnfidentiality Agreement prir t the cmmencement f the assignment Translate the EIA frm French t English Cnduct a technical review f the translated EIA t identify any gaps in meeting the requirements f internatinal gd practice principles, standards and guidelines including: Equatr Principles III Internatinal Finance Crpratin s Perfrmance Standards n Envirnmental and Scial Sustainability Wrld Bank Grup (WBG) Envirnmental, Health and Safety (EHS) Guidelines, including the General Guideline and Sectr-specific guideline n Cement and Lime Manufacturing Internatinal Labur Organisatin (ILO) Cre Cnventins and ther standards such as the Vluntary Principles n Security and Human Rights Prepare a reprt that presents the findings f the gap analysis and prvides an apprach and plan f actin fr addressing identified gaps in rder t prepare an ESIA that meets internatinal envirnmental requirements. 3 Prject Objectives and Wrk Prgram 3.1 Prgram bjectives The prject bjectives were t: Task A: Sign a Cnfidentiality Agreement with PPC Task B: Translate the EIEIAS frm French int English, and prvide this dcument t PPC fr their recrd Task C: Review the translated EIA against internatinal requirements fr envirnmental and scial sustainability t identify gaps Task D: Prepare a gap analysis reprt. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 3 3.2 Purpse f the Reprt This reprt has been prepared t advise PPC n gaps in the EIA that need t be addressed in rder t prepare an ESIA that meets internatinal envirnmental and scial requirements. This dcument is nt meant fr wider circulatin. The reprt als sets ut SRK s prpsed apprach t preparing an ESIA that meets EPFI requirements as well as aligns with the likely timing f PPC s negtiatins with relevant lenders. 3.3 Wrk prgram The assignment was cnducted frm 23 August t 13 September 2013 and the time was allcated as fllws: Task A: Sign Cnfidentiality Agreement 1 day Task B: Translatin undertaken by a prfessinal translatr 14 days Task C: Technical review f language and gap analysis 7 days Task D: Reprt develpment 2 days Task A was cmpleted prir t the cmmencement f Tasks B, C and D, which were run cncurrently. It is assumed that SRK will meet with the PPC prject team t discuss its findings and prpsed apprach t preparing an internatinally cmpliant ESIA that addresses gaps in the EIA. 3.4 Statement f SRK Independence Neither SRK nr any f the authrs f this Reprt have any material present r cntingent interest in the utcme f this Reprt, nr d they have any pecuniary r ther interest that culd be reasnably regarded as being capable f affecting their independence r that f SRK. SRK has n beneficial interest in the utcme f the technical assessment being capable f affecting its independence. 4 Overview f findings f the gap analysis The gaps the gaps that were identified in the EIA relate t: Lack f an envirnmental and scial management system (ESMS) fr the prpsed prject, including plicies, institutinal arrangement and staffing fr envirnmental health and safety (EHS) Key details pertaining t the prject descriptin Legal framewrk fr envirnmental and scial assessment and management Envirnmental and scial baseline studies, including wet and dry seasn data pertaining t surface and grundwater and air quality as well as sci-ecnmic cnditins f villages living and practicing their livelihds in clse prximity t the prpsed prject Identificatin f sensitive envirnmental and scial areas relative t the siting and layut f the prpsed prject Impact assessment methdlgy and presentatin f ratings Management planning Stakehlder engagement. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 4 Table 4-1 presents the key gaps that need t be filled in rder t ensure that the Envirnmental and Scial Impact Assessment (EISA) reprt meets the requirements f the EPFIs, IFC PSs and gd internatinal practice (GIIP). Appendix A prvides a detailed analysis f the EIA against the eight IFC PSs, which prvide a cmprehensive framewrk fr assessing cmpliance with glbally accepted internatinal standards. It is anticipated that the IFC PS bradly encmpass the principles and standards internatinally. The ESIA will hwever need t align and reference all relevant standards and guidelines f thse lenders that are being apprached by PPC. The ESIA will need t be updated t address additinal lender requirements identified in the curse f the develpment f the dcument, shuld these be identified. Table 4-1: Gaps fund in the EIA Issue Gap t be filled PS reference ESMS An ESMS needs t be develped which will set ut plicies plans and prgrammes, as well as rganisatinal arrangements and capacity fr mitigating and managing identified risks and impacts. Mnitring and review shuld be an integral part f this system. PS1, PS2 Prject descriptin Legal framewrk The crprate plicies must be aligned t the bjectives f the ESMS, and any plicy gaps filled. Typical plicies might include: Sustainable develpment Envirnment Human resurces Human rights Crprate scial respnsibility Health and safety Cmmunity develpment Resurce efficiency Supply chain management Prject infrmatin t be supplied includes the fllwing: Prject mtivatin, t include descriptin f exprt markets (if any), vlumes and rutes Surce f cal, and hw is this being transprted Water vlume requirements during different prject phases Staff requirements during different prject phases Staff accmmdatin (temprary and permanent, t include the use f migrant and expatriate staff Transprt vlumes and frequency Tpsil management Design and management f the verburden facility Hurs f peratin r the quarry and the plant Full layut f the quarry, plant and assciated infrastructure Pwer supply and measures fr pwer utages Rad and rail infrastructure, as well as pwerlines and cnveyrs Waste management, including management f hazardus waste Explsives and hazardus chemicals management and strage Management and strage f hydrcarbns Water pllutin management systems Efficiency aimed at minimising resurce and avidance f waste Service prviders and cntractrs Prvide an verview f natinal legislatin and plicies, internatinal standards and guidelines, as well as crprate guidelines n PS1 Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 5 Issue Gap t be filled PS reference sustainability Baseline Data t be prvided by PPC includes: PS3, PS4, cnditins High reslutin aerial phtgraphy f the entire prject site and PS6, PS8 surrunds Cmprehensive baseline data needs t be gathered as fllws: Surface and grundwater Air quality and climate, including greenhuse gases Ambient nise levels Sciecnmic cnditins including ecsystem services Sil, land capability and land use Natural habitat classificatin including f the aquatic envirnment Cultural heritage Traffic Baseline data needs t be cllected using methds such as site bservatin, surveys, sampling, census, as well as secndary surces. Predictive mdelling needs t be undertaken fr water, air and nise. Determining The ftprint f the develpment needs t be aligned carefully t PS1 sensitivities avid envirnmental and scial sensitivities Overlay infrmatin frm the specialists t determine the relative sensitivity f parts f the site Infrm layut and design Impact The ESIA needs expanding t meet internatinal standards PS1 assessment Systematic identificatin and assessment f risks and impacts applying a standardised methdlgy which assesses impacts befre and after mitigatin during difference prject phases Cumulative assessment f impacts frm ther develpments in the vicinity needs t be assessed Define the znes f influence fr impacts utilising spatially represented data Management plans and A cmprehensive envirnmental and scial management plan (ESMP) which presents the fllwing: PS1 prgrammes Mitigatin r enhancement measures need t be identified fr each impact by prject phase Institutinal rles and respnsibilities Mnitring, review, reprting and crrective actin Develp an envirnmental and scial actin plan, timeframes, respnsibilities, perfrmance indicatrs and targets, as well as resurces required fr implementatin Develp peratinal plans t cver: Emergency preparedness and respnse Cmmunity health and safety Labur and human resurces plan Greenhuse gas inventry and management plan Framewrk resettlement actin plan (including ecnmic displacement) Occupatinal health and safety Waste management plan Sustainable develpment plan Cultural heritage management plan (including chance find prcedure) Bidiversity management plan Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 6 Issue Gap t be filled PS reference Water quality mnitring plan Air quality management plan Strmwater management plan Resurce efficiency plan Nise abatement Clsure and rehabilitatin plan Stakehlder engagement Stakehlder analysis needs t be undertaken t identify stakehlders frm gvernment, civil sciety, lcal affected cmmunities and nn-gvernmental rganisatins. The dcument currently nly ntes engagement with villages. Vulnerable interest grups, ntably wmen, children and disabled need t be identified, and engagement needs t be structure ensure engagement PS 1, PS2, PS3, PS8 A tailred stakehlder engagement plan (SEP) needs t be develped t guide an nging engagement prcess. Infrmatin needs t be disclsed systematic and clear manner, t include a backgrund infrmatin dcument (BID) and nn-technical summary and cmment frms. The SEP needs t include a grievance mechanism Language barriers need t be vercme thrugh and apprpriate means f cmmunicatin utilised The stakehlder engagement prcess needs t be clearly dcumented Establish stakehlder engagement frum 5 Cnclusins and Recmmendatins 5.1 Cnclusins The key cnclusins f the Gap Analysis are as fllws: The EIA apprved by the DRC Gvernment will need t be significantly expanded t ensure that it meets internatinal standard fr ESIA Key gaps identified relate t the need fr the develpment f a cmprehensive ESMS, the descriptin f the prject, baseline studies and impact assessment, preparatin f management plans t mitigate prject impacts and stakehlder engagement The gaps relating t the legislative framewrk, prject descriptin, identifying sensitive areas impacted by the prpsed prject and assessing the impacts and preparing management plans can be addressed relatively quickly (i.e. abut 2 mnths) assuming the infrmatin is available The fllwing identified gaps are likely t require mre time (i.e. minimum f 6 mnths) t address: wet and dry seasn mnitring as part f the baseline investigatin f surface water, grundwater, air quality and bidiversity; and stakehlder engagement with lcal cmmunities, gvernment institutins (natinal, reginal and lcal), traditinal leaders and special interests grups The timing f lnger lead cmpnents f the ESIA (e.g. baseline studies fr water, air and bidiversity and stakehlder engagement) will be influenced by seasnal mnitring and the review/cmment perids f stakehlders Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 7 It des nt appear that the prpsed prject will result in physical displacement f lcal cmmunities but it will be necessary t survey the area t determine if there will be ecnmic displacement thrugh lss f access t land fr subsistence cultivatin and use f gds and services. This will necessitate field surveys and analysis f aerial phtgraphy (if available) There des nt appear t be high reslutin aerial phtgraphy f the prject area and surrunds which will be essential fr reviewing the lcatin and extent f farming activities within the prject area Based n the abve cnclusins, the updating f the EIA t an internatinal standard ESIA will nt be cmpleted by the Nvember 2013 but will need t be phased. 5.2 Recmmendatins The key recmmendatins arising frm the Gap Analysis are as fllws: 5.2.1 Apprach t addressing identified gaps SRK prpses a phased apprach t the updating f the bankable ESIA. In rder t meet tight timeframes, it suggested that the prcess be phased as fllws: Phase 1: Gap Analysis and High Level Actin Plan (this dcument) which highlights the areas that need t be addressed in rder t ensure that the requirements f EPFIs are met. Phase 2: Preparatin f ESIA and ESMP. This prcess shuld be cmpleted in tw steps as fllws: Phase 2a: Draft ESIA. This will present the legal framewrk, sensitivity analysis, baseline studies fr scial, cultural heritage and traffic, preliminary findings fr water, air and bidiversity baseline studies, as well as an interim impact assessment and ESMP. It will further prvide a Detailed Plan f Actin fr addressing utstanding infrmatin. The dcument will be prvided t preferred lenders fr review and cmment) Phase 2b: Cmprehensive ESIA. that includes the findings f remaining baseline studies and updates t the impact assessment and ESMP and management plans Phase 3: Review and finalisatin f ESIA. The cmprehensive ESIA reprt shuld be distributed t stakehlders (including lenders) fr review. Fllwing any updates based n feedback frm stakehlders, the ESIA reprt shuld be finalised including the Issues and Respnses Reprt and submitted t lenders fr disclsure and decisin making. 5.2.2 Acceptance f prcess by preferred lenders In rder t avid any challenges t the prpsed phased apprach, it is recmmended that PPC meet with preferred lenders as sn as is feasible t get their buy-in t the prcess. SRK can present the apprach if required. Cnsideratin shuld be given t submitting the Draft ESIA t preferred lenders t ascertain their cmments which can be addressed prir t the finalisatin f the ESIA. This can als give PPC an pprtunity t secure cmmitments frm the lenders fr their disclsure f the ESIA based n the detailed plan f actin. 5.2.3 Streamlining f baseline investigatins Where pssible, baseline envirnmental and scial investigatins shuld be cmpleted during Phase 2a s as t feed int the Draft ESIA reprt. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 8 Baseline investigatins relating t sci-ecnmic, cultural heritage, nise and traffic shuld be fast tracked and ideally rganised t take place during the first site visit (refer t Appendix B fr prpsed scpe fr specialist investigatins). Baseline investigatins that require lnger term mnitring t cver bth wet and dry seasns (i.e. surface water, grundwater, bidiversity (if required) and air quality) shuld be scheduled t cmmence at the first site visit (refer t Appendix B fr prpsed scpe fr specialist investigatins). 5.2.4 Scping and stakehlder engagement Scping f issues shuld be undertaken during Phase 2a in rder t infrm the Draft ESIA Stakehlder engagement shuld cmprise a minimum f tw runds f engagement namely: Ntificatin f stakehlders regarding the updating f the EIA Release f Cmprehensive ESIA fr review and cmment Frmal presentatin f dcumentatin t stakehlders, and engagement t gather feedback and cmment The Draft ESIA shuld be prvided t lenders fr their input and review The Cmprehensive ESIA shuld be released t the lenders cncurrently as it is being reviewed by DRC stakehlders The feedback frm DRC stakehlders shuld be captured in the frm f an Issues and Respnses Reprt and used t updated the Stakehlder Engagement Plan. 5.2.5 Timing f the ESIA update Based n the phased apprach recmmended abve, it is envisaged that the ESIA update fr the prpsed prject can be scheduled as fllws: Phase 2a: Mid-September t end-nvember 2013 Phase 2b: Mid-Nvember 2013 t Mid-June 2014 Phase 3: July 2014. 6 Prpsed next steps Fllwing PPC s review f the Gap Analysis and prpsed apprach t updating the EIA t meet EPFI requirements, it is prpsed that: The PPC prject team fr the prpsed prject meet with SRK t discuss the findings and recmmended apprach set ut in the Gap Analysis SRK t amend the prpsed apprach t the EIA update based n feedback frm PPC PPC cnfirm the scpe f wrk and timing f the prpsed prject and request SRK t prceed with the preparatin f a prpsal and estimate f csts SRK submit the prpsal and budget fr updating the EIA fr cnsideratin by PPC Upn apprval f SRK s prpsal, wrk shuld cmmence. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 9 As nted abve, it is recmmended that PPC apprach the lenders as sn as feasible t gather feedback n the prpsed apprach. Prepared by L Brwn Principal Envirnmental Scientist Reviewed by D Kilian Partner All data used as surce material plus the text, tables, figures, and attachments f this dcument have been reviewed and prepared in accrdance with generally accepted prfessinal engineering and envirnmental practices. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 10 7 References Annymus (2010). PPC Cement: EIA and EMP fr New Cement Plant, December 2010. Study cmmissined fr PPC Barnet. IFC (2012). Perfrmance Standards n Envirnmental and Scial Sustainability, including the Guidance Ntes. Published by the Internatinal Finance Crpratin, 1 January, 2012. The Equatr Principles (2012). A financial industry benchmark fr determining, assessing and managing envirnmental and scial risk in prjects. Draft published June 2013 Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 11 Appendices Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: Prject N: 467328 Page 12 Appendix A: Detailed Gap Analysis Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 1 Appendix A 2012 IFC Perfrmance Standards Review f PPC Barnet EIA Table f Cntents 1 PS1: Assessment and Management f Envirnmental and Scial Risks and Impacts 2 2 PS2: Labur and wrking cnditins... 7 3 PS3: Resurce Efficiency and Pllutin Preventin... 9 4 PS4: Cmmunity health and safety, and security... 11 5 PS5: Land Acquisitin and Invluntary Resettlement... 13 6 PS 6: Bidiversity Cnservatin and Sustainable Management f Living Natural Resurces 18 7 PS7 Indigenus Peples... 21 8 PS 8: Cultural Heritage... 21

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 2 Table 1-1: IFC Perfrmance Standards Review fr PPC Barnet 1 PS heading Para. Ref. Detail Review cmment Recmmendatin 1 PS1: Assessment and Management f Envirnmental and Scial Risks 2 and Impacts 3 Objectives Identify and evaluate envirnmental and scial (E&S) risks and impacts f the prject; Adpt a mitigatin hierarchy t anticipate and avid, r where avidance is nt pssible, minimize 4, and, where residual impacts remain, cmpensate/ffset fr risks and impacts t wrkers, Affected Cmmunities, and the envirnment; Prmte imprved envirnmental and scial perfrmance f clients thrugh the effective use f management systems; Ensure that grievances frm Affected Cmmunities and external cmmunicatins frm ther stakehlders 5 are respnded t and managed apprpriately; Prmte and prvide means fr adequate engagement with Affected Cmmunities thrughut the prject cycle n issues that culd ptentially affect them and t ensure that relevant envirnmental and scial infrmatin is disclsed and disseminated. Envirnmental and scial assessment and management system 5 Cnduct a prcess f envirnmental and scial assessment and establish and maintain an Envirnmental and Scial Management System (ESMS) 6 incrprating the fllwing elements: plicy; identificatin f risks and impacts; management prgrams; rganizatinal capacity and cmpetency; a emergency preparedness and respnse; stakehlder engagement; and mnitring and review. The cmpany that carried ut the drafting f the EIA is nt stated, the date that the wrk was dne, nr the status f apprval is nt stated An envirnmental impact assessment t cmply with DRC requirements has been cmpleted and authrisatin prvided. While the reprt cvers sme f the internatinal standards, significant gaps and areas f further detail remain t be filled t meet IFC requirements. The EIA cvers numerus elements f a management system, including varius measures fr management f aspects f cnstructin and peratinal equipment. A frmal management system, such as an internatinally accredited system) culd be cnsidered fr implementatin. Cmpany activities have been updated since the EA was carried ut and the assessments d nt cver the full extent f prductin envisaged. Revise the ESIA/ESAP dcumentatin in line with recmmendatins made in this reprt. Develp a management system, t be in alignment with identified risks and pririties fr management. Plicy 6 Establish an verarching, stand-alne, prject-specific plicy, which defines E&S bjectives and principles that guide the prject t achieve sund E&S perfrmance. The plicy shuld: specify that the prject will cmply with applicable hst cuntry and internatinal laws and regulatins; be cnsistent with the principles f the Perfrmance Standards; include ther internatinally recgnised standards, certificatin, cdes f practice subscribed t; indicate wh, within the client s rganisatin, will ensure cnfrmance with the plicy and be respnsible fr its executin (reference third parties as relevant). Cmmunicate the plicy t all levels f the rganisatin. As key cmpnents f the ESMS, PPC Barnet will need t develp a plicy, a suitable EHS management structure which will include cmpetencies fr emergency preparedness and respnse, as well as stakehlder engagement t be assciated with apprpriate plans incrprating mnitring and review. The full extent f requirements is elabrated n within this table belw and in the assciated actin plan. It needs t be identified which plicies PPC Barnet has in place are applicable t the DRC prject., t becme the basis fr the ESMS fr the prject. These shuld be adapted (where relevant plicies exist) and gaps filled t be cmpliant with the IFC requirements. PPC Barnet t review its existing plicies and, with the assistance f SRK, identify where new plicy is required r where updates t fill gaps are necessary. The crprate plicies must be aligned t the bjectives f the ESMS, and any plicy gaps filled. Typical plicies might include: Sustainable develpment Envirnment Human resurces Human rights Crprate scial respnsibility Health and safety Cmmunity develpment Resurce efficiency Supply chain management 1 NOTE TO THE USER: This table is an SRK Cnsulting prepared summary f the IFC Perfrmance Standards (2012) and is nt intended t substitute the PS Guidance Ntes. 2 E&S risk is a cmbinatin f the prbability f certain hazard ccurrences and the severity f impacts resulting frm such an ccurrence. 3 E&S impacts refer t any change, ptential r actual, t (i) the physical, natural, r cultural envirnment, and (ii) impacts n surrunding cmmunity and wrkers, resulting frm the business activity t be supprted. 4 Abate, rectify, repair, and/r restre 5 Other stakehlders are thse nt directly affected by the prject but that have an interest in it. These culd include natinal and lcal authrities, neighburing prjects, and/r nngvernmental rganizatins. 6 Apprpriate t the nature and scale f the prject and cmmensurate with the level f its scial and envirnmental risks and impacts.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 3 PS heading Identificatin f risks and impacts Para. Ref. Detail Review cmment Recmmendatin 7 Establish and maintain a prcess 7 fr identifying prject-related E&S risks and impacts, in accrdance with gd internatinal industry practice (GIIP) 8. 8 Ensure that the risks and impacts identificatin prcess: is based n recent E&S baseline data at an apprpriate level f detail; cnsiders all relevant E&S risks and impacts f the prject, including thse frm PS2 t PS8, and thse wh are likely t be affected by such risks and impacts (including individuals/grups that are cnsidered disadvantaged r vulnerable 9 ) and cmplement this with a human rights due diligence in high risk circumstances; cnsiders the emissins f greenhuse gases, the risks assciated with a changing climate (and adaptatin pprtunities), and ptential transbundary effects. Analyse risks and impacts in the cntext f the prject s area f influence encmpassing: the area likely t be affected by: the prject and related facilities that the client and its cntractrs develps r cntrls; unplanned but predictable develpments caused by the prject that may ccur later r at a different lcatin; indirect prject impacts n bidiversity r n ecsystem services. assciated facilities nt funded as part f this prject and whse viability and existence depend exclusively n the prject and are essential fr the successful peratin f the prject; areas ptentially impacted by cumulative impacts fr further planned develpment f the prject, any existing prject r cnditin and ther prject-related develpments. 9 Cnsider risks and impacts resulting frm third party invlvement (where the client can reasnably exercise cntrl). 10 Cnsider risk and impacts assciated with primary supply chains (where the client can reasnably exercise cntrl) defined in PS2 and PS6. The EIA includes a generic and qualitative descriptin f a range f prject related risks and impacts. Hwever, there is insufficient baseline infrmatin presented upn which t base the impacts assessed cvering aspects including water, air quality, scial, cultural heritage and climate change (GHG emissins). The risk and impact identificatin and evaluatin prcess is nt cmprehensive, systematic r based n an internatinally accepted rating methd. The impact assessment methd des nt deal with the prject in phases (cnstructin, peratin and decmmissining/ clsure), nr des it deal with pre-and pstmitiatin impacts.. E&S risks and impacts are nt in general based n detailed baseline data and substantial deficiencies in baseline and mnitring data exist (ntably water quantity (wet and dry seasn data and mdelling nt presented), water quality, air quality, nise, scial, bidiversity (dry and wet seasn data des nt appear t have been gathered) and cultural heritage). The risks and impacts are described generically in the ESIA. There are n mdelling studies, n quantificatin f impacts, n rating system used t assess significance, and thus n relative imprtance assigned t understand materiality fr management, althugh the ESAP des list the key pririties fr management. There is als n cnsideratin f impacts per prject phase, and nne fr clsure and decmmissining. Receptrs are nt described and surces f impacts are generic and s auditability is difficult. Limited labur, security r wrkplace health and safety impacts are cnsidered in the ESIA. The emissin f greenhuse gases is briefly cnsidered in the EIA check, but n quantificatin is given based n emitting surces and land use change. Area f influence is nt clearly specified fr the baseline data r impact assessment. It is nt explicit r clear in the ESIA what prject activities are included in the assessment, and unplanned but predictable develpments, as well as cumulative impacts are nt assessed. Few indirect impacts are cnsidered althugh these culd ptentially be the mst significant impacts that require management interventin. There appears t be insufficient cnsideratin f assciated facilities such as rad infrastructure. A cumulative impact descriptin shuld include impacts assciated with reginal develpment which culd result in significant envirnmental and scial impacts. While it is SRK s current understanding that there will nt be any physical displacement f cmmunities caused by the develpment ftprint, it is pssible that there will be ecnmic displacement invlved (displacement f crp prductin, as well as impacts n ecsystem services). Cmpensatin fr ecnmic displacement wuld need t be undertaken in line with DRC and IFC requirements, while impacts n ecsystem services will need t be addressed thrugh management planning. A resettlement actin planning prcess will need t be implemented shuld there be ecnmic displacement. PPC Barnet will need t take steps t ensure that key suppliers such as hspitality management, security, lcal suppliers f cnstructin materials and ther service prviders d nt cntravene child and frced labur guidelines, r place their PPC Barnet shuld determine whether in-huse risk assessment and management dcumentatin is available fr analgus prjects. If available, these shuld guide the identificatin f ptential risks and impacts fr the current prject. Revise the ESIA dcuments t ensure that all relevant risks and impacts have been identified in accrdance with GIIP. Carry ut impact identificatin and rating using an internatinally credible methd t be applied t individual prject phases (cnstructin, peratin and decmmissin/ clsure as relevant) per impact. Assessment must cver bth pre-and pst-mitigatin impact assessment There further needs t be revisin and expansin f the mnitring plans as well as priritisatin f management actins. Carry ut a cmprehensive scial baseline assessment, t ensure attentin is paid t identificatin f vulnerable grups. Cnduct a greenhuse gas inventry and cmpile a greenhuse gas management plan. Assessments and management plans shuld be cmpiled that fcus n the area f influence f each prject activity, as well as incrprating indirect and assciated facilities, and reginal develpment and cumulative impacts. Checking f the prject descriptin in the EIA shuld be carried ut t ensure that all develpment activities have been identified, the ftprint f the develpment is clearly depicted in a map (shapefile-based), which needs t include the plant, quarry, and assciated infrastructure. These features need t be shwn in relatin t surrunding receptrs including villages. Verify which additinal assciated facilities such as transprt infrastructure shuld be included in the prject descriptin. Shuld the prject result in ecnmic displacement, (t be determined thrugh a detailed baseline survey) cmpensatin agreements will need t be negtiated with displaced stakehlders. Transparency and fairness in cmpensatin prcesses will need t be ensured, including thrugh the develpment f a disclsed Resettlement Actin Plan. PPC Barnet shuld review gvernment cmpensatin framewrk t see alignment with PS5. A prtcl will need t be put int place fr the checking f supply chains and service prviders, t include the safe dispsal f wastes. This will need t include a mnitring prgramme t ensure cmpliance with PS2 7 The prcess may cmprise a full-scale ESIA; a limited r fcused ESIA; applicatin f envirnmental siting, pllutin standards, design criteria, r cnstructin standards; E&S audits; E&S risk/hazard assessments. 8 The exercise f prfessinal skill, diligence, prudence, and fresight that wuld reasnably be expected frm skilled and experienced prfessinals engaged in the same type f undertaking under the same r similar circumstances glbally r reginally. 9 This disadvantaged r vulnerable status may stem frm an individual s r grup s race, clur, sex, language, religin, plitical r ther pinin, natinal r scial rigin, prperty, birth, r ther status. The client shuld als cnsider factrs such as gender, age, ethnicity, culture, literacy, sickness, physical r mental disability, pverty r ecnmic disadvantage, and dependence n unique natural resurces.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 4 PS heading Para. Ref. Detail Review cmment Recmmendatin wrkers in life threatening situatins. Supplies received based n cnversin natural resurces such as fd, fibre and cnstructin materials shuld be cnsidered, as shuld the dispsal f wastes. and PS6 11 Take cgnisance f the findings and cnclusins f related plans, studies r assessments that are directly related t the prject and its area f influence and the utcme f engagement with Affected Cmmunities. 12 Identify individuals and grups directly and differentially r disprprtinately affected by the prject because f their disadvantaged r vulnerable status and implement differentiated measures t ensure they are nt disprprtinally impacted r disadvantaged in terms f benefits and pprtunities. Management 13 Establish management prgrammes that describe mitigatin and perfrmance Prgrams 10 11 imprvement measures and actins that address the identified risks and impacts. 14 Favur impact and risk avidance ver minimizatin, and where residual impacts remain, cmpensate r ffset these, where technically and financially feasible. 15 Ensure mitigatin and perfrmance measures cmply with applicable laws and regulatins and meet PS1 t PS8. 16 Establish E&S Actin Plans 12 defining desired utcmes as measurable events with perfrmance indicatrs, targets and acceptable criteria that can be tracked ver defined perids, with estimates f resurces and respnsibilities fr implementatin. Plans must recgnise the rle f third parties and must be respnsive t changes in circumstances, unfreseen events and results f mnitring and review. PPC Barnet will need t undertake a prcess f identifying and btaining gvernmental and civil sciety plans relevant t the prject area f influence, t include natinal plans and strategic assessments which pertain t the develpment f the cement industry in DRC. The prject may reduce the land available fr subsistence agriculture r fd harvesting, which is likely t place an added burden n cmmunities including wmen. Mitigatin measures are included in the discussin f impacts is cntained in the EIA, with an verarching management plan. Hwever n detailed management prgramme exists with apprpriate, criteria, respnsibilities, timelines and budget. There are currently n detailed prgrammes and plans encmpassing cmmunity (sustainable) develpment, emergency preparedness and respnse, mine reclamatin and clsure, stakehlder engagement, waste management, ccupatinal health and safety, cmmunity health and safety, labur and human resurces, strmwater management, air pllutin management as well as resettlement shuld be develped. Plans are further required fr bidiversity management and resurce use efficiency. The develpment f standards, plicies and prcedures shuld be aligned, with the custdian f these being cmpany management, nt divisinal management. Strng fcus needs t be placed n the avidance t damage f ecsystems, livelihds and pllutin, rather than end-f-pipe slutins. This shuld encmpass a screening exercise t ensure the as the careful siting f the develpment in relatin t crp prductin (ecnmic displacement), cmmunities in relatin t ambient wind directin (health and nuisance impacts), watercurses and water bdies (flding, ersin and pllutin risks), and careful siting f waste management facilities (health and pllutin risks). The impact assessment and mitigatin measures are generic, and will need t be revised. Imprtantly, existing measures d nt cnsider the IFC Envirnmental, Health and Safety Guidelines. The ESAP and Management Plans d nt define specific utcmes, measurable events with perfrmance indicatrs, targets and acceptable criteria. It is nt clear what criteria are tracked in mnitring prgrammes, and respnsibilities fr implementatin are nt clearly described. Cnsideratin f the rle f third parties is nt prvided. The updated ESIA dcumentatin, prcedures and activities need t take accunt f natinal plicy and planning initiatives, including at the lcal level. Stakehlder engagement will need t take cgnisance f risks and impacts as identified by affected cmmunities. If it is identified that there will be ecnmic displacement thrugh develpment f the prject (such as subsistence crp prductin), a Resettlement Actin Plan will need t be develped t address this issue. Further, a mre detailed Cmmunity (Sustainable) Develpment Plan shuld be develped which sets ut measures fr vulnerable peple including wmen, disabled adults, HIV infected peple and thers. cmpile plans fr cmmunity (sustainable) develpment, emergency preparedness and respnse, mine reclamatin and clsure, stakehlder engagement, waste management, ccupatinal health and safety, cmmunity health and safety, labur and human resurces, air pllutin, strmwater management as well as resettlement. These shuld include detailed planning including standards, perating prcedures and implementatin details. Cntractr management plans shuld frm an imprtant part f the plans. Implement a standardised system f plicies, prcedures and systems fr the rganisatin, with the custdian fr perfrmance being cmpany management and the sustainability department. Baseline assessments and identificatin and mapping f imprtant envirnmental and scial assets shuld be strengthened t infrm prject layut and design (screening). Develp a hierarchy f plicies, prgrammes and plans as utlined in this table. Revise impact assessments and develp management plans t incrprate the IFC EHS Guidelines. A management structure shuld be set in place, matched with an envirnmental and scial management system. Management prgrammes and actin plans including these elements shuld be cmpiled fr each area f critical management. The management system shuld be designed s that plans are implemented thrughut the rganisatin. Organizatinal capacity and cmpetency 17 Establish, maintain and strengthen as apprpriate an rganisatinal structure that defines rles and respnsibilities, authrity t implement the ESMS. Specific persnnel with clear lines f respnsibility and authrity shuld be designated. Key scial and envirnmental respnsibilities shuld be well defined and cmmunicated t relevant persnnel and the rest f the rganisatin. Sufficient management spnsrship and human and financial resurces will be prvided n an nging basis t achieve and cntinuus perfrmance. The rganisatinal structure fr the prject is nt yet in place given the early stage f develpment. Hwever, the IFC requires that structures are identified, including identificatin f the persns respnsible fr cmmunity liaisn, as well as envirnmental health and safety. An envirnmental and scial management system, incrprating an rgangram shuld be develped. Envirnmental and scial rles and respnsibilities shuld be clearly defined. 10 Prgrams may cnsist f cmbinatins f peratinal prcedures, practices, plans, and related supprting dcuments (including legal agreements) managed in a systematic way. 11 Prgrams may apply bradly acrss the client s rganizatin, including cntractrs and primary suppliers ver which the rganizatin has cntrl r influence, r t specific sites, facilities, r activities. 12 Actin Plan/Management Plan/Develpment Plan.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 5 PS heading Para. Ref. Detail Review cmment Recmmendatin Emergency preparedness and respnse 18 Persnnel with direct respnsibility fr E&S perfrmance must have the apprpriate knwledge, skills, and experience necessary t perfrm their wrk, including implementatin f the measures and actins in the ESMS and current knwledge f hst cuntry regulatin and the requirements f PS1 t PS8. 19 E&S prcess must cnsist f an adequate, accurate, and bjective evaluatin and presentatin, prepared by cmpetent prfessinals. External experts must assist in the risks and impacts identificatin prcess fr prjects with significant adverse impacts r that are technically cmplex. 20 Establish and maintain an emergency preparedness and respnse system identifying: areas where incidents may ccur; cmmunities and individuals that may be impacted; respnse prcedures; prvisin f equipment and resurces; designatin f respnsibilities; cmmunicatin (including Affected Cmmunities) and training t ensure effective respnse. Review and revise activities peridically. 21 Assist ptentially affected cmmunities and lcal gvernment with preparatins t enable effective respnse t emergency situatins (if applicable). Where lcal gvernment agencies have little r n capacity t respnd effectively, the Client will play an active rle in preparing fr and respnding t emergencies assciated with the prject. Dcument and disclse t Affected Cmmunities and gvernment agencies. Mnitring and review 22 Establish prcedures fr mnitring and measuring effectiveness f the management prgramme and cmpliance with legal/cntractual bligatins and regulatry requirements. Include representatives frm Affected Cmmunities in the mnitring activities (where apprpriate). Retain qualified external experts t verify mnitring infrmatin. 23 Use inspectins and audits t verify cmpliance and prgress tward desired utcmes. Dcument results and crrective and preventative actins implemented and fllwed up. 24 Relay the effectiveness f the ESMS t senir management n a peridic basis. Senir management shuld take apprpriate steps t ensure that the intent f the client s plicy is met, the ESMS is being implemented and is effective. Staff required fr E&S perfrmance, including fr management f DRC regulatry and IFC cmpliance, have nt yet been appinted by PPC Barnet An EIA was cmmissined by PPC Barnet and was develped by XXXXX (PPC t supply) in rder t meet in-cuntry legal requirements fr which apprval fr the prject was granted by the DRC authrities. Significant updating f the dcumentatin is required t becme an IFC- cmpliant ESIA, as utlined in this table and the accmpanying actin plan. This is f significance, particularly since the prpsed prject pses significant risks and ptential impacts, bth in terms f the scial as well as the envirnmental baselines. N cmprehensive emergency preparedness and respnse system has been develped fr the prject which adequately identifies ptential incidents, affected cmmunities and individuals, and means f dealing with and updating the system. The gvernment agencies have little capacity t respnd t emergencies and will be reliant n PPC Barnet fr assistance. The EIA includes a sectin n mnitring which des nt define indicatrs and therefre measuring its effectiveness is difficult. While the EIA lists varius mnitring activities, it des nt cntain measures fr verifying and crrective actin twards desired utcmes (including audit prcedures) The ESMS fr the prject still needs develpment. A prgram fr reprting and reviewing als need t be develped. Apprpriate staff appintments shuld be implemented in a phased manner fr the prject, t ensure that structure are in place prir t cmmencement f cnstructin Specialist input will be required t ensure that key material risks and ptential impacts have been identified, that avidance and mitigatin management measures are cmprehensive, impacts have been adequately assessed using replicable and established methdlgy, and t assist with setting up a frmal envirnmental and scial management system. The rgangram fr the prject shuld be develped fr PPC Barnet, including the identificatin f rles and respnsibilities fr emergency preparedness and respnse. Emergency preparedness and respnse plan(s) cvering bth n-site and ff-site emergencies related t the prject shuld be develped as part f the EIA update prcess. Emergency plans shuld be updated prir t cnstructin nce design has been finalised. Ensure that the emergency preparedness and respnse plans (applying t bth n- and ffsite emergencies) incrprates the input f relevant gvernment agencies. Incrprate the dcumentatin develped int stakehlder engagement t ensure disclsure Cmpile and dcument a cmprehensive mnitring system in line with the updated impact assessment t be carried ut. Cmpile a legal register t be used as the basis f regular legal cmpliance reviews, particularly fr ptentially nerus requirements f new legislatin. Experts shuld be appinted prir t the cmmencement f cnstructin, and at regular intervals thereafter (at least annually) t verify mnitring infrmatin. Where relevant, representatives frm affected cmmunities shuld frm part f mnitring activities. The mnitring prgramme in the updated ESIA will need t be expanded upn t prvide clarity n rles, respnsibilities and frequencies f reprting, indicatrs, means f verificatin and auditing prcedures. Frm cmmencement f cnstructin and t be cntinued thrugh all prject phases, internal inspectins f facilities will need t be cmmenced by PPC Barnet s envirnmental health and safety staff. Results f internal inspectins and nn-cnfrmances shuld be recrded and dcumented. Crrective and preventative actins and respnsibilities shuld be included. The ESMS must be develped t include envirnmental health and safety reprting requirements. Frequencies f reprting, rles and respnsibilities will need t be clearly defined. A prgramme f reprting and reviewing will als need t be develped as part f the updated ESIA. On cmmencement f cnstructin, systematic mnitring f the prgress n implementatin f the management system will need t be undertaken by management. EHS issues will need t be addressed n a frequently (weekly) basis by management, with regular (mnthly) reprts are submitted by the EHS department fr review by tp management structures. An apprpriately cnstituted safety cmmittee shuld meet n a mnthly t review results..management and the Bard shuld regularly mnitr the implementatin f the management system

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 6 PS heading Stakehlder engagement Stakehlder analysis and engagement planning Disclsure f infrmatin Para. Ref. Detail Review cmment Recmmendatin 25 Stakehlder engagement is an nging prcess that may invlve the fllwing elements: stakehlder analysis and planning; disclsure and disseminatin f infrmatin; cnsultatin and participatin; grievance mechanism; nging reprting t Affected Cmmunities. 26 Identify stakehlders, including Affected Cmmunities, and cnsider external cmmunicatins t facilitate a dialg with them. 27 Develp and implement a SEP tailred t the characteristics and interests f the Affected Cmmunities. Include differentiated measures t allw effective participatin f thse identified as disadvantaged r vulnerable. Where the prcess depends n cmmunity representatives, verify that they represent the cmmunity views and can be relied n t cmmunicate results t cnstituents. 28 Where the prject lcatin is nt knwn, prepare a stakehlder engagement framewrk including general principles and strategy t: 29 identify Affected Cmmunities and ther stakehlders; plan fr an engagement prcess. Disclse infrmatin n the purpse, nature, scale f the prject, duratin f activities, risks and impacts n cmmunities, the envisaged stakehlder engagement prcess and grievance mechanism. Cnsultatin 30 Undertake a cnsultatin prcess that prvides Affected Cmmunities with pprtunities t express their views n prject risks, impacts and mitigatin measures. The client will cnsider and respnd t these. Infrmed cnsultatin and participatin (ICP) Ensure the cnsultatin is a tw-way prcess that: cmmences early in the assessment prcess and cntinues n an nging basis; is based n prir disclsure and disseminatin f relevant, transparent, bjective, meaningful and easily accessible infrmatin which is in a culturally apprpriate lcal language(s) and frmat and is understandable t Affected Cmmunities; is inclusive fr thse directly affected; is free f external manipulatin, interference r cercin and intimidatin; enables meaningful participatin; is dcumented. 31 Cnduct an Infrmed Cnsultatin and Participatin (ICP) prcess fr prjects that may have significant adverse impacts. ICP invlves a mre in-depth exchange f views and infrmatin, and an rganized and iterative cnsultatin, leading t the incrpratin f Affected Cmmunities views int the prject decisin-making prcess. The ICP prcess shuld: capture bth men s and wmen s views, separately if necessary; reflect men s and wmen s differing cncerns and pririties abut impacts, mitigatin mechanisms, and benefits; be dcumented, particularly measures taken t avid r minimise risks and impacts; infrm thse affected hw their cncerns have been cnsidered. Indigenus peples 32 Cnduct an ICP prcess fr prjects that may have adverse impacts t Indigenus Peples. In certain circumstances the client may be required t btain their free, prir and infrmed cnsent (FPIC) (refer PS 7). Private sectr respnsibilities under gvernment-led stakehlder engagement 33 When stakehlder engagement is the respnsibility f the hst Gvernment: cllabrate with the respnsible agencies (t the extent permitted) t achieve utcmes cnsistent with the bjectives f this PS. play an active rle in engagement planning, implementatin planning and mnitring (if Gvernment capacity is limited). Stakehlder engagement has taken place t date n the prject t meet DRC legal requirements. N cmprehensive stakehlder engagement plan (SEP) has yet been develped fr the prject, and neither has a grievance mechanism been established. Stakehlder engagement needs t be in place fr the full prject life cycle. Stakehlder engagement tk place during the develpment f the EIA, with a stakehlder database having been develped. Villages where cnsultatin has taken place are Zamba and Malange Village. Stakehlder engagement will need t be cntinued and expanded t ensure adequate disclsure f the updated ESIA. The SEP t be develped as part f the updated ESIA will need t be tailred t ensure, in particular, participatin by vulnerable grups including wmen and disadvantaged peple. Nt applicable The EIA des nt clearly indicate what cntent r infrmatin was prvided t cmmunity members during stakehlder engagement fr the EIA. A SEP and grievance mechanism has nt yet been develped and has nt been disclsed t cmmunities. The principles f stakehlder cnsultatin and disclsure need t be clearly presented thrugh PPC Barnet crprate plicies, and further need t be reflected in the SEP t be develped. Stakehlder engagement needs t be a key cmpnent in the updated ESIA, with implementatin taking place fr the lifetime f the prject. It was nt clearly indicated in the EIA whether r nt the stakehlder engagement prcess has been cnducted t date using independent stakehlder engagement specialists skilled at ensuring meaningful participatin. Detail n what was presented t the cmmunities is nt dcumented in the EIA. Questins were asked the stakehlders regarding their respnse t the prject. It is nt clear whether they were prvided sufficient pprtunity t raise their cncerns abut the prject. N dcumentatin f the issues and cncerns raised is prvided. It is als unknwn whether respnses were prvided t cmmunity members regarding cncerns raised (if any), Stakehlder engagement fr the prject has nt taken place in a structured way t date, s as t ensure that bth men and wmen can prvide cmment n an equal basis. Stakehlders will further need t be infrmed f hw their cncerns have been cnsidered which has nt taken place s far n the prject. Nt applicable as far as has been determined. Nt applicable. A cmprehensive SEP shuld be develped, t incrprate a grievance mechanism. The updated ESIA including the SEP and the grievance mechanism will need t be disclsed as an nging stakehlder engagement prcess fr the prject. The SEP t be develped as part f the updated ESIA will set ut a prcedure fr cmmunicating externally fr the full life f prject. Tailr the SEP t be develped as part f the updated ESIA t ensure participatin by vulnerable grups including wmen and disadvantaged peple. Nt applicable Further detail is required n what dcumentatin/infrmatin was prvided t cmmunities during stakehlder engagement fr the EIA. Develp a SEP and grievance mechanism t disclse t cmmunities alng with the updated ESIA Appint stakehlder engagement practitiners wh are independent f PPC Barnet t cnduct the stakehlder engagement and t review and update and stakehlder database. Cmmissin the develpment f a SEP and grievance mechanism t disclse t cmmunities alng with the updated ESIA. A nn-technical summary f the updated ESIA shuld be prvided in apprpriate language (such as Lingala as well as French) t ensure accessibility f text. A register f stakehlder issues and cmments shuld be kept. Apprpriate engagement shuld take place t as t encurage the participatin f vulnerable and disadvantaged stakehlders. Maintain the engagement prcess and grievance mechanism n an nging prcess fr the lifetime f the prject. An ICP prcess shuld frm part f a detailed sciecnmic survey f the study area, t frm part f the updating f the ESIA. Structured stakehlder engagement shuld take place t ensure that bth men and wmen s views n the prject are captures. The stakehlder engagement prcess must prvide feedback t cmmunities n hw their cncerns have been addressed. Nt applicable as far as has been determined. Nt applicable.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 7 PS heading External cmmunicatins Para. Ref. Detail Review cmment Recmmendatin cnduct a cmplementary prcess when the Gvernment-led prcess des nt meet the relevant requirements f this PS. 34 Implement and maintain a prcedure fr external cmmunicatin including methds t: receive and register cmmunicatins frm the public; screen and assess issue raised and hw t address them; prvide, track and dcument respnses; adjust the management prgram. Make public peridic reprts n E&S sustainability. Grievance mechanisms 35 Establish a grievance mechanism t receive and facilitate reslutin f Affected Cmmunities cncerns abut the prject s envirnmental and scial perfrmance. Cncerns will be addressed prmptly, using an understandable and transparent cnsultative prcess that is culturally apprpriate and readily accessible at n cst and withut retributin. It will nt impede access t judicial r administrative remedies. Cmmunities will be infrmed abut the mechanism as part f the stakehlder engagement prcess. Onging reprting t Affected Cmmunities 36 Prvide peridic reprts (nt less than annually) t Affected Cmmunities that describe prgress with implementatin f prject Actin Plans n issues f nging risk r impact n Cmmunities and n issues that are f cncern t Affected Cmmunities. 2 PS2 13 : Labur and wrking cnditins 14 Objectives Cmmunicate material changes r additins t mitigatin measures r actins described in the Actin Plans t Affected Cmmunities nt less than annually. A prcess fr tracking and addressing stakehlder cncerns has nt yet been established, and shuld be put in place prir t cmmencement f cnstructin. A grievance mechanism has nt yet been develped fr the prject. Since the prject has nt yet been implemented, regular reprting t cmmunities n nging risk r impacts has nt yet cmmenced. Prir t cmmencement f cnstructin, develp a SEP. This shuld incrprate the hlding f regular minuted meetings with cmmunities and regular reprting bth t cmmunities, as well as t PPC Barnet structures. A clear prtcl fr when and hw reprts are made available t the public shuld be develped. Set up a system that is able t track and dcument respnses t issues raised by cmmunities, and that actins plans are apprpriately updated in respnse t issues raised. A grievance mechanism shuld be develped aligned t PS1, with rles and respnsibilities within PPC Barnet fr addressing cmplaints. This shuld incrprate the prcedure fr recrding and addressing cmplaints, t include a hardcpy register with electrnic backup. The register shuld recrd when cmplaints were addressed and clsed ut. Cmmunities shuld be infrmed abut the grievance prcedure. Prir t cmmencement f cnstructin, develp a SEP. This shuld incrprate the hlding f regular minuted meetings with cmmunities and regular reprting bth t cmmunities, as well as t PPC Barnet structures. A clear prtcl fr when and hw reprts are made available t the public shuld be develped. Set up a system that is able t track and dcument respnses t issues raised by cmmunities, and that actins plans are apprpriately updated in respnse t issues raised. Prmte the fair treatment, nn-discriminatin, and equal pprtunity f wrkers; Establish, maintain, and imprve the wrker-management relatinship; Prmte cmpliance with natinal emplyment and labur laws; Prtect wrkers, including vulnerable categries f wrkers such as children, migrant wrkers, wrkers engaged by third parties, and wrkers in the client s supply chain; Prmte safe and healthy wrking cnditins, and the health f wrkers; Avid the use f frced labur. Wrking Cnditins and Management f Wrker Relatinship Human resurces plicies and prcedures Wrking cnditins and terms f emplyment 8 Adpt and implement apprpriate human resurce plicies and prcedures that set ut the apprach t managing wrkers in line with natinal law and PS2. 9 Prvide wrkers with clear and understandable, dcumented infrmatin regarding their rights under natinal labur and emplyment law and any applicable cllective agreements including rights related t: hurs f wrk, wages, vertime, cmpensatin, benefits upn beginning the wrking relatinship, and when any material changes ccur. 10 Respect cllective bargaining agreements with wrkers rganisatins. Prvide reasnable wrking cnditins and terms f emplyment where cllective bargaining agreements d nt exist, r d n address wrking cnditins and terms f emplyment. N Labur and Human Resurces plicies and prcedures have yet been incrprated int the ESMS fr the prject in line with DRC legislatin and IFC requirements, as well as relevant rganisatins such as the Internatinal Labur Organisatin (ILO). Since the prject has nt yet cmmenced implementatin, there is nt as yet a systematic system f recruitment. N Labur and Human Resurces plicies and prcedures have yet been incrprated int the ESMS fr the prject in line with DRC legislatin and IFC requirements, as well as relevant rganisatins such as the Internatinal Labur Organisatin (ILO). 11 Ensure migrant wrkers are identified and engaged n substantially equivalent terms and N clear descriptin is prvided n the estimated number f wrkers per prject phase, nr has infrmatin been prvided n Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in line with natinal law and PS2. Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in line with natinal law and PS2. The Labur and Human Resurces Plan must clearly set ut respect f cllective bargaining with wrkers rganisatins. Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in 13 PS2 is guided by a number f internatinal cnventins and instruments, including thse f the Internatinal Labur Organizatin and the United Natins. 14 PS2 applies t wrkers directly engaged by the client (direct wrkers), wrkers engaged thrugh third parties t perfrm wrk related t cre business prcesses 3 f the prject fr a substantial duratin (cntracted wrkers), as well as wrkers engaged by the client s primary suppliers (supply chain wrkers).

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 8 PS heading Para. Ref. Detail Review cmment Recmmendatin cnditins t nn-migrant wrkers carrying ut similar wrk. the number f immigrant / expatriate emplyees anticipated. N Labur and Human Resurces plicies and prcedures have yet been incrprated int the ESMS fr the prject in line with DRC legislatin and IFC requirements, nr have relevant rganisatins such as the Internatinal Labur Organisatin (ILO) been referred t. line with natinal law and PS2. This must clearly state that migrant wrkers are identified and engaged n substantially equivalent terms and cnditins t nn-migrant wrkers carrying ut similar wrk. 12 Where accmmdatin services are prvided t wrkers: Implement plicies n quality and management f accmmdatin and prvisin f basic services. Prvide services cnsistent with principles f nn-discriminatin and equal pprtunity. Allw wrkers freedm f mvement r assciatin. Wrkers rganisatins 13 Allw wrkers t develp alternative mechanisms t express their grievances and prtect their rights regarding wrking cnditins and terms f emplyment. Nn-discriminatin and equal pprtunities 14 D nt discurage, discriminate r retaliate against wrkers frm electing wrker representatives, frming r jining wrkers rganisatins, and frm cllective bargaining. Engage with wrkers representatives and wrkers rganisatins and prvide infrmatin needed fr negtiatin in a timely manner. 15 Adpt the principles f equal pprtunity and fair treatment with respect t emplyment relatinship. Take measures t prevent harassment, intimidatin and explitatin especially against wmen. Apply principles f nn-discriminatin t migrant wrkers. 16 Cmply with natinal law that requires nn-discriminatin r if law silent then cmply with PS2. 17 Measures t remedy past discriminatin r selectin are nt be deemed as discriminatin, if cnsistent with natinal law. Retrenchment 18 Analyse alternatives t retrenchment, prir t implementing cllective dismissals. Where retrenchment is unavidable, develp and implement a retrenchment plan t reduce the impacts f retrenchment n wrkers. Base the retrenchment plan n the principle f nndiscriminatin, cnsultatin undertaken with affected parties (wrkers, rganisatins and gvernment) and legal, cntractual and cllective bargaining requirements. 19 Prvide wrkers with ntice f dismissal and severance payments in a timely manner. Pay utstanding pay, benefits and cntributins n r befre terminatin, fr the benefit f the wrker r in accrdance with a cllective agreement. Prvide evidence f such payments t the wrkers. Grievance mechanism 20 Prvide a grievance mechanism fr wrkers t raise wrkplace cncerns. Infrm wrkers f the grievance mechanism when recruited and make it easily accessible. Address cncerns prmptly using a transparent prcess that prvides timely feedback, withut retributin. It will nt impede access t judicial r administrative remedies. Prtecting the wrk frce Child labur 21 Children will nt be emplyed in a manner that is ecnmically explitative, hazardus, interferes with their educatin, r harmful t health r their physical, mental, spiritual, mral r scial develpment. Cmply with natinal laws. Under 18s will nt be emplyed in hazardus wrk. Identify persns under the age f 18 and undertake an apprpriate risk assessment and regular mnitring f health, wrking cnditins and hurs f wrk. Frced labur 22 Frced labur will nt be emplyed, whether invluntary r cmpulsry. D nt emply trafficked persns. Occupatinal health and safety 23 Prvide a safe and healthy wrk envirnment that takes accunt f inherent risks and hazards and threats t wmen. Minimise the cause f hazards (as far as practicable) t prevent accidents, injury and disease. In line with GIIP, including WBG EHS Guidelines, The prject descriptin des nt prvide infrmatin n the number f wrkers per prject phase, nr the husing that is planned t accmmdate them. N Labur and Human Resurces plicies and prcedures have yet been incrprated int the ESMS fr the prject in line with DRC legislatin and IFC requirements, as well as relevant rganisatins such as the Internatinal Labur Organisatin (ILO). Nt applicable N Labur and Human Resurces plicies and prcedures have yet been put in place fr the prject. These will need t be aligned t the ESMS fr the prject in line with DRC legislatin and IFC requirements, as well as relevant rganisatins such as the Internatinal Labur Organisatin (ILO). A grievance mechanism fr wrkers has nt yet been tailred fr the prject. N Labur and Human Resurces plicies and prcedures have yet been put in place fr the prject. These will need t be aligned t the ESMS fr the prject in line with DRC legislatin and IFC requirements, as well as relevant rganisatins such as the Internatinal Labur Organisatin (ILO). N Occupatinal Health and Safety plicies and prcedures have yet been put in place fr the prject. These will need t be aligned t the ESMS fr the prject in line with DRC legislatin Prvide detailed infrmatin n accmmdatin requirements fr cnstructin and peratin phases, with designs f accmmdatin t cmply with IFC standards. This shuld be accmpanied by a plicy n the quality and management f accmmdatin in line with nndiscriminatin and equal pprtunity, as well as allwing freedm f mvement f wrkers. Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in line with natinal law and PS2. This shuld allw wrkers t develp alternative mechanisms t express their grievances and prtect their rights regarding wrking cnditins and terms f emplyment. Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in line with natinal law and PS2. This must clearly set ut respect f cllective bargaining with wrkers rganisatins. Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in line with natinal law and PS2. Put in place measures aimed at preventing harassment, intimidatin, explitatin and avidance f discriminatin. Nt applicable Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in line with natinal law and PS2. This must clearly set ut prcedures fr retrenchment based n nn-discriminatin, cnsultatin with affected parties, as well as cllective bargaining requirements. Ntice f dismissal and severance payments need t be cnducted in a timely manner, pay utstanding duly paid. Prir t cnstructin, set up a grievance prcedure requiring prmpt respnse is issues, t be addressed at the apprpriate level f management. Infrm wrkers abut the mechanism when they are recruited. Prir t cnstructin develp a Labur and Human Resurces Plan which sets ut plicies and prcedures fr the emplyment f wrkers in line with natinal law and PS2. This must clearly set ut measures fr prtectin f the wrkfrce t ensure cmpliance regarding emplyment f children and frced labur. Develp an Occupatinal Health and Safety Plan during the develpment f the updated ESIA. This will need t be aligned t the ESMS fr the prject, and will further need t be in accrdance with DRC legislatin

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 9 PS heading Para. Ref. Wrkers Engaged by Third Parties Supply Chain Detail Review cmment Recmmendatin address areas including: identificatin f ptential hazards t wrkers (especially life threatening); prvisin f prtective and preventive measures (mdificatin, substitutin/eliminatin f hazardus cnditins r substances); training f wrkers; dcumentatin and reprting f accidents, diseases and incidents; emergency preventin, preparedness and respnse arrangements. 24 Take cmmercially reasnable effrts t ensure third party emplyers are reputable and legitimate and have an apprpriate ESMS t allw them t perate in accrdance with the requirements f this PS (except paragraphs 18-19 and 27-29). 25 Establish plicies fr managing and mnitring the perfrmance f third party emplyers in accrdance with PS2 and where cmmercially reasnable, incrprate these in cntractual agreements. 26 Ensure that cntracted wrkers have access t a grievance mechanism, either prvided by the third party r by the cmpany. 27 Mnitr the primary supply chain t identify risks and incidents f child and frced labur and take steps t remedy them. 28 Intrduce prcedures and measures t ensure primary suppliers are taking steps t prevent r crrect life threatening situatins. 29 Where child/frced labur and significant safety risks cannt be remedied, shift the primary chain t suppliers that can demnstrate cmpliance with this PS. 3 PS3: Resurce Efficiency and Pllutin Preventin and IFC requirements, as well GIIP, including the WBG EHS Guidelines. Third party emplyers including security, hspitality management and cleaning service prviders will need t be reputable, and aligned t the PS s t include plicies and including labur and health and safety plicies, plans and prcedures. There is as yet n plicy fr the management and mnitring f the perfrmance f 3 rd party emplyers in accrdance with PS2. A grievance mechanism fr cntracted wrkers is nt yet in place since cnstructin has nt yet cmmenced. PPC Barnet will need t take steps t ensure that key suppliers such as hspitality management, security, lcal suppliers f cnstructin materials and ther service prviders d nt cntravene child and frced labur guidelines, r place their wrkers in life threatening situatins. Supplies received based n cnversin natural resurces such as fd, fibre and cnstructin materials shuld be cnsidered, as shuld the dispsal f wastes. and IFC requirements, as well GIIP, including the WBG EHS Guidelines. Prir t cmmencement f cnstructin, develp and implement a system fr review third party cntractrs t determine that they are wrking within the requirements f PS 2. Prir t cnstructin establish a plicy fr third party emplyer management and mnitring. Update cntracts as necessary when they cme up fr renewal. Ensure that this requirement is reflected in the verall Labur and Human Resurces plicy and plan. On cmmencement f cntracting f third parties, ensure a grievance prcedure is place t include prmpt respnse t be addressed at the apprpriate level f management (either within PPC Barnet r the third party cmpany). Infrm wrkers abut the mechanism when they are recruited. Prir t cnstructin, a prtcl will need t be put int place fr the checking f supply chains and service prviders, t include a mnitring prgramme t ensure cmpliance with PS2 and PS6. Mnitring f child and frced labur, as well as life threatening situatins, will need t frm an integral part f this prgramme. Steps t remedy and prevent issues will need t be implemented. Objectives Avid r minimize adverse impacts n human health and the envirnment by aviding r minimising pllutin frm prject activities; Prmte mre sustainable use f resurces, including energy and water; Reduce prject-related GHG emissins. General 4 During prject life-cycle: Resurce efficiency cnsider ambient cnditins, apply technically and financially feasible resurce efficiency and pllutin preventin principles, apply techniques best suited t avid r, where nt pssible, minimize adverse impacts n human health and the envirnment. Tailr principles and techniques t hazards and risks assciated with prject s nature and cnsistent with GIIP including WBG EHS Guidelines. 5 Refer t the EHS Guidelines r ther internatinally recgnized surces when evaluating and selecting resurce efficiency and pllutin preventin and cntrl techniques. Achieve whichever levels and measures is the mre stringent f hst cuntry regulatins and the EHS Guidelines. When less stringent levels are apprpriate, prvide justificatin fr perfrmance levels thrugh the ESIA prcess indicating that the chice is cnsistent with the bjectives f PS3. 6 Implement technically and financially feasible and cst effective measures fr imprving efficiency in cnsumptin (energy, water, and ther resurces and material inputs). If available, make cmparisn t establish relative level f efficiency. An EIA has been develped t meet DRC regulatry requirements and has received in-cuntry authrity apprval. Baseline studies were undertaken which prvided a brief utline f the existing envirnmental and scial cnditins. Gaps include the clear definitin f the study area, as well as baseline assessment f sufficient detail (t include air dispersin mdelling and surface and grundwater studies), znes f influence and detailed mitigatin measures t avid and minimize pllutin. Measures fr strage f tpsil is a further gap. Measures fr resurce efficiency and greenhuse gas emissin preventin and mitigatin have nt been prvided. N resurce efficiency measures are included in the EIA dcumentatin A prcess t update the ESIA shuld be undertaken t address gaps in the descriptin f the affected envirnment as described abve. Further, prcess water effluent needs t be clearly described, and means fr mitigatin and managing impacts need t be clearly defined. Dust mitigatin measures need t be clearly identified, in line with natinal regulatins and IFC guidelines. Pririty risks and impacts require substantial management attentin. This will require implementatin f detailed and cmprehensive mnitring and sampling activities (particularly fr grundwater quality, air quality and stack emissins, dust levels in the dry plant, water quality impacts frm the lack f sewage treatment). A waste management plan, pllutin preventin plan (t include management f strmwater), greenhuse gas management plan as well as resurce efficiency plan shuld be develped fr inclusin in the ESIA update. Incrprate resurce efficiency aspects int assessments and management prgrammes. A well as resurce efficiency plan shuld be develped fr inclusin in the ESIA update. The resurce efficiency plan shuld incrprate water and energy efficiency, as well as GHG

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 10 PS heading Para. Ref. Detail Review cmment Recmmendatin Greenhuse Gases 7 Cnsider alternatives and implement feasible ptins t reduce prject-related GHG emissins during design and peratin (including prject lcatins, renewable r lw carbn energy surces, agricultural, frestry and livestck management practices, reductin f fugitive emissins and gas flaring). 8 If expected t r prduce mre than 25,000 t CO2-equivalent annually, quantify direct emissins frm facilities wned r cntrlled within physical prject bundary and indirect emissins assciated with ff-site prductin f energy used. Cnduct emissins quantificatin annually in accrdance with internatinally recgnized methdlgies and gd practice. Water Cnsumptin 9 When a ptential significant water cnsumer, adpt measures that avid r reduce water usage t d nt have significant adverse impacts n thers (including use f additinal technically feasible water cnservatin measures, alternative water supplies, cnsumptin ffsets t reduce ttal demand and alternative prject lcatins). Pllutin Preventin 10 Avid release f pllutants r, when nt feasible, minimize and/r cntrl intensity and mass flw f release. Applies t air, water and land due t rutine, nn-rutine, accidental circumstances within lcal, reginal and transbundary impacts. Determine legal respnsibility fr histrical pllutin required t determine and reslved in accrdance with natinal law r GIIP. 11 Cnsider relevant factrs t address ptential adverse prject impacts n existing ambient cnditins: existing ambient cnditins; finite assimilative capacity f the envirnment; existing and future land use; prject s prximity t areas f imprtance t bidiversity; ptential fr cumulative impacts with uncertain and/r irreversible cnsequences. Cnsider additinal strategies and adpt measures that avid r reduce negative effects (including evaluatin f prject lcatin alternatives and emissins ffsets) when prject is a significatin surce f emissins in an already degraded area. Wastes 12 Avid generatin f hazardus and nn-hazardus waste materials. Where generatin cannt be avided, reduce, and recver and reuse in a manner safe fr human health and envirnment. Where waste cannt be recvered and reused, treat, destry r dispse theref in an envirnmentally sund manner (including apprpriate resulting emissins cntrl and residues). While sme cnsideratin has been given t GHG emissins in the EIA, mitigatin and management measures are nt prvided. Opprtunities d exist t develp renewable energy surces (e.g. slar) fr certain activities (e.g. camps and accmmdatin). Cprcessing shuld als be cnsidered. Key surces f GHG emissins need t be determined fr the prject, and pprtunities fr sequestratin investigated. The prject descriptin des nt prvide the vlumes f water required fr cement prductin, nr the vlumes which will be reuiqrd t meet sanitatin and drinking water needs. Further, infrmatin is nt rvided n the water surces t be used fr these purpses. N hydrlgical assessment has been cnducted t determine the impacts n the surface and grundwater systems. Further, n data gathering n existing water demands fr ther users been undertaken. Data frm the dry seasn/ wet seasn has als nt been btained. N detailed plan has been develped which sets ut water management prcedures and demand reductin has been develped. The EIA has incrprated the identificatin f ptential surces f pllutin. Hwever, n Waste Management Plan r Emergency Preparedness and Respnse Plan, r Pllutin Preventin Plan (t incrprate strmwater management) has been develped t date. Insufficient attentin has been paid in the EIA t the ptential fr nise pllutin, and t the develpment f a nise mnitring prgramme. N histrical pllutin has been identified n the site. These listed factrs are nt cnsidered sufficiently in existing dcumentatin. In particular the existing ambient cnditins require further mnitring and dcumentatin. The develpment is planned t take place in a greenfield site. The EIA des nt sufficiently address the need fr a waste management system, plan and prcedures t be put int place. This is f particular imprtance given the lack f waste management services within DRC assciated with apprpriately designed and lcated dispsal facilities. emissin reductin. Planning fr resurce efficiency (energy and water) wuld be beneficial frm bth a cst and envirnmental perfrmance perspective. The updated ESIA shuld include resurce efficiency in the envirnmental and scial management system. It shuld further have a resurce efficiency plan which shuld incrprate water and energy efficiency, as well as GHG emissin reductin (such as thrugh c-prcessing). As part f the prcess fr updating the ESIA, undertake a GHG inventry and identify ptins fr management. Incrprate findings int the resurce efficiency plan. The updated ESIA shuld incrprate cmprehensive hydrlgical baseline studies t incrprate bth wet and dry seasn assessments. This infrmatin shuld feed int the resurce efficiency plan which shuld incrprate water use efficiency. The plant shuld be designed t meet GIIP, in particular cnsidering the IFC EHS Guidelines and engineering standards. A detailed management prgramme fr pllutin preventin shuld be cmpiled and implemented, cvering water, air emissins and dustrelated impacts, as well as nise. A waste management plan, as well as emergency preparedness and respnse plan shuld als be develped. These plans shuld be incrprated int the updated ESIA. An apprpriately designed nise mnitring prgramme shuld be implemented fr the prject t cmply with wrkplace and ambient nise standards in line with natinal requirements (and where pertinent, Suth African Natinal Standards (SANS)). Undertake detailed liabilities audit and csting t ensure adequate financial prvisin is made fr legacy. Infrmatin is prvided abve n the gaps in the baseline and impact assessment sectins. Prcess water effluent needs t be clearly described, and means fr mitigatin and managing impacts need t be clearly defined. Dust mitigatin measures need t be clearly identified, in line with natinal regulatins and IFC guidelines. Pririty risks and impacts require substantial management attentin. This will require implementatin f detailed and cmprehensive mnitring and sampling activities (particularly fr grundwater quality, air quality and stack emissins, dust levels in the dry plant, water quality impacts frm the lack f sewage treatment). A waste management plan, pllutin preventin plan (t include management f strmwater), greenhuse gas management plan as well as resurce efficiency plan shuld be develped fr inclusin in the ESIA update. Cmpile plan fr emergency preparedness and respnse, waste management, ccupatinal health and safety, as well as cmmunity health and safety. This shuld further be accmpanied by a strmwater management plan and air quality management plan. These shuld set in place standards, perating prcedures and ther relevant implementatin details.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 11 PS heading Hazardus materials management Pesticide use and management Para. Ref. Detail Review cmment Recmmendatin If cnsidered hazardus, adpt GIIP alternatives fr its envirnmentally sund dispsal while adhering t the limitatins applicable t its transbundary mvement. When hazardus waste dispsal is cnducted by third parties cnduct dispsal, use reputable, legitimate cntractrs that are licensed by relevant gvernment agencies and btain chain f custdy dcumentatin t the final destinatin. Ascertain if licensed dispsal sites are being perated t acceptable standards. If nt, reduce waste sent t such sites and cnsider alternative dispsal ptins (including develping wn recvery r dispsal facilities at the prject site). 13 Avid r, when avidance is nt pssible, minimize and cntrl the release f hazardus materials; Assess prductin, transprtatin, handling, strage and use f hazardus materials; Cnsider using less hazardus substitutes in manufacturing prcesses r ther peratins; Avid manufacture, trade and use f chemicals and hazardus materials subject t internatinal bans r phase-uts due t high txicity t living rganisms, envirnmental persistence, ptential fr biaccumulatin r depletin f zne layer. 14 Frmulate and implement integrated pest management (IPM) and/r integrated vectr management (IVM) apprach targeting ecnmically significant pest infestatins and disease vectrs f public health significance. IPM and IVM prgram will integrate crdinated use f pest and envirnmental infrmatin alng with available pest cntrl methds (including cultural practices, bilgical, genetic and chemical means) t prevent ecnmically significant pest damage and/r disease transmissin t humans and animals. 15 Select chemical pesticides lw in human txicity, knwn t be effective against the target species and that have minimal effects n nn-target species and the envirnment and based upn requirements that pesticides: be packaged in safe cntainers; be clearly labelled fr safe and prper use; have been manufactured by an entity currently licensed by relevant regulatry agencies. 16 Design pesticide applicatin regime t: avid damage t natural enemies f the target pest r, where nt pssible, minimize; avid risks assciated with develpment f resistance in pests and vectrs r, where nt pssible, minimize; Pesticides will be handled, stred, applied and dispsed f in accrdance with Fd and Agriculture Organisatin s Internatinal Cde f Cnduct n the Distributin and Use f Pesticides r ther GIIP. 17 D nt purchase, stre, use, manufacture r trade in prducts that fall in WHO Recmmended Classificatin f Pesticides by Hazard: Class Ia (extremely hazardus) r Ib (highly hazardus); Class II (mderately hazardus) unless the prject has apprpriate cntrls n manufacture, prcurement r distributin and/r use f these chemicals. These chemicals shuld nt be accessible t persnnel withut prper training, equipment and facilities t handle, stre, apply and dispse f these prducts prperly. Hazardus materials t be used and generated n site and their respective vlumes are nt detailed in the EIA. Nt applicable at this stage Nt applicable at this stage Nt applicable at this stage Nt applicable at this stage The ESIA update shuld incrprate the identificatin f hazardus material t be used and generated n site, with estimates f the vlumes f substances invlved. Management measures shuld be included in the pllutin preventin plan. Nt applicable at this stage Nt applicable at this stage Nt applicable at this stage Nt applicable at this stage 15 16 4 PS4: Cmmunity health and safety, and security Objectives Anticipate and avid adverse impacts n the health and safety f the Affected Cmmunity during the prject life frm bth rutine and nn-rutine circumstances. Ensure that the safeguarding f persnnel and prperty is carried ut in accrdance with relevant human rights principles and in a manner that avids r minimizes risks t the Affected Cmmunities. 15 PS4 recgnizes that prject activities, equipment, and infrastructure can increase cmmunity expsure t risks and impacts. In additin, cmmunities that are already subjected t impacts frm climate change may als experience an acceleratin and/r intensificatin f impacts due t prject activities. While acknwledging the public authrities rle in prmting the health, safety, and security f the public, this Perfrmance Standard addresses the client s respnsibility t avid r minimize the risks and impacts t cmmunity health, safety, and security that may arise frm prject relatedactivities, with particular attentin t vulnerable grups. In cnflict and pst-cnflict areas, the level f risks and impacts described in this Perfrmance Standard may be greater. The risks that a prject culd exacerbate an already sensitive lcal situatin and stress scarce lcal resurces shuld nt be verlked as it may lead t further cnflict. 16 PS4 addresses ptential risks and impacts t the Affected Cmmunities frm prject activities. Occupatinal health and safety requirements fr wrkers are included in PS2, and envirnmental standards t avid r minimize impacts n human health and the envirnment due t pllutin are included in PS3.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 12 PS heading Para. Ref. Cmmunity health and safety Detail Review cmment Recmmendatin 5 Evaluate risks and impacts t health and safety f affected cmmunities during prject life cycle. Establish preventive measures cnsistent with GIIP, such as the WBG EHS Guidelines. Identify risks and impacts and prpse mitigatin measures. Measures will favur the avidance f risks and impacts ver minimizatin. Infrastructure and 6 Design, cnstruct, perate, and decmmissin the structural elements r cmpnents equipment design and f the prject in accrdance with GIIP, taking int cnsideratin safety risks t third safety parties r Affected Cmmunities. When new buildings and structures will be accessed by members f the public, cnsider incremental risks f the public s ptential expsure t peratinal accidents and/r natural hazards and be cnsistent with the principles f universal access. Structural elements will be designed and cnstructed by cmpetent prfessinals, and certified r apprved by cmpetent authrities r prfessinals. When structural elements r cmpnents, such as dams, tailings dams, r ash pnds are situated in high-risk lcatins, and their failure r malfunctin may threaten the safety f cmmunities, engage external experts with relevant and recgnized experience in similar prjects, separate frm thse respnsible fr the design and cnstructin, t cnduct a review as early as pssible in prject develpment and thrughut the stages f prject design, cnstructin, peratin, and decmmissining. Fr prjects that perate mving equipment n public rads and ther frms f infrastructure, seek t avid the ccurrence f incidents and injuries t members f the public assciated with the peratin f such equipment. Hazardus materials 7 Avid r minimise ptential fr public (wrkers and their families) expsure t management and hazardus materials and substances that may be released by the prject safety Where hazardus materials are part f existing prject infrastructure r cmpnents, the client will exercise special care when cnducting decmmissining activities in rder t avid expsure t the cmmunity. Exercise cmmercially reasnable effrts t cntrl the safety f deliveries, transprtatin and dispsal f hazardus materials and wastes. Implement measures t avid r cntrl expsure t pesticides in accrdance with PS3. Ecsystem services 17 8 Where apprpriate and feasible, identify risks and ptential impacts n pririty ecsystem services that may be exacerbated by climate change. Avid adverse impacts, and if these impacts are unavidable, implement mitigatin measures in accrdance with PS6, paragraphs 24 and 25. Implement mitigatin measures with respect t use f and lss f access t prvisining services in accrdance with PS5, paragraphs 25 29. Cmmunity expsure t disease Emergency Preparedness and Respnse 9 Avid r minimise ptential fr cmmunity expsure t water-brne, water-based, water-related, vectr-brne diseases and cmmunicable diseases that culd result frm prject activities, taking int cnsideratin differentiated expsure t and higher sensitivity f vulnerable grups. Where specific diseases are endemic in cmmunities in the prject area f influence, explre pprtunities during the prject life-cycle t imprve envirnmental cnditins that culd help minimize their incidence. 10 Avid r minimize transmissin f cmmunicable diseases that may be assciated with the influx f temprary r permanent prject labur. 11 In additin t PS1 emergency preparedness and respnse requirements, assist Affected Cmmunities, lcal gvernment agencies and ther relevant parties in preparatin t respnd effectively t emergency situatins especially when their participatin and cllabratin are necessary t respnd t such emergency situatins If lcal gvernment agencies have little r n capacity t respnd effectively, play an active rle in preparing and respnding t emergencies assciated with the prject. Dcument emergency preparedness, respnse activities, resurces and The EIA des nt cntain detailed baseline infrmatin n the health and safety f cmmunities affected during the prject life cycle. The ESIA des nt in sufficient detail prvide identify key risks t cmmunities, psed by such aspects as traffic, pen pits, strage f hazardus material and access t cnstructin and quarrying areas. The EIA des nt cntain detailed descriptin f the hazardus materials and estimated vlumes which are t be generated during the life cycle f the prject. The EIA des nt in sufficient detail determine impacts n ecsystem services, nr the mitigatin and management measures which shuld be implemented. Only limited infrmatin is prvided in the EIA n the ptential fr cmmunity expsure t diseases which culd result frm prject activities. There is, further, insufficient baseline infrmatin prvided n endemic diseases and vulnerable grups particularly affected by disease. Insufficient infrmatin is presented in the EIA regarding the ptential risks assciated with influx f wrkers. There are further n mitigatin measures which sufficiently address the ptential severity f the health risks invlved. The EIA des nt cntain detailed baseline infrmatin n the health and safety f cmmunities affected during the prject life cycle. It can be assumed that there is insufficient capacity amngst lcal gvernment agencies t deal with emergency situatins. The updated EISA shuld evaluate health and safety risks fr cmmunities resulting frm the prpsed develpment. Integrate management measures int the cmmunity health and safety plan, which shuld be reviewed n an annual basis. The cmmunity (sustainability) develpment plan shuld further integrate health develpment requirements. The updated EISA shuld evaluate health and safety risks fr cmmunities resulting frm the prpsed develpment during cnstructin and peratin. Integrate management measures int the cmmunity health and safety plan, which shuld be reviewed n an annual basis. The updated EISA shuld prvide a descriptin f the hazardus materials which may be evaluate health and safety risks fr cmmunities resulting frm the prpsed develpment during cnstructin and peratin. Integrate management measures int the cmmunity health and safety plan, the pllutin preventin plan and the waste management plan which shuld be reviewed n an annual basis. Measures fr the safe handling, strage and labelling f hazardus materials shuld be prvided. The updated EISA shuld prvide a mre cmprehensive descriptin f the ecsystem services baseline, and shuld determine the impacts n cmmunities as well as mitigatin measures. The updated EISA shuld evaluate health and safety risks fr cmmunities resulting frm the prpsed develpment. Integrate management measures int the cmmunity health and safety plan, which shuld be reviewed n an annual basis. The cmmunity (sustainability) develpment plan shuld further integrate health develpment requirements, in particular as this relates t disadvantaged and vulnerable grups. The updated EISA shuld evaluate health and safety risks fr cmmunities resulting frm the prpsed develpment. Integrate management measures int the cmmunity health and safety plan, which shuld be reviewed n an annual basis. The cmmunity (sustainability) develpment plan shuld further integrate health develpment requirements. The updated EISA shuld evaluate health and safety risks fr cmmunities resulting frm the prpsed develpment. Integrate management measures int the cmmunity health and safety plan, which shuld be reviewed n an annual basis. This shuld be develped in tandem and in alignment with the emergency preparedness and respnse plan which shuld dcument rles and respnsibilities. The plans shuld be disclsed as prat f the stakehlder engagement prcess fr the 17 With respect t PS4, ecsystem services are limited t prvisining and regulating services as defined in f PS6, paragraph 2.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 13 PS heading Security Persnnel Para. Ref. Detail Review cmment Recmmendatin respnsibilities. Disclse apprpriate infrmatin t affected cmmunities, gvernment agencies and relevant parties 12 When direct r cntracted wrkers are retained t prvide security t safeguard persnnel and prperty, assess risks psed by security arrangements t thse within and utside the prject site. Security arrangements shuld be guided by principles f prprtinality and GIIP 18 in relatin t hiring, rules f cnduct, training, equipping and mnitring f such wrkers, and by applicable law. Make reasnable inquiries t ensure thse prviding security are nt implicated in past abuses. Train security persnnel in the use f frce (and where applicable, firearms) and apprpriate cnduct tward wrkers and Affected Cmmunities and require them t act within applicable law. Sanctin use f frce nly when used fr preventive and defensive purpses in prprtin t the nature and extent f the threat. Prvide a grievance mechanism fr affected cmmunities t express cncerns abut security arrangements and acts f security persnnel. 13 Assess and dcument risks arising frm use f gvernment security persnnel deplyed t prvide security services. Ensure security persnnel act in a manner cnsistent with paragraph 12. Encurage public authrities t disclse security arrangements t the public, subject t verriding security cncerns. 14 Cnsider and where apprpriate investigate allegatins f unlawful r abusive acts f security persnnel. Take actin (r urge apprpriate parties t take actin) t prevent recurrence and reprt unlawful and abusive acts t public authrities. Owing t the early stage in prject develpment, security persnnel have nt as yet been appinted by PPC Barnet. PPC Barnet will need t take steps t ensure that key suppliers and their emplyees, including security prviders, d nt cntravene GIIP and cnduct themselves apprpriately. A grievance mechanism fr cmmunity members is nt yet in place. Nt applicable as far as is knwn Owing t the early stage in prject develpment, security persnnel have nt as yet been appinted by PPC Barnet and suitable prcedures regarding unlawful r abusive acts n their behalf are nt yet in place. updated ESIA. Prir t cnstructin, a prtcl will need t be put int place fr the checking f supply chains and service prviders, t include a mnitring prgramme t ensure cmpliance with PS2, PS4 and PS6. Steps t remedy and prevent issues will need t be implemented. PPC Barnet shuld ensure that security persnnel adhere t GIIP principles and in particular the Vluntary Principles n Security and Human Rights. The cmmunity grievance mechanism shuld be frmalised thrugh a cmpany prcedure, and the cmmunity infrmed f its existence. Nt applicable as far as is knwn Further t sectin 12 abve, ensure that a prcedure is n place t investigate incidences f unlawful r abusive acts f security persnnel. 5 PS5: Land Acquisitin and Invluntary Resettlement 19 Objectives T avid, and when avidance is nt pssible, minimize displacement by explring alternative prject designs. T avid frced evictin. T anticipate and avid, r where avidance is nt pssible, minimize adverse scial and ecnmic impacts frm land acquisitin r restrictins n land use by (i) prviding cmpensatin fr lss f assets at replacement csts 20 and (ii) ensuring that resettlement activities are implemented with apprpriate disclsure f infrmatin, cnsultatin, and the infrmed participatin f thse affected. T imprve, r restre, the livelihds and standards f living f displaced persns. T imprve living cnditins amng physically displaced persns thrugh the prvisin f adequate husing with security f tenure 21 at resettlement sites. Scpe f applicatin 5 PS5 applies t physical and/r ecnmic displacement resulting frm the fllwing types f land-related transactins: Based n the baseline studies already carried ut fr the EIA, physical displacement f cmmunities will nt result frm the develpment ftprint. Hwever, it has nt been clearly As part f the update f the ESIA, a detailed scial baseline fr the prject shuld be undertaken. The requirements set ut by PS5 shuld be applied fr prject activities where it affects peple s access t and 18 Including practice cnsistent with the United Natin s (UN) Cde f Cnduct fr Law Enfrcement Officials, and UN Basic Principles n the Use f Frce and Firearms by Law Enfrcement Officials. 19 PS5 recgnizes that prject-related land acquisitin and restrictins n land use can have adverse impacts n cmmunities and persns that use this land. Invluntary resettlement refers bth t physical displacement (relcatin r lss f shelter) and t ecnmic displacement (lss f assets r access t assets that leads t lss f incme surces r ther means f livelihd) as a result f prject-related land acquisitin and/r restrictins n land use. Resettlement is cnsidered invluntary when affected persns r cmmunities d nt have the right t refuse land acquisitin r restrictins n land use that result in physical r ecnmic displacement. This ccurs in cases f (i) lawful exprpriatin r temprary r permanent restrictins n land use and (ii) negtiated settlements in which the buyer can resrt t exprpriatin r impse legal restrictins n land use if negtiatins with the seller fail. Unless prperly managed, invluntary resettlement may result in lng-term hardship and impverishment fr the Affected Cmmunities and persns, as well as envirnmental damage and adverse sci-ecnmic impacts in areas t which they have been displaced. Fr these reasns, invluntary resettlement shuld be avided. Hwever, where invluntary resettlement is unavidable, it shuld be minimized and apprpriate measures t mitigate adverse impacts n displaced persns and hst cmmunities3 shuld be carefully planned and implemented. The gvernment ften plays a central rle in the land acquisitin and resettlement prcess, including the determinatin f cmpensatin, and is therefre an imprtant third party in many situatins. Experience demnstrates that the direct invlvement f the client in resettlement activities can result in mre cst-effective, efficient, and timely implementatin f thse activities, as well as in the intrductin f innvative appraches t imprving the livelihds f thse affected by resettlement. T help avid exprpriatin and eliminate the need t use gvernmental authrity t enfrce relcatin, clients are encuraged t use negtiated settlements meeting the requirements f this Perfrmance Standard, even if they have the legal means t acquire land withut the seller s cnsent. The term livelihd refers t the full range f means that individuals, families, and cmmunities utilize t make a living, such as wage-based incme, agriculture, fishing, fraging, ther natural resurce-based livelihds, petty trade, and bartering. Land acquisitin includes bth utright purchases f prperty and acquisitin f access rights, such as easements r rights f way. A hst cmmunity is any cmmunity receiving displaced persns. 20 Replacement cst is defined as the market value f the assets plus transactin csts. In applying this methd f valuatin, depreciatin f structures and assets shuld nt be taken int accunt. Market value is defined as the value required t allw Affected Cmmunities and persns t replace lst assets with assets f similar value. The valuatin methd fr determining replacement cst shuld be dcumented and included in applicable Resettlement and/r Livelihd Restratin plans (see paragraphs 18 and 25). 21 Security f tenure means that resettled individuals r cmmunities are resettled t a site that they can legally ccupy and where they are prtected frm the risk f evictin.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 14 PS heading General Para. Ref. Detail Review cmment Recmmendatin Land rights r land use rights acquired thrugh exprpriatin r ther cmpulsry prcedures in accrdance with the legal system f the hst cuntry; Land rights r land use rights acquired thrugh negtiated settlements with prperty wners r thse with legal rights t the land if failure t reach settlement wuld have resulted in exprpriatin r ther cmpulsry prcedures 22 ; Prject situatins where invluntary restrictins n land use and access t natural resurces cause a cmmunity r grups within a cmmunity t lse access t resurce usage where they have traditinal r recgnizable usage rights 23 ; Certain prject situatins requiring evictins f peple ccupying land withut frmal, traditinal, r recgnizable usage rights 24 ; r Restrictin n access t land r use f ther resurces including cmmunal prperty and natural resurces such as marine and aquatic resurces, timber and nn-timber frest prducts, freshwater, medicinal plants, hunting and gathering grunds and grazing and crpping areas 25. 6 PS5 des nt apply t resettlement resulting frm vluntary land transactins (i.e., market transactins in which the seller is nt bliged t sell and the buyer cannt resrt t exprpriatin r ther cmpulsry prcedures sanctined by the legal system f the hst cuntry if negtiatins fail). It als des nt apply t impacts n livelihds where the prject is nt changing the land use f the affected grups r cmmunities 26. 7 Where prject impacts n land, assets, r access t assets becme significantly adverse at any stage f the prject, the client shuld cnsider applying requirements f PS5, even where n land acquisitin r land use restrictin is invlved. Prject design 8 Cnsider feasible alternative prject designs t avid r minimise physical/ ecnmic displacement while balancing envirnmental, scial and financial csts and benefits paying attentin t impacts n the pr and vulnerable. Cmpensatin and benefits fr displaced persns Cmmunity engagement 9 When displacement cannt be avided, ffer displaced cmmunities and persn s cmpensatin fr lss f assets at full replacement cst 27 and ther assistance. Transparent and cnsistent cmpensatin standards t be ffered t all cmmunities and persns affected by the displacement. Where feasible 28 ffer thse whse livelihds are land based 29 and are displaced frm land, land-based cmpensatin. Pssessin f acquired land and related assets will take place nly after cmpensatin has been made available 30 and where applicable resettlement sites and mving allwances have been prvided in additin t cmpensatin 31. Prvide pprtunities t displaced cmmunities and persns t derive apprpriate develpment benefits frm the prject. 10 Engage with affected cmmunities, including hst cmmunities thrugh stakehlder engagement as described in PS1. Decisin making prcesses shuld include ptins and alternatives t resettlement and livelihd restratin where applicable. Disclsure f relevant infrmatin and participatin with cmmunities will cntinue during planning, implementatin, mnitring and evaluatin f cmpensatin established thrugh detailed scial baseline surveys whether r nt ecnmic displacement/ impact n livelihds might take place. There is n resettlement actin plan in place t deal with displacement. Nt applicable as far as is knwn The EIA indicates that n villages will be directly impacted by the prpsed develpment (i.e. nt physical displacement), althugh it still needs t be determined thrugh scial baseline survey whether r nt ecnmic displacement f vulnerable cmmunities will take place. The nature f the quarrying peratin makes it difficult t avid ecnmic displacement, but the lcatin f the cement prcessing plant may be able t mve, depending n envirnmental, scial and financial cst-benefit cnsideratins. Livelihd restratin planning fr affected individuals will be required shuld it nt be pssible t avid ecnmic displacement. N cmprehensive SEP has yet been develped fr the prject and wuld need t be in place prir t the cmmencement f livelihd restratin as applicable.. N indigenus peples are knwn t be living in the prject area. use f land. Shuld it be determined that this is required, a resettlement actin plan will then need t be undertaken. Nt applicable as far as is knwn Mnitring f the stakehlder engagement feedback and the grievance mechanism fr the lifetime f the prject will need t be undertaken. Need t apply the requirements f PS5 fr future prject activities may arise. As part f the update f the ESIA, undertake a detailed scial baseline fr the prject in accrdance with PS5. Shuld the prject design result in ecnmic displacement, alternative layuts must be cnsidered, based n envirnmental, scial and financial cnsideratins. Where ecnmic displacement cannt be avided, livelihd restratin planning will need t be undertaken. Ensure that the full replacement cst principle is applied and dcumented in cmpensatin activities. Develp a cmprehensive SEP which can frm the basis f engagement with affected cmmunities shuld it be determined that there will be ecnmic displacement frm the prject. Optins and alternatives fr cmpensatin shuld be explred with the affected individuals. A cmprehensive plan fr reslutin f the displacement shuld be develped t deal with the full life cycle f the cmpensatin prcess, 22 This als applies t custmary r traditinal rights recgnized r recgnizable under the laws f the hst cuntry. The negtiatins may be carried ut by the gvernment r by the cmpany (in sme circumstances, as an agent f the gvernment). 23 In such situatins, affected persns frequently d nt have frmal wnership. This may include freshwater and marine envirnments. PS5 may als apply when prject-related bidiversity areas r legally designated buffer znes are established but nt acquired by the client. 24 While sme peple d nt have rights ver the land they ccupy, this Perfrmance Standard requires that nn-land assets be retained, replaced, r cmpensated fr; relcatin take place with security f tenure; and lst livelihds be restred. 25 Natural resurce assets referred t in PS5 are equivalent t ecsystem prvisining services as described in Perfrmance Standard 6. 26 Mre generalized impacts n cmmunities r grups f peple are cvered in PS1. Fr example, disruptin f access t mineral depsits by artisanal miners is cvered by Perfrmance Standard 1. 27 As described in paragraphs 19 and 26. 28 Refer t paragraph 26 f this Perfrmance Standard fr further requirements. 29 The term land-based includes livelihd activities such as subsistence crpping and grazing f livestck as well as the harvesting f natural resurces. 30 In certain cases it may nt be feasible t pay cmpensatin t all thse affected befre taking pssessin f the land, fr example when the wnership f the land in questin is in dispute. Such circumstances shall be identified and agreed n a case-by-case basis, and cmpensatin funds shall be made available fr example thrugh depsit int an escrw accunt befre displacement takes place.. 31 Unless gvernment-managed resettlement is invlved and where the client has n direct influence ver the timing f cmpensatin payments. Such cases shuld be handled in accrdance with paragraphs 27 29 f this PS. Staggered cmpensatin payments may be made where ne-ff cash payments wuld demnstrably undermine scial and/r resettlement bjectives, r where there are nging impacts t livelihd activities.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 15 PS heading Para. Ref. Detail Review cmment Recmmendatin payments, livelihd restratin and resettlement t achieve utcmes cnsistent with the bjectives f PS5 32. Additinal prvisins apply t cnsultatins with Indigenus Peples, in accrdance with PS7. Grievance mechanism 11 Establish a grievance mechanism cnsistent with PS1 as early as pssible in the prject develpment phase The grievance mechanism must be designed t receive and address specific cncerns abut cmpensatin and relcatin raised by displaced persns r members f hst cmmunities in a timely fashin, including a recurse mechanism t reslve disputes impartially. Resettlement and livelihd restratin planning and implementatin Displacement 12 Where invluntary resettlement is unavidable, either as a result f a negtiated settlement r exprpriatin, carry ut a census t cllect apprpriate sci-ecnmic baseline data t identify persns wh will be displaced and determine wh will be eligible fr cmpensatin and assistance33 and discurage ineligible persns, such as pprtunistic settlers. In the absence f hst gvernment prcedures, establish a cut ff date fr eligibility. Dcument and disseminate infrmatin abut the cut-ff date thrughut the prject area. 13 In cases where affected persns reject cmpensatin ffers that meet the requirements f this PS and, as a result, exprpriatin r ther legal prcedures are initiated, explre pprtunities t cllabrate with respnsible gvernment agencies and if permitted play an active rle in resettlement actin planning, implementatin and mnitring ( refer t 30 32). 14 Establish prcedures t mnitr and evaluate the implementatin f a RAP r livelihd restratin plan (LRP) (see paragraphs19-25) and take crrective actin as necessary. Retain cmpetent resettlement prfessinals t prvide advice n PS cmpliance and t verify the client s mnitring infrmatin fr prjects with significant invluntary resettlement. Persns will be cnsulted during the mnitring prcess. 15 Implementatin f RAP r LRP cnsidered cmplete when adverse impacts have been addressed in a manner cnsistent with the relevant plan as well as the bjectives f this PS. Cmmissin an external cmpletin audit f the RAP and LRP if necessary (depending n scale and cmplexity f physical and ecnmic displacement). The cmpletin audit shuld be undertaken nce all mitigatin measures have been substantially cmpleted and nce displaced persns are deemed t have been prvided adequate pprtunity and assistance t sustainably restre their livelihds. The cmpletin audit will be undertaken by cmpetent resettlement prfessinals nce the agreed mnitring perid is cncluded. The cmpletin audit will include, at a minimum, a review f the ttality f mitigatin measures implemented, a cmparisn f implementatin utcmes against agreed bjectives, and a cnclusin as t whether the mnitring prcess can be ended 34. 16 Develp a resettlement and/r livelihd restratin framewrk utlining principles cmpatible with this PS where the exact nature r magnitude is unknwn due t the stage f prject develpment. Once the individual prject cmpnents are defined and the necessary infrmatin becmes available, such a framewrk will be expanded int a specific RAP r LRP and prcedures in accrdance with paragraphs 19 and 25. PPC Barnet will need t have a grievance mechanism as part f the SEP in accrdance with PS1. This will need t include a rbust system t capture issues related t cmpensatin and t respnd t disputes, t include a register f issues/cmplaints and hw they were addressed. The register shuld be in hard and electrnic cpy, with clear dates when the cmplaint was fllwed up and clsed ut. It must be easy t determine whether the cmplaints were addressed timeusly r nt. The EIA cntains sme basic baseline sciecnmic infrmatin fr the prject are but this needs t be expanded n t ensure that there is cmprehensive understanding f the ptential impacts f the prject. The infrmatin needs t be disclsed as part f the stakehlder engagement prcess, and a cut-ff date fr eligibility determined. If it is determined that ecnmic displacement will need t ccur, a livelihd restratin plan will been t be develped, negtiated and disclsed. Shuld this be rejected, the relevant authrity respnsible fr exprpriatin and cmpensatin prcess will need t be identified by PPC. Shuld this be fund t be applicable, PPC will need t prvide assistance t restre incme and livelihd based n the preprject baseline. The EIA des nt refer t livelihd restratin and the requirement fr this has nt yet been determined. The EIA des nt refer t livelihd restratin and the requirement fr this has nt yet been determined. 17 Displaced persns may be classified as persns wh: A census has nt yet been undertaken t determine displaced persns. This may nt be relevant except with regards t including review.. Develp a SEP t incrprate a grievance mechanism and make it knwn t the cmmunity. The system fr registering and addressing cmplaints shuld be included n PPC Barnet s cmputer netwrk. This will ensure easy access t this infrmatin by relevant senir mine persnnel. A set timeframe shuld be placed n addressing issues/cmplaints nce they are registered, and prject persnnel shuld reprt n perfrmance n a regular basis. A sci-ecnmic census shuld be cnducted f apprpriate baseline data t determine ecnmic displacement frm the prject. A husehld survey shuld als be cnducted and the findings reprted n as part f the stakehlder engagement prcess. A cmprehensive plan fr reslutin f the displacement shuld be develped t deal with the full life cycle f the cmpensatin prcess, including review. Develp a livelihd restratin plan as part f the ESIA updating prcess, as relevant (fllwing detailed scial baseline assessment). Ensure that prcedures fr livelihd restratin mnitring are prepared and align with PS5 guidelines. Identify and retain cmpetent resettlement prfessinals t prvide advice n PS cmpliance and t verify the client s mnitring infrmatin fr prjects with significant invluntary resettlement. Develp a livelihd restratin plan as part f the ESIA updating prcess, as relevant (fllwing detailed scial baseline assessment). Ensure that prcedures fr livelihd restratin mnitring are prepared and align with PS5 guidelines. Develp a livelihd restratin plan as part f the ESIA updating prcess, as relevant (fllwing detailed scial baseline assessment). Ensure that prcedures fr livelihd restratin mnitring are prepared and align with PS5 guidelines. PPC will need t ensure that all prject affected persns (PAPS) 32 The cnsultatin prcess shuld ensure that wmen s perspectives are btained and their interests factred int all aspects f resettlement planning and implementatin. Addressing livelihd impacts may require intra-husehld analysis in cases where wmen s and men s livelihds are affected differently. Wmen s and men s preferences in terms f cmpensatin mechanisms, such as cmpensatin in kind rather than in cash, shuld be explred. 33 Dcumentatin f wnership r ccupancy and cmpensatin arrangements shuld be issued in the names f bth spuses r heads f husehlds, and ther resettlement assistance, such as skills training, access t credit, and jb pprtunities, shuld be equally available t wmen and adapted t their needs. Where natinal law and tenure systems d nt recgnize the rights f wmen t hld r cntract in prperty, measures shuld be cnsidered t prvide wmen as much prtectin as pssible with the bjective t achieve equity with men. 34 The cmpletin audit f the Resettlement Actin Plan and/r Livelihd Restratin Plan, will be undertaken by external resettlement experts nce the agreed mnitring perid is cncluded, and will invlve a mre in-depth assessment than regular resettlement mnitring activities, including at a minimum a review f all mitigatin measures with respect t the physical and/r ecnmic displacement implemented by the Client, a cmparisn f implementatin utcmes against agreed bjectives, a cnclusin as t whether the mnitring prcess can be ended and, where necessary, a Crrective Actin Plan listing utstanding actins necessary t meet the bjectives.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 16 PS heading Para. Ref. Detail Review cmment Recmmendatin have frmal legal rights t the land r assets they ccupy r use; d nt have frmal legal rights t land r assets, but have a claim t land that is recgnized r recgnizable under natinal law; r have n recgnizable legal right r claim t the land r assets they ccupy r use. The census will establish the status f the displaced persns. 18 Prject-related land acquisitin and/r restrictins n land use may result in the physical displacement f peple as well as their ecnmic displacement. Cnsequently, requirements f this PS in respect f physical displacement and ecnmic displacement may apply simultaneusly. Physical displacement 19 In the case f physical displacement develp a RAP that cvers at minimum the applicable requirements f this PS regardless f number f peple affected. The plan will be designed t mitigate the negative impacts f displacement; identify develpment pprtunities; develp a resettlement budget and schedule; and establish the entitlements f all categries f affected persns (including hst cmmunities). Particular attentin will be paid t the needs f the pr and the vulnerable. All transactins t acquire land rights, as well as cmpensatin measures and relcatin activities will be dcumented. 20 Offer thse wh have t mve t anther lcatin feasible resettlement ptins, including adequate replacement husing r cash cmpensatin where apprpriate; and prvide relcatin assistance suited t the needs f each grup f displaced persns. New resettlement sites built fr displaced persns must ffer imprved living cnditins. The displaced persns preferences with respect t relcating in pre-existing cmmunities and grups will be taken int cnsideratin. Existing scial and cultural institutins f the displaced persns and any hst cmmunities will be respected. 21 In the case f physically displaced persns under paragraph 17, ffer chice f replacement prperty f equal r higher value, security f tenure, equivalent r better characteristics and advantages f lcatin r cash where apprpriate. Cmpensatin in kind shuld be cnsidered in lieu f cash. 22 In the case f physically displaced persns (paragraph 17), ffer them a chice f ptins fr adequate husing with security f tenure s that they can resettle legally withut facing the risk f frced evictin. Where displaced persns wn and ccupy structures, cmpensate them fr the lss f assets ther than land, such as dwellings and ther imprvements f the land at full replacement cst, prvided these persns have been ccupying the prject area prir t the cut-ff date fr eligibility. Based n cnsultant with such displaced persns, prvide relcatin assistance sufficient fr them t restre their standard f living at an adequate alternative site 35. 23 Nt required t cmpensate r assist thse wh encrach n the prject area after the cut-ff date fr eligibility, prvided the cut-ff date has been clearly established and made public. 24 Frced evictins 36 will nt be carried ut except in accrdance with the law and the requirements f the this PS. Ecnmic 25 In the case f prjects invlving ecnmic displacement nly, develp a LRP t Displacement cmpensate affected persns and/r cmmunities and ffer ther assistance that meets the bjectives f this PS. The LRP will establish the entitlements f affected persns and/r cmmunities and will ensure that these are prvided in a transparent, cnsistent, and equitable manner. The mitigatin f ecnmic displacement will be cnsidered cmplete when affected ecnmic displacement, such as crps displaced by the develpment ftprint. The EIA indicates that n villages will be directly impacted by the prpsed develpment (i.e. nt physical displacement), althugh it still needs t be determined thrugh scial baseline survey whether r nt ecnmic displacement f vulnerable cmmunities will take place. The nature f the quarrying peratin makes it difficult t avid ecnmic displacement, but the lcatin f the cement prcessing plant may be able t mve, depending n envirnmental, scial and financial cst-benefit cnsideratins. Livelihd restratin planning fr affected individuals will be required shuld it nt be pssible t avid ecnmic displacement. Nt applicable based n available infrmatin Ecnmic displacement is nt prperly addressed in the EIA. Shuld this be fund t be applicable, PPC will need t develp a livelihd restratin plan prvide assistance t restre incme and livelihd based n the pre-prject baseline. (ecnmic displacement) are identified, as relevant.. As part f the update f the ESIA, undertake a detailed scial baseline fr the prject in accrdance with PS5. Shuld the prject design result in ecnmic displacement, alternative layuts must be cnsidered, based n envirnmental, scial and financial cnsideratins. Where ecnmic displacement cannt be avided, livelihd restratin planning will need t be undertaken. Ensure that the full replacement cst principle is applied and dcumented in cmpensatin activities. Nt applicable based n available infrmatin Develp a livelihd restratin plan as part f the ESIA updating prcess, as relevant (fllwing detailed scial baseline assessment). Ensure that prcedures fr livelihd restratin mnitring are prepared and align with PS5 guidelines. Identify and retain cmpetent resettlement prfessinals t prvide advice n PS cmpliance and t verify the client s mnitring, and t determine wither adequate pprtunity fr re- 35 Relcatin f infrmal settlers in urban areas may invlve trade-ffs. Fr example relcated families may gain security f tenure but they may lse the advantages f lcatin. Changes in lcatin that may be affect livelihd pprtunities shuld be addressed in accrdance with the principles f this PS (in particular Paragraph 25) 36 The permanent r temprary remval against the will f individuals, families and/r cmmunities frm the hmes and/r lands which they ccupy with the prvisin f and acc t apprpriate frms f legal and ther prtectin.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 17 PS heading Para. Ref. Detail Review cmment Recmmendatin persns r cmmunities have received cmpensatin and ther assistance accrding t the requirements f the LRP and this PS, and are deemed t have been prvided with adequate pprtunity t re-establish their livelihds. 26 If land acquisitin r restrictins n land use result in ecnmic displacement defined as lss f assets and/r means f livelihd, regardless f whether r nt the affected peple are physically displaced, the client will meet the requirements in paragraphs 27 29, as applicable. 27 Ecnmically displaced persns wh face lss f assets r access t assets will be cmpensated fr such lss at full replacement cst. In cases where land acquisitin r restrictins n land use affect cmmercial structures, affected business wners will be cmpensated fr the cst f reestablishing cmmercial activities elsewhere, fr lst net incme during the perid f transitin, and fr the csts f the transfer and reinstallatin f the plant, machinery, r ther equipment. In cases affecting persns with legal rights r claims t land which are recgnized r recgnizable under natinal law (see paragraph 17 (i) and (ii)), replacement prperty (e.g., agricultural r cmmercial sites) f equal r greater value will be prvided, r, where apprpriate, cash cmpensatin at full replacement cst. Ecnmically displaced persns wh are withut legally recgnizable claims t land (see paragraph 17 (iii)) will be cmpensated fr lst assets ther than land (such as crps, irrigatin infrastructure and ther imprvements made t the land), at full replacement cst. The client is nt required t cmpensate r assist pprtunistic settlers wh encrach n the prject area after the cut-ff date fr eligibility. 28 In additin t cmpensatin fr lst assets, if any, as required under paragraph 27, ecnmically displaced persns whse livelihds r incme levels are adversely affected will als be prvided pprtunities t imprve, r at least restre, their means f incmeearning capacity, prductin levels, and standards f living: Fr persns whse livelihds are land-based, replacement land that has a cmbinatin f prductive ptential, lcatinal advantages, and ther factrs at least equivalent t that being lst shuld be ffered as a matter f pririty. Fr persns whse livelihds are natural resurce-based and where prject-related restrictins n access envisaged in paragraph 5 apply, implementatin f measures will be made t either allw cntinued access t affected resurces r prvide access t alternative resurces with equivalent livelihd-earning ptential and accessibility. Where apprpriate, benefits and cmpensatin assciated with natural resurce usage may be cllective in nature rather than directly riented twards individuals r husehlds. If circumstances prevent the client frm prviding land r similar resurces as described abve, alternative incme earning pprtunities may be prvided, such as credit facilities, training, cash, r emplyment pprtunities. Cash cmpensatin alne, hwever, is frequently insufficient t restre livelihds. 29 Transitinal supprt shuld be prvided as necessary t all ecnmically displaced persns, based n a reasnable estimate f the time required t restre their incmeearning capacity, prductin levels, and standards f living. Private sectr respnsibilities under gvernment managed resettlement 30 Where land acquisitin and resettlement are the respnsibility f the gvernment, cllabrate with respnsible gvernment agency t the extent permitted by the agency, t achieve utcmes that are cnsistent with this PS. In additin, where gvernment capacity is limited, play an active rle during resettlement planning, implementatin, and mnitring, as described belw. It is SRK s understanding that paragraphs 27-29 apply t the prject. A census f crps, identificatin f relevant farmer/ family, extent and type f crp t be affected by the develpment ftprint is nt yet in place. Prcedures fr cmpensatin have nt yet been develped. Nt applicable based n available infrmatin It is assumed that land acquisitin will nt be required fr this prject, unless it is decided that alternative cultivatin areas fr crps displaced by the develped ftprint are required. establishment has been prvided. Ensure that the prcess is transparent, cnsistent and equitable, Implement paragraphs 27-29 PPC needs t review the gvernment cmpensatin framewrk t understand alignment with PS5. A census f crps, t include identificatin f relevant farmer/ family, extent and type f crps t be affected by the develpment ftprint needs t be undertaken. Prcedures fr cmpensatin will need t be specified in a livelihds restratin plan. Ensure that transitinal supprt is prvided t prject affected persns. Nt applicable based n available infrmatin This may need t be reviewed based n the utcmes f the livelihd restratin prcess. 31 In the case f acquisitin f land rights r access t land thrugh cmpulsry means r negtiated settlements invlving physical displacement, identify and describe 37 gvernment resettlement measures. If these measures d nt meet the relevant requirements f this Perfrmance Standard prepare a supplemental resettlement plan that tgether with the dcuments prepared by the respnsible gvernment agency, will address the relevant requirements f this PS (see General Requirements and requirements fr Physical Displacement and Ecnmic Displacement). Nt applicable based n available infrmatin Nt applicable based n available infrmatin 37 Gvernment dcuments, where available, may be used t identify such measures

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 18 PS heading Para. Ref. Detail Review cmment Recmmendatin Supplemental Resettlement Plan, must include at a minimum (i) identificatin f affected peple and impacts; (ii) a descriptin f regulated activities, including the entitlements f displaced persns prvided under applicable natinal laws and regulatins; (iii) the supplemental measures t achieve the requirements f this Perfrmance Standard as described in paragraphs 19 29 in a way that is permitted by the respnsible agency and implementatin time schedule; and (iv) the financial and implementatin respnsibilities f the client in the executin f its Supplemental Resettlement Plan. 32 In the case f prjects invlving ecnmic displacement nly, identify and describe the measures that the respnsible gvernment agency plans t use t cmpensate affected cmmunities and persns. If these measures d nt meet the relevant requirements f this PS develp an Envirnmental and Scial Actin Plan t cmplement gvernment actin. This may include additinal cmpensatin fr lst assets, and additinal effrts t restre lst livelihds where applicable. Review will need t be undertaken f the gvernment cmpensatin framewrk t evaluate alignment with PS5. PPC t review gvernment cmpensatin framewrk t evaluate alignment with PS5. 6 PS 6: Bidiversity Cnservatin and Sustainable Management f Living Natural Resurces Objectives Prtect and cnserve bidiversity; Maintain the benefits frm ecsystem services 38 ; Prmte the sustainable management f living natural resurces. General 6 In the risks and impacts identificatin prcess (PS1) cnsider direct and indirect prjectrelated impacts n bidiversity and ecsystem services and identify significant residual impacts. The prcess shuld cnsider: Prtectin and cnservatin f bidiversity threats t bidiversity and ecsystems services fcus habitat lss, degradatin and fragmentatin, invasive alien species, verexplitatin, hydrlgical changes, nutrient lading, and pllutin ; the differing values attached t bidiversity and ecsystem services by Affected Cmmunities and ther stakehlders. 7 Avid impacts n bidiversity and ecsystem services. When nt pssible, implement measures t minimize impacts and restre bidiversity and ecsystem services. Adpt a practice f adaptive management in which the implementatin f mitigatin and management measures are respnsive t changing cnditins and the results f mnitring thrughut the prject s lifecycle. 8 Where the prject may cause risks r impacts t natural habitats, retain cmpetent prfessinals t assist with cnducting the risk and impact identificatin prcess in natural habitats. Where the prject may cause risks r impacts t critical habitat, retain external experts with apprpriate reginal experience t assist in the develpment f a mitigatin hierarchy that cmplies with PS6 and t verify the implementatin f thse measures. 9 Habitat is defined as a terrestrial, freshwater, r marine gegraphical unit r airway that supprts assemblages f living rganisms and their interactins with the nn-living envirnment. PS6 divides these int mdified, natural, and critical habitats which are a subset f mdified r natural habitats. 10 Cnsider bidiversity ffsets nly after apprpriate measures t avid, minimise and restre bidiversity have been applied. Design and implement bidiversity ffsets t achieve measurable cnservatin utcmes, resulting in n let lss and preferably a net A baseline descriptin f the bidiversity f the prject area is prvided in the EIA, and ptential impacts as well as mitigatin measures are prvided. Hwever, the EIA des nt prvide a sufficiently clear definitin f the study area/ zne f influence. Assessment ver a dry and wet seasn has nt been undertaken. While sme infrmatin has been prvided n the use by lcal cmmunities f ecsystem services, this infrmatin is nt prvided in sufficient detail. A cmprehensive ESMS has nt yet been develped fr the prject. An effective system fr mnitring f implementatin f mitigatin and management measures has nt yet been dcumented. Details f a specialist eclgist prviding input t the study are nt prvided in the EIA. Habitat classificatin cvering mdified, natural r critical, is nt prvided in the EIA. The site is predminantly natural, but has been mdified ver time by the presence f peple practising subsistence agriculture, and making use f ecsystem services such as cllecting f wd. N ffsets have been cnsidered, as part f the EIA. This apprach shuld be reviewed as part f the update t the EISA. Revise the baseline impact assessment and management plans t cver bidiversity and ecsystem services in sufficient detail. PPC shuld appint a sustainability manager t versee the implementatin f mitigatin and management measures. This shuld include the management f the implementatin f the mnitring system t ensure that bidiversity impacts are cnsidered ut the life f the prject. During the updating f the ESIA, lcal specialist expertise shuld be included as the prject team t ensure that the key bidiversity issues have been identified, and that the mitigatin measures are sufficiently cmprehensive. The updated ESIA shuld expand n the classificatin f the bidiversity present in the prject area Cnsider bidiversity ffsets during the updating f the ESIA. 38 Ecsystem services are the benefits that peple, including businesses, derive frm ecsystems. Ecsystem services are rganized int fur types: (i) prvisining services, which are the prducts peple btain frm ecsystems; (ii) regulating services, which are the benefits peple btain frm the regulatin f ecsystem prcesses; (iii) cultural services, which are the nnmaterial benefits peple btain frm ecsystems; and (iv) supprting services, which are the natural prcesses that maintain the ther services.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 19 PS heading Para. Ref. Detail Review cmment Recmmendatin gain f bidiversity (and net gain is required in critical habitats). Ensure bidiversity ffsets are designed t cnserve the same bidiversity values 39 (r better) that are being impacted. Retain apprpriate external experts fr design and implementatin f ffsets. Mdified habitat 11 Mdified habitats 40 may cntain a large prprtin f plant and/r animal species f nnnative rigin, and/r where human activity has substantially mdified an area s primary eclgical functins and species cmpsitin. 12 When mdified habitat areas include significant bidiversity value, minimise impacts n areas f mdified habitat that include significant bidiversity value and implement mitigatin measures as apprpriate. Nt applicable t the prject It remains t be verified whether areas f significant bidiversity value are present in the prject area Nt applicable t the prject Determine during the updating f the EIA whether areas f significant bidiversity are present Natural habitat 13 Natural habitats are areas cmpsed f viable assemblages f plant and/r animal species f largely native rigin, and/r where human activity has nt essentially mdified an area s primary eclgical functins and species cmpsitin. 14 Ensure n significant cnversin r degradatin f natural habitats, unless the fllwing cnditins are met: there are n viable alternatives within the regin; the views f stakehlders with respect t the extent f cnversin and degradatin have been established; any cnversin r degradatin is mitigated accrding t the mitigatin hierarchy. 15 Design mitigatin measures t achieve n net lss 41 f bidiversity (where feasible) by: Aviding impacts n bidiversity thrugh the identificatin and prtectin f set-asides; Implementing measures t minimize habitat fragmentatin, such as bilgical crridrs; Restring habitats during peratins and/r after peratins; Implementing bidiversity ffsets. Critical habitat 16 Critical habitats are areas with high bidiversity value, including: habitat f significant imprtance t Critically Endangered and/r Endangered species; habitat f significant imprtance t endemic and/r restricted-range species; habitat supprting glbally significant cncentratins f migratry species and/r cngregatry species; highly threatened and/r unique ecsystems; and/r areas assciated with key evlutinary prcesses. 17 Ensure prject activities are nt implemented in areas f critical habitat unless the fllwing cnditins are met: there are n viable alternative lcatins within the regin; there will be n measurable adverse impacts n the bidiversity values fr which the critical habitat was designated r the eclgical prcess supprting thse bidiversity values; there will be n net reductin in the glbal and/r natinal/reginal ppulatin f critically endangered r endangered species ver a reasnable perid f time; a lng-term bidiversity mnitring and evaluatin prgram is designed and integrated int the verall management prgramme. 18 If the requirements abve are met, describe mitigatin strategies within a Bidiversity Actin Plan that is designed t achieve net gains 42 f the bidiversity values fr which the critical habitat was designated. The site is predminantly natural, but has been mdified ver time by the presence f peple practising subsistence agriculture, and making use f ecsystem services such as cllecting f wd. These principles have nt been cnsidered in the EIA t date. These principles have nt been cnsidered in the EIA t date. It remains t be verified whether areas f significant bidiversity value are present in the prject area It remains t be verified whether areas f significant bidiversity value are present in the prject area It remains t be verified whether areas f significant bidiversity value are present in the prject area Address these principles during the updating f the ESIA Address these principles during the updating f the ESIA Determine during the updating f the EIA whether areas f significant bidiversity are present Determine during the updating f the ESIA whether areas f significant bidiversity/ critical habitat are present. Determine during the updating f the ESIA whether areas f significant bidiversity/ critical habitat are present. 39 The principle f like-fr-like r better 40 Mdified habitats may include areas managed fr agriculture, frest plantatins, reclaimed castal znes, and reclaimed wetlands. 41 N net lss is defined as the pint at which prject-related impacts n bidiversity are balanced by measures taken t avid and minimize the prject s impacts, t undertake n-site restratin and finally t ffset significant residual impacts, if any, n an apprpriate gegraphic scale (e.g., lcal, landscape-level, natinal, reginal). 42 Net gains are additinal cnservatin utcmes that can be achieved fr the bidiversity values fr which the critical habitat was designated. Net gains may be achieved thrugh the develpment f a bidiversity ffset and/r, in instances where the client culd meet the requirements f paragraph 17 withut a bidiversity ffset, the client shuld achieve net gains thrugh the implementatin f prgrams that culd be implemented in situ (n-the-grund) t enhance habitat, and prtect and cnserve bidiversity.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 20 PS heading Para. Ref. Detail Review cmment Recmmendatin 19 Where ffsets are prpsed, demnstrate that the significant residual impacts n bidiversity will be adequately mitigated t meet the requirements f paragraph 17. It remains t be verified whether areas f significant bidiversity value are present in the prject area Determine during the updating f the ESIA whether areas f significant bidiversity are present. Legally prtected and internatinally recgnised areas 20 Where prject falls in legally prtected and internatinally recgnised areas - cmply with the requirements fr natural and critical habitats and in additin: demnstrate that the prpsed develpment is legally permitted in such areas; cmply with any gvernment recgnized management plans fr such areas; cnsult prtected area spnsrs and managers, Affected Cmmunities, Indigenus Peples and ther stakehlders, as apprpriate; implement additinal prgrammes t prmte and enhance the cnservatin aims and effective management f the area. Alien invasive species 21 Intentinal r accidental intrductin f alien, r nn-native, species f flra and fauna int areas where they are nt nrmally fund can be a significant threat t bidiversity, since sme alien species can becme invasive, spreading rapidly and ut-cmpeting native species. Management f Ecsystem Services 22 Ensure there is n intentinal intrductin f alien species, unless this is carried ut in accrdance with the existing regulatry framewrk fr such intrductin r is subject t a risk assessment. Implement measures t avid accidental r unintended intrductins. 23 Exercise diligence in nt spreading established alien species int areas in which they are nt already established. Take measures, where practicable, t eradicate such species frm natural habitats ver which there is management cntrl. 24 Cnduct a systematic review t identify pririty ecsystem services which are: thse which prject peratins are mst likely t impact and which result in adverse impacts t Affected Cmmunities; thse that the prject is directly dependent upn fr its peratins. Affected Cmmunities must be cnsulted t determine pririty ecsystem services. 25 Avid adverse impacts n pririty ecsystem services f relevance t Affected Cmmunities, where there is direct management cntrl r significant influence ver these services. Where unavidable, minimise impacts and implement measures t maintain the value and functinality f pririty ecsystem services. Sustainable Management f Living Natural Resurces Only relevant t primary prductin f living natural resurces, including natural and plantatin frestry, agriculture, animal husbandry, aquaculture, and fisheries Supply chain With respect t impacts n pririty ecsystem services n which the prject depends, minimize impacts n ecsystem services and implement measures that increase resurce efficiency f prject peratins (PS3). Additinal prvisins fr ecsystem services are included in PS4, paragraph 8; PS5, paragraphs 5 and 25 29; PS 7, paragraphs 13 17 and 20; and PS8, paragraph 11. 26 Lcate land-based agribusiness and frestry prjects n unfrested land r land already cnverted. Implement sustainable management practices t ne r mre relevant and credible standards as demnstrated by independent verificatin r certificatin. 27 Credible glbally, reginally, r natinally recgnized standards fr sustainable management f living natural resurces are thse which: are bjective and achievable; are funded n a multi-stakehlder cnsultative prcess; encurage step-wise and cntinual imprvements; prvide fr independent verificatin r certificatin thrugh apprpriate accredited bdies fr such standards. 28 Cnduct a pre-assessment f cnfrmity with applicable standards (if verificatin has nt yet been btained) and take actins t achieve verificatin r certificatin ver an apprpriate perid f time. 29 In the absence f relevant standards, cmmit t applying gd internatinal industry perating principles, management practices and technlgies; and actively engage and supprt the develpment f a natinal standard. Nt applicable t the prject The EIA des nt address the issue f alien invasive species. The prject presents a risk f resulting in the intrductin f alien invasive species. Nt applicable t the prject The EIA des nt cntain measures fr the preventin f spread f alien invasive species. The EIA des nt in sufficient detail determine impacts n ecsystem services, nr the mitigatin and management measures which shuld be implemented. Nt applicable t the prject Nt applicable t the prject Nt applicable t the prject Nt applicable t the prject Nt applicable t the prject Determine during the updating f the ESIA whether areas f significant bidiversity are present. Include measures fr the preventin and management f invasive alien species during the updating f the ESIA. Nt applicable t the prject Include measures fr the preventin and management f invasive alien species during the updating f the ESIA. The updated EISA shuld prvide a mre cmprehensive descriptin f the ecsystem services baseline, and shuld determine the impacts n cmmunities as well as mitigatin measures. Nt applicable t the prject Nt applicable t the prject Nt applicable t the prject Nt applicable t the prject

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 21 PS heading Para. Ref. Detail Review cmment Recmmendatin 30 Adpt systems and verificatin practices, as part f the ESMS, t evaluate primary suppliers, where there is a risk f significant cnversin f natural and/r critical habitats - especially but nt exclusively fd and fibre cmmdities. These shuld: identify where the supply chain is cming frm and the habitat type f this area; prvide fr nging review f primary supply chains; limit prcurement t suppliers that can demnstrate they are nt cntributing t significant cnversin f natural and/r critical habitats; shift supply chain t suppliers that can demnstrate they are nt significantly adversely affecting these areas. The ability t fully address these risks will depend upn the level f management cntrl r influence ver its primary suppliers. PPC BARNET will need t take steps t ensure that key suppliers such as hspitality management, security, lcal suppliers f cnstructin materials and ther service prviders d nt cntravene child and frced labur guidelines, r place their wrkers in life threatening situatins. Supplies received based n cnversin natural resurces such as fd, fibre and cnstructin materials shuld be cnsidered, as shuld the dispsal f wastes. Prir t cnstructin, a prtcl will need t be put int place fr the checking f supply chains and service prviders, t include a mnitring prgramme t ensure cmpliance with PS2 and PS6. Mnitring f child and frced labur, as well as life threatening situatins, will need t frm an integral part f this prgramme. Steps t remedy and prevent issues will need t be implemented. 43 44 7 PS7 Indigenus Peples Objectives Nt applicable based n available infrmatin Ensure that the develpment prcess fsters full respect fr the human rights, dignity, aspiratins, culture, and natural resurce-based livelihds f Indigenus Peples. Anticipate and avid adverse impacts f prjects n cmmunities f Indigenus Peples, r when avidance is nt pssible, t minimize and/r cmpensate fr such impacts. Prmte sustainable develpment benefits and pprtunities fr Indigenus Peples in a culturally apprpriate manner. Establish and maintain an nging relatinship based n Infrmed Cnsultatin and Participatin (ICP) with the Indigenus Peples affected by a prject thrughut the prject s life-cycle. Ensure the Free, Prir, and Infrmed Cnsent (FPIC) f the Affected Cmmunities f Indigenus Peples when the circumstances described in this Perfrmance Standard are present. Respect and preserve the culture, knwledge, and practices f Indigenus Peples. 8 PS 8: Cultural Heritage 45 Objectives Prtect cultural heritage frm the adverse impacts f prject activities and supprt its preservatin. Prmte the equitable sharing f benefits frm the use f cultural heritage. Prtectin f cultural heritage in prject design and executin Change find prcedures 6 Cmply with applicable natinal laws. Identify and prtect cultural heritage by ensuring that internatinally recgnised practices are implemented fr the prtectin, field-based study, and dcumentatin f cultural heritage 7 Retain cmpetent prfessinals t assist in identificatin and prtectin f cultural heritage. See als paragraphs 10 and 13 t 15. 8 Siting and design t avid significant adverse impacts t cultural heritage. Determine whether the prpsed lcatin f a prject is in areas where cultural heritage is expected t be fund, either during cnstructin r peratins as part f the envirnmental and scial risks and impacts identificatin prcess. Develp prvisins in the ESMS fr managing chance finds 46 thrugh a chance find prcedure 47. D nt disturb any chance find until an assessment by cmpetent prfessinals is made and actins cnsistent with the requirements PS8 are identified. The DRC has ratified United Natins Cnventins relating, inter alia, t scial and cultural rights. The EIA des nt sufficiently describe the cultural heritage baseline, religius and cultural custms f the prject area and features such as presence f graves. N apprpriately qualified specialists were appinted t develp a baseline assessment f the cultural heritage f the prject area. The EIA des nt address the issue f chance cultural heritage finds. The updated EISA baseline shuld prvide cmprehensive dcumentatin f the cultural heritage f the area, t include n-site surveys t determine the presence f graves and ther features f significance. As part f the updating f the ESIA, identify and appint a cmpetent cultural heritage specialist t develp a baseline assessment f the study area. Align crprate plicies t PS 8 guidelines, and update the ESIA t incrprate cultural heritage aspects. Prepare a chance find prcedure fr implementatin by prject persnnel. Cnsultatin 9 Cnsult with Affected Cmmunities wh use, r have used within living memry, the The EIA des nt cntain a cmprehensive cultural heritage The EISA needs t be updated t incrprate feedback frm stakehlders 43 In PS7 Indigenus Peples is used in a generic sense t refer t a distinct scial and cultural grup pssessing the fllwing characteristics in varying degrees: Self-identificatin as members f a distinct indigenus cultural grup and recgnitin f this identity by thers; Cllective attachment t gegraphically distinct habitats r ancestral territries in the prject area and t the natural resurces in these habitats and territries; Custmary cultural, ecnmic, scial, r plitical institutins that are separate frm thse f the mainstream sciety r culture; r A distinct language r dialect, ften different frm the fficial language r languages f the cuntry r regin in which they reside. 44 PS7 applies t cmmunities r grups f Indigenus Peples wh maintain a cllective attachment, i.e., whse identity as a grup r cmmunity is linked, t distinct habitats r ancestral territries and the natural resurces therein. It may als apply t cmmunities r grups that have lst cllective attachment t distinct habitats r ancestral territries in the prject area, ccurring within the cncerned grup members lifetime, because f frced severance, cnflict, gvernment resettlement prgrams, dispssessin f their lands, natural disasters, r incrpratin f such territries int an urban area. 45 The requirements f this Perfrmance Standard d nt apply t cultural heritage f Indigenus Peples. PS7 describes thse requirements. 46 Tangible cultural heritage encuntered unexpectedly during prject cnstructin r peratin. 47 A prject-specific prcedure that utlines the actins t be taken if previusly unknwn cultural heritage is encuntered.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 22 PS heading Para. Ref. Detail Review cmment Recmmendatin cultural heritage fr lng-standing cultural purpses t identify cultural heritage f imprtance. Incrprate int the decisin-making prcess the views f the Affected Cmmunities n such cultural heritage. Cnsult with relevant natinal r lcal regulatry agencies that are entrusted with the prtectin f cultural heritage. Cmmunity access 10 Allw cntinued access by Affected Cmmunities t cultural sites r prvide alternative access subject t verriding health, safety and security cnsideratins. Remval r replicable 48 cultural heritage Remval r nnreplicable 50 cultural heritage 11 Apply mitigatin measures that favur avidance. Where avidance is nt feasible, apply a mitigatin hierarchy as fllws: Minimize adverse impacts and implement restratin measures, in situ, that ensure maintenance f the value and functinality f the cultural heritage, including maintaining r restring any ecsystem prcesses 49 needed t supprt it; Where restratin in situ is nt pssible, restre the functinality f the cultural heritage, in a different lcatin, including the ecsystem prcesses needed t supprt it; The permanent remval f histrical and archaelgical artefacts and structures is carried ut accrding t the principles f paragraphs 6 and 7; Cmpensate fr lss f that tangible cultural heritage, nly where minimizatin f adverse impacts and restratin t ensure maintenance f the value and functinality f the cultural heritage are demnstrably nt feasible, and where the Affected Cmmunities are using the tangible cultural heritage fr lng-standing cultural purpses. 12 D nt remve any nn-replicable cultural heritage unless all f the fllwing cnditins are met: There are n technically r financially feasible alternatives t remval; The verall benefits f the prject cnclusively utweigh the anticipated cultural heritage lss frm remval; Any remval f cultural heritage is cnducted using the best available technique. Critical cultural heritage 13 Critical cultural heritage cnsists f ne r bth f the fllwing: Prject s use f cultural heritage the internatinally recgnized heritage f cmmunities wh use, r have used within living memry the cultural heritage fr lng-standing cultural purpses; r legally prtected cultural heritage areas, including thse prpsed by hst gvernments fr such designatin. 14 D nt remve, significantly alter, r damage critical cultural heritage. When impacts are unavidable, use a prcess f Infrmed Cnsultatin and Participatin (ICP) f the Affected Cmmunities (as per PS1) and which uses a gd faith negtiatin prcess that results in a dcumented utcme. Retain external experts t assist in the assessment and prtectin f critical cultural heritage. 15 Meet the fllwing requirements where a prject is lcated within a legally prtected area r legally defined buffer zne: Cmply with natinal/lcal regulatins r prtected area management plans; Cnsult the areas spnsrs and managers, lcal cmmunities and ther key stakehlders; Implement additinal prgrams t prmte and enhance cnservatin aims f the area. 16 Where a prject prpses t use the cultural heritage, including knwledge, innvatins, r practices f lcal cmmunities fr cmmercial purpses, the Infrm cmmunities f: baseline. Further, n stakehlder cnsultatin addressing heritage issues has been undertaken amngst affected cmmunities. N identificatin f imprtant cultural heritage features was carried ut in the EIA. The cultural heritage baseline f the EIA is inadequate and has nt identified the presence (r therwise ) f cultural heritage features in the prject area. The cultural heritage baseline f the EIA is inadequate and has nt identified the presence (r therwise ) f cultural heritage features in the prject area. Management measures fr the prtecti0n f cultural heritage need t be develped. The presence (r therwise ) f cultural heritage features in the prject area, including the ptential fr any f critical imprtance, has nt been verified. It is nt anticipated that such features will be present. The cultural heritage baseline f the EIA is inadequate and has nt identified the presence (r therwise ) f cultural heritage features in the prject area. N prcedures have been develped fr the prtectin f cultural heritage. There are n apparent natinal/lcal prtected areas in the prject area. Nt applicable t the prject regarding cultural heritage in the prject area. Ensure that relevant authrities are incrprated n the stakehlder database. Identify imprtant sites/features which frm part f lcal cultural practices within the prject area. This shuld be undertaken as part f the part f the cultural heritage baseline fr the ESIA update. Ensure that cntinued access by cmmunities during cnstructin and peratin, subject t health, safety and security cncerns. Update the ESIA with a baseline and mitigatin measures fr prtectin f cultural heritage. Evaluate the ptential fr realigning the prject layut based n the presence f cultural heritage features, as relevant. Identify mitigatin measures fr the prtectin f cultural heritage, and specify management measures in the updated EISA. Update the ESIA with a baseline and mitigatin measures fr prtectin f cultural heritage. Evaluate the ptential fr realigning the prject layut based n the presence f cultural heritage features, as applicable and as relevant. Identify mitigatin measures fr the prtectin f cultural heritage, and specify management measures in the updated ESIA. This will include a chance find prcedure. Identify during the baseline cultural heritage study fr the ESIA update whether r nt critical cultural heritage is present in the area. Take apprpriate steps in line with PS8 shuld critical cultural heritage be identified. Update the ESIA with a baseline and mitigatin measures fr prtectin f cultural heritage. Evaluate the ptential fr realigning the prject layut based n the presence f cultural heritage features, as relevant. Identify mitigatin measures fr the prtectin f cultural heritage, and specify management measures in the updated EISA. This will include a chance find prcedure. Implement measures t prmte and enhance the cnservatin f areas f cultural heritage imprtance. Nt applicable t the prject 48 Tangible frms f cultural heritage that can themselves be mved t anther lcatin r that can be replaced by a similar structure r natural features t which the cultural values can be transferred by apprpriate measures. Archaelgical r histrical sites may be cnsidered replicable where the particular eras and cultural values they represent are well represented by ther sites and/r structures. 49 As per PS6. 50 This relates t the scial, ecnmic, cultural, envirnmental, and climatic cnditins f past peples, their evlving eclgies, adaptive strategies, and early frms f envirnmental management, where the (i) cultural heritage is unique r relatively unique fr the perid it represents, r (ii) cultural heritage is unique r relatively unique in linking several perids in the same site.

SRK Cnsulting: IFC Perfrmance Standard Review Framewrk (2012) Page 23 PS heading Para. Ref. Detail Review cmment Recmmendatin their rights under natinal law; the scpe and nature f the prpsed cmmercial develpment; the ptential cnsequences f such develpment. D nt prceed with cmmercializatin unless: a prcess f ICP (see PS1) and which uses a gd faith negtiatin prcess that results in a dcumented utcme is undertaken; fair and equitable sharing f benefits frm cmmercializatin f such knwledge, innvatin, r practice, cnsistent with their custms and traditins is prvided.

SRK Cnsulting: Prject N: 467328 Page 13 Appendix B: Prpsed Scpe f Wrk fr Specialists Brl/Kili Gap Analysis - Sngll Cement Prject September 2013

Appendix B: SRK Prvisinal Terms f Reference fr Specialists

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION Specialist data cllectin will take place as fllws: Cmmencement f data cllectin at the earliest pssible stage f phase 2a fr specialist areas that requires a lng lead time t cmplete, and will need t extend t Phase 2b cvering: Bidiversity (terrestrial and aquatic including ecsystem services) Hydrlgy and hydrgelgy Air quality Ambient nise levels Cmmencement f data cllectin at the earliest pssible stage f phase 2a,anticipated t be cmpleted during this phase, cvering: Sci-ecnmic baseline Cultural heritage Sil, land capability and land use Traffic Bidiversity (terrestrial and aquatic) Review f existing studies and assessment f relevant prject gaps Desk-tp mapping and characterisatin f vegetatin/habitats and fauna f terrestrial and aquatic envirnments Additinal assessment f vegetatin may be required depending n availability f infrmatin. Surveys will include mapping f any rare, endemic r Red Data as well as alien species will be recrded and mapped during surveys Mid-June 2014 Based n immediately available data, carry ut high-level assessment f sensitivities with respect t receptrs in the vicinity f the prject. This data shuld be used t infrm prject layut and design, t be refined as necessary during the data gathering prcess. Ptential risks and mitigatry measures t prtect ntable flra and fauna resurces will be identified based n impacts assciated with the prpsed PPC Prject. Sensitivity mapping will include develping a spatial map that incrprates bidiversity and eclgical cnstraints and pprtunities acrss the entire prject

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION area. Lcal experts specialising in varius bidiversity fields will be engaged and invlved in the cmpilatin f the bidiversity study. This will include sharing f data and mnitring prcedures t strengthen the scientific rigur f the verall prject. This will be used t infrm layut and design f the prject Aquatic bidiversity elements f the fd chain shuld be examined as pints f impact frm the prject. This will be dne accrding t specified bi-mnitring prcedures and thus detailed accrding t apprpriate bi-mnitring indicatrs. The Suth African Scring System, Versin 5 (SASS5) culd be applied if cnsidered t be apprpriate by the specialists. Additinal in situ water quality indicatrs will cver disslved xygen; ph; cnductivity and water temperature; water clarity mnitring. Any additinal water quality sampling data (e.g. chemical and nutrient cnstituents), where available, will be reviewed, analysed and integrated frm an aquatic ecsystem cntext highlighting pssible impacts t the aquatic envirnment. Assessment f wetland systems by mapping ff digital imagery and in field visual verificatin. N detailed mapping is currently envisaged. Assessment f ecsystem gds and services is increasingly a requirement fr majr prjects and meets recently revised Internatinal Finance Crpratin standards (IFC, 2011 ) and Wrld Business Cuncil fr Sustainable Develpment best practice (WBCSD, 2011 ). This assessment tl is an efficient prcess in situatins where there is large-scale cmmunity dependence n natural resurces. Hydrlgy and hydrgelgy Data cllectin and review Mid-June 2014 A surface water and grundwater specialist will g t site and will spend apprximately 10 days n site Based n immediately available data, carry ut high-level assessment f sensitivities with respect t hydrlgy n the site. This data shuld be used t infrm prject layut and design, t be refined as necessary during the data gathering prcess. It is assumed that drilling infrmatin, hydrcensus and surface water flw infrmatin will be supplied t SRK, as well as 1:5m cntur infrmatin fr the site Fldline assessment will be carried ut fr the site based n 1:5m cnturs Sensitivity mapping will include develping a spatial map that incrprates hydrlgical cnstraints and pprtunities acrss the entire prject area, t be used

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION t infrm prject layut and design Drilling infrmatin, hydrcensus and surface water flw and water quality data will be analysed and a reprt prepared. A quarterly reprt will be prepared and then the annual reprt will cmbine all data received; 2 additinal site visits by the surface water and grundwater specialist will ccur during the year (10 days per site trip); and A baseline reprt will be prepared. Air Quality The bjective f this study is t develp adequate baseline data relating t climate and air quality and mdel impacts assciated with the mine s cnstructin, peratins and clsure activities with respect t respirable and nuisance dust, carbn emissins and greenhuse gases. The climate and air quality study will include the fllwing tasks: Mid-June 2014 Based n immediately available data, carry ut high-level assessment f sensitivities with respect t receptrs in the vicinity f the prject. This data shuld be used t infrm prject layut and design, t be refined as necessary during the data gathering prcess. Setup a baseline mnitring netwrk that will include the cllectin f dust samples and gases such as SO 2, NO x as required. Investigate and btain suitable lcal meterlgical data fr the in-cuntry EIA. Falea has a weather statin and data frm this shuld be used in the ESIA. Cllectin f data (maximum f 8 sampling pints) ver a 12 mnth perid which will include the fllwing: Dust - mnthly dust fallut; PM10 cntinuus mnitring; and Gas quarterly The mnitring prgram shuld run ver a 12 mnth perid. Only the gas and dust fallut samples need t be analysed. It will be necessary t identify a lcal labratry t d the gravimetric analysis. If n

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION suitable labratry is available in Mali fr gas analysis (r gravimetric analysis) then this can be dne by a labratry based in Eurpe r Suth Africa. Site persnnel will be trained t run and maintain the mnitring netwrk fr the duratin f the sampling prgram. The PM10 mnitr shuld be set up t run ff slar panels. Ambient Nise levels The baseline data will be cllected n site by a nise specialist. Undertake a desktp study t review available prject infrmatin and data fr the area, including legal requirements. Cmpile an infrmatin needs list. Prvide input int defining and mapping the area f influence. Based n immediately available data, carry ut high-level assessment f sensitivities with respect t receptrs in the vicinity f the prject. This data shuld be used t infrm prject layut and design, t be refined as necessary during the data gathering prcess. Specialists must liaise clsely with SRK and the SRK GIS Team (cntact details in sectin 9) fr mapping requirements. Analyse aerial pht/ satellite imagery t identify ptentially sensitive receptrs in relatin t prpsed mine infrastructure. Review the mnitring prtcl that was used t guide n-site mnitring fr applicability based n the new prject descriptin. Review the lcatins and characteristics f receptrs and nise surces; Nte in particular the numerus mining activities nw being undertaken t the west f the cncessin. Verify whether additinal baseline definitin and mnitring r result in cumulative impact, hwever this must be cnfirmed in yur study. Review the previus measurement f ambient nise levels at selected sites in accrdance with DRC and internatinal requirements. Develp a detailed predictive mdel fr the nise emissins frm the prpsed prject. It is prpsed that the internatinally accepted CONCAWE methd will be used fr the calculatin f nise prpagatin. This will cnsider: The sund pwer emissin levels f equipment and prcesses; The attenuatin f nise due t gemetric spreading; The attenuatin f nise due t atmspheric absrptin and the grund effect; The attenuatin f nise due t the screening effect f the tpgraphy and ther structures; and The effect f meterlgical and ther atmspheric cnditins that influence the prpagatin f nise. The predictive mdelling shuld be used t determine and describe in detail using as much quantitative data as pssible, the direct, indirect and cumulative impacts arising Mid-June 2014

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION Sci-ecnmic baseline assessment and reprt develpment frm the activity fr the key stages f the prject including: precnstructin (if applicable), cnstructin, peratin and pst-clsure, as well as fr different prject alternatives. This may necessitate prviding advice t the engineering team n preferred alternatives. Identify management and mitigatin measures and actins that address the direct, indirect and cumulative impacts in rder t cmply with applicable laws and standards. The assessment shuld present in tabular frm the predicted nise levels fr receptrs in relatin t the DRC and WHO/IFC nise emissin limits. Based n immediately available data, carry ut high-level assessment f sensitivities with respect t receptrs in the vicinity f the prject. This data shuld be used t infrm prject layut and design, t be refined as necessary during the data gathering prcess. Existing sci-ecnmic data (publicly available and supplied by PPC) will be reviewed and analysed. This will include census statistics, and natinal and lcal gvernment reprts Mid-Nvember 2013 A current baseline descriptin with secndary and primary qualitative and quantitative data will be develped The Primary Area f Influence (PAI) will be determined in cnsultatin with PPC; t cver surrunding cmmunities. Infrmatin will be surced using fcus grup interviews, key infrmants and a husehld surveys The Secndary Area f Influence (SAI) will extend thrughut the District, the capital and cmmercial centre f the regin. Infrmatin fr the SAI will be based largely n dcumented surces and key infrmant interviews, fcus grups and husehld surveys Where pssible SRK will make use f lcal fieldwrkers and translatrs t assist in the cmpletin f the husehld survey, fcus grups and key infrmant interviews. SRK may require the assistance f PPC t surce suitable candidates. A husehld survey will be cnducted t reinfrce findings and t capture basic husehld data such as husehld cmpsitin, educatinal attainment, and access t health services. By ding a randm and widespread sample it will ensure that the surveyed husehlds are representative f the cmmunity cmpsitin; Scial Mapping: the lcatin f all scial infrastructure such as schls, clinics,

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION hspitals, graves, plice statins etc. will be recrded and cmprehensive mapping will be prduced, likely t cver: Demgraphics (including influx); Cmmunity prfile and ethnlgy; Livelihds analysis and cntext ; Ecnmic and cmmunity develpment determinants (access t scial service infrastructure and basic Human Develpment Indices (HDIs)); Gender and marginalised grups; Scial rganisatin and cmmunity gvernance; Ecnmic cntext; Sci-plitical cntext and relevant institutins; Histrical cntext; and Cultural prperty and practices Links with stakehlders and implicatins f impacts will be explred: implicatins fr stakehlders, as well as assciated risks t PPC and the stakehlders Cultural Heritage Undertake a desktp study t review available prject infrmatin and data fr the area, including legal requirements fr the prtectin f cultural heritage and permits that may be required. Cmpile an infrmatin needs list. Prvide input int defining and mapping the area f influence. Based n immediately available data, carry ut high-level assessment f sensitivities with respect t receptrs in the vicinity f the prject. This data shuld be used t infrm prject layut and design, t be refined as necessary during the data gathering prcess. Specialists must liaise clsely with SRK and the SRK GIS Team (cntact details in sectin 9) fr mapping requirements. Undertake a field survey (using internatinally accepted field survey methds) t grund-truth and update any surface remains and artefacts f archaelgical, histrical r cultural significance (including graves) that were fund n the prpsed Mid Nvember 2013

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION ftprint areas and t recrd their gegraphical lcatin. Analyse any material fund t establish the significance f sites/ material, and develpment f a register f sites and relevant material. All sites must be pltted n a map. Identify sites/ material requiring excavatin r preservatin and dcument these sites in the reprt. Identify significant sites in the ftprint areas and cmment n the pssible ccurrence and, if relevant significance f such ccurrence, f sites in the wider cncessin area and characterise the significance f these sites (e.g. traditinal and sacred sites, cemeteries, areas fr medicinal plant use). This will require liaisn with the sci-ecnmic specialists t ensure alignment in data cllectin and reprting (especially with the scial baseline team refer t cntact details belw). If sites f imprtance are fund, advise n the prcess t preserve r remve them as required. In additin t reprting n the results frm surveys as detailed abve: Describe the baseline cultural envirnment including religin, language, cultural practices and the significance (internatinal, natinal and lcal) f cultural heritage in the prject area; and Identify sensitive r critical cultural heritage which requires prtectin r management (delineate these n a map). Identify, map, study and describe the significance f any cultural heritage sites. Sufficient baseline infrmatin shuld be prvided t adequately assess future impacts prject develpment may pse, and identify apprpriate avidance, mitigatin and/r cmpensatin measures. Prvide gegraphic c-rdinates electrnically n the lcatins f identified sites and their attributes in the agreed c-rdinate system. The baseline shuld be used t determine and describe in detail using as much quantitative data as pssible, the direct, indirect and cumulative impacts arising frm the activity fr the key stages f the prject including: precnstructin, cnstructin, peratin and pst-clsure, as well as fr different prject alternatives. This may necessitate prviding advice t the engineering team n preferred alternatives. Identify management and mitigatin measures and actins that address the direct,

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION indirect and cumulative impacts in rder t cmply with applicable DRC laws and standards. Maps shuld be prvided wherever pssible. The fllwing maps need t be included and/ r updated: Sample sites and transects (e.g. excavatins); and Heritage sites and their classificatin and cnservatin status. Prvide details f any future wrk required. Recmmendatins must be frmulated fr the future mnitring f significant impacts, in the cntext f existing surces and receptrs. This shuld include indicatrs, targets and where necessary, acceptable criteria Sils and land capability Undertake a desktp study t review available prject infrmatin and data fr the area, including legal requirements fr the prtectin f sils and lands f high capability as well as permits that may be required by the DRC legislatin. Cmpile an infrmatin needs list. Prvide input int defining and mapping the area f influence. Specialists must liaise clsely with SRK and the SRK GIS Team (cntact details in sectin 9) fr mapping requirements. Update the existing baseline reprt and ensure that the fllwing cmpnents are cvered and still relevant and apprpriate. Review aerial phtgraphs, cadastral maps and gelgical maps t update the fllwing aspects (particular attentin shuld be paid t the new haul rad): Underlying gelgy; Land use; The prximity f the areas under investigatin t the surrunding land users; and Physical features which may influence sil type. These include water bdies, utcrps, slpes fr catena differences etc. Each type f sil identified in the prject area must be described in terms f size, frmatin and its lcatin 1. Mid Nvember 2013 1 DRC legal requirement, refer t Article 28, Schedule IX f the DRC Mining Regulatins

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION Specify whether hydrmrphic sils are present in the permit area and indicate their lcatin: Immature nn climatic (aznal) alluvial sils; and Hydrmrphic sils excluding the sub-grup f saline humic gley sils 2. Review the: Sil fertility parameters required t assess agricultural and rehabilitatin ptential; and Sil characteristics and land capability in terms f the Fd and Agriculture Organisatin (FAO) Guidelines fr Sil Descriptin, 2006, which includes physical and mrphlgical characteristics as well as infrmatin used t derive land capability. The abve mentined parameters will need t be cnsidered fr the new haul rad. Calculate the percentages f the sils in the area f influence that are used fr agriculture/ farming, cattle, industrial purpses, cmmercial activities, residual sils and sils left in their natural state. Fr each use f sil, describe the type and purpse f activity as well as the methds used, specifying whether such activity is temprary r permanent, intermittent r regular. 3 Liaise with ther specialists as necessary (cntact details in sectin 9 belw), such as the scial, water and bidiversity teams. 4 Particular attentin must be paid t mapping the bundaries f wetland sils. This will require cnsultatin with the bidiversity specialist wh will be mapping land-cver and habitat types. Identify areas subject t ersin, the arid r semi-arid areas subject t desertificatin and specify their size and lcatin n a tpgraphical map Traffic Undertake a desktp study t review available prject infrmatin and data fr the area, including legal requirements. Mid-Nvember 2013 2 DRC legal requirement, refer t Article 28, Schedule IX f the DRC Mining Regulatins 3 DRC legal requirement, refer t Article 28, Schedule IX f the DRC Mining Regulatins 4 DRC legal requirement, refer t Article 28, Schedule IX f the DRC Mining Regulatins

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION Cmpile an infrmatin needs list. Prvide input int defining and mapping the area f influence. Based n immediately available data, carry ut high-level assessment f sensitivities with respect t traffic flws and receptrs in the vicinity f the prject. This data shuld be used t infrm prject layut and design, t be refined as necessary during the data gathering prcess. Specialists must liaise clsely with SRK and the SRK GIS Team (cntact details in sectin 9) fr mapping requirements. Liaise with mine planners abut where the n-site rads culd g. Review and update where necessary (using Tenke and Kisanfu data): Current traffic and pedestrian flws n the surrunding rad netwrk thrughut the day and ver weekends; Public transprt and rad safety; Rad infrastructure, rad safety r public transprt related issues n the surrunding rad netwrk, including the haul rute fr supplies, equipment, raw materials and the finished prduct up t the first majr twn; Structural capacity and cnditin f the surrunding rad netwrk with respect t their ability t deal with prpsed increased levels f mine related traffic during the cnstructin and peratinal phases f the prject; and Future transprtatin plans fr the area. Particular attentin shuld be paid t the prpsed 15 km haul rad and its intersectins with existing transprt rutes. The baseline shuld be used t determine and describe in detail using as much quantitative data as pssible, the direct, indirect and cumulative impacts arising frm the activity fr the key stages f the prject including: precnstructin (if applicable), cnstructin, peratin and pst-clsure, as well as fr different prject alternatives. This will invlve: Estimating the ptential vlume f daily and peak hur external traffic that the prpsed mining prject will generate (t and frm the prpsed mine); Estimating the ptential vlume f daily and peak hur traffic and pedestrians that wuld be generated during the cnstructin phase f the prject, if applicable; Estimating the distributin f this additinal and cnstructin related external traffic within the site and estimate the distributin f the external traffic n the

SUB-TASK ACTIVITIES ANTICIPATED COMPLETION external rad netwrk; Assessing the traffic and pedestrian impact f the prpsed prject n the surrunding external rad netwrk, including pedestrians, cyclists, mtr cyclists, rad safety and public transprt. Nte that rad safety issues are t be highlighted. This may necessitate prviding advice t the engineering team n preferred alternatives. Identify management and mitigatin measures and actins that address the direct, indirect and cumulative impacts in rder t cmply with applicable laws and standards. Review the mine layut and cmment n the adequacy f the prpsed internal infrastructure, including access rads, haul rads, bus stps and parking areas. Recmmend external rad netwrk imprvements that may be required t mitigate any traffic and pedestrian impacts that are identified, including alternative rutes, rad safety and public transprt Health A high-level review will be carried ut which identifies the key baseline health issues Mid-Nvember 2013

SRK Cnsulting: Prject N: 467328 Page 14 SRK Reprt Distributin Recrd Reprt N. 467328 Cpy N. 1 Name/Title Cmpany Cpy Date Authrised by A Shirley PPC 1 (electrnic) 13/09/2013 L Brwn L Brwn/D Kilian SRK 2 (electrnic) 13/09/2013 L Brwn Apprval Signature: This reprt is prtected by cpyright vested in SRK (SA) Pty Ltd. It may nt be reprduced r transmitted in any frm r by any means whatsever t any persn withut the written permissin f the cpyright hlder, SRK. Brl/Kili Gap Analysis - Sngll Cement Prject September 2013