Our approach to sustainability
Altyn plc is a UK based company with its main properties and interests in the Republic of Kazakhstan. The company is registered in England with its Registered Office in London (Registration Number 05048549). Its shares are listed on the Main Market of the London Stock Exchange. Altyn plc is the parent holding company controlling the Kazakhstan operations. The operating companies are subsidiaries based in the Republic of Kazakhstan which are 100% owned by Altyn plc. The mineral rights and mining licence at Sekisovskoye are held by ME BAURGOLD LLP whilst the processing plant is held and operated by MMC Altyn MM LLP. Further subsidiaries hold the other Altyn plc interests in the area. These Kazakh operating companies hold, administer and maintain the mining and exploitation licences and the other statutory instruments required by Kazakh legislation and regulation on behalf of the parent company, Altyn plc.
Altyn plc and its subsidiary operating companies are committed to contributing positively to the well-being of their employees, the environment, economy and society and believe that the long- term future of the Company is best served by respecting the interests of all stakeholders: employees, customers, suppliers and the wider community. Altyn plc will look actively for opportunities to improve the environment and to contribute to the wellbeing of their local communities, believing that responsible behaviour generates greater value for the stakeholders and earns us the trust of employees, customers and the local communities.
The following principles form the core of Altyn plc commitment:
— Implement and maintain ethical business practices and sound systems of corporate governance.
— Integrate sustainable development considerations within the corporate decision-making process.
— Uphold fundamental human rights and respect cultures, customs and values in dealings with employees and others who are affected by the company’s activities.
— Implement risk management strategies based on valid data and sound science.
— Seek continual improvement of the company’s health and safety performance.
— Seek continual improvement of the company’s environmental performance.
— Contribute to conservation of biodiversity and integrated approaches to land use planning.
— Facilitate and encourage responsible product design, use, re-use, recycling and disposal of the company’s products.
— Contribute to the social, economic and institutional development of the communities in which the company operates.
— Implement effective and transparent engagement, communication and verifiable reporting arrangements with the company’s stakeholders.
The Stakeholder Engagement Plan (SEP) is a communication tool that will link and assist in the management and flow of information between Altyn plc and its stakeholders. Its primary aim is to enhance and encourage relations between all parties in an objective way and to clearly disseminate information about the company’s plans, the project, its associated activities and the potential impacts, both adverse and positive, which may accrue, together with details about how this information flow will be achieved. Implementation of the plan will reduce the risk of ambiguity in decisions reached and increase the level of transparency displayed by providing information in language which will be accessible and easily understood by all interested stakeholders.
Stakeholder engagement provides an opportunity for the stakeholders to ask questions, discuss the programme and express any concerns they may have, so that Altyn plc is able to respond to comments received. Periodic monitoring and evaluation of the SEP will ensure that any necessary revisions are made in a timely manner to ensure that the programme remains relevant to the needs of both the company and the stakeholders. The SEP also defines a formal complaint procedure.
The main objectives of the SEP are to:
— Facilitate open communication with all interested stakeholders;
— Build a robust and open relationship with the local community of Sekisovka;
— Provide publicly available information concerning the policies and plans of Altyn plc and details of project;
— Provide timely, relevant, accessible and easily understood information to stakeholders in an appropriate non-technical format, in both Kazakh and Russian languages;
— Open consultation with stakeholders to ascertain and discuss their opinions and concerns;
— Propose and establish formal and informal public consultation and participation procedures;
— Implement management and mitigation measures designed to reduce potential negative impacts while enhancing potential benefits;
— Establish accessible and effective systems for reporting, investigating and resolving grievances separately for both Altyn plc employees and the general community; and
— To establish stakeholder engagement as an integral part of on-going environmental and social impact assessment activity, vital in ensuring mitigation measures address impact and a priority as a basis for future engagement.
Although not required by Kazakhstan laws or the London Stock Exchange, a full Environmental Impact Assessment (EIA) and Social Impact Assessment (SIA) for the Sekisovskoye Mine has been prepared by Altyn plc, as part of its commitment to meeting best international practice.
The major potential environmental and socio-economic benefits of the project have been identified as:
— Creation and provision of new jobs due to the increase in overall mine production and the associated upgrades to the mine and the process plant;
— increased contributions to revenues from taxes and royalties;
— establishment of improved local infrastructure and upgraded social amenities;
— improved local economic conditions;
— encouragement for local entrepreneurship and the establishment of new small locally based businesses;
— long term rehabilitation of the Sekisovskoye working area with a sympathetically designed restored landform conforming generally with the existing undisturbed regional landscape;
— provision of improved biodiversity as part of the restoration and rehabilitation plan;
— agreed community development projects sponsored by the company; and
— by multi-skilling, re-skilling and education opportunities provided by employee training at the mine.
The major potential adverse environmental and socio-economic impacts of the project have been identified as:
— visual intrusion particularly on the local landscape;
— environmental health impacts due to dust, noise, and blasting vibration;
— production of greenhouse and noxious gases from mobile plant, blasting and other operations and functions;
— hydrological impact on the quality and quantity of local water resources;
— the social impacts of the recruitment of workers from outside the area;
— the social impacts of the exhaustion and closure of the open pit and its replacement with underground operations and the consequent potential loss of local jobs; and
— the socio-economic impacts of mine closure.
Background to the legislative obligations
Details of the requirements of Kazakh legislation are set out below.
In 2007, the Ecology Code came into force in Kazakhstan and it combined all main regulations related to ecology issues into one document, including duties and responsibilities of the authorized state bodies and of nature users as well as requirements on protection of natural resources. The Ecology Code requires that development activities and projects, which have direct or indirect impact on the environment and socio-economic issues, are subject to the Environment and Social Impact Assessment (ESIA) process. The ESIA process includes the evaluation of the impact on the environmental and social issues over the life of the project and requires that studies should establish baseline prior to commencement of works with regular update and review throughout the project’s life. Monitoring of environmental and social impacts is required and is regulated by the terms of the licence and by periodic regulatory inspection by the authorities to ensure compliance. Emissions and other limits are set for a number of parameters such as water quality, air quality, soil quality, dust noise and vibration. The regulatory authorities expect and require full compliance with the achievement and fulfilment of all environmental limiting indices and licence requirements and any non-compliance or violations may lead to severe consequences, including cessation of operations and judicial penalty.
The international EIS and SIA preparation which has been carried out by Altyn are in addition to the statutory requirements of the Kazakh codes. Altyn has completed these studies to ensure that best practice methods are achieved at their operations. All new and/or additional operations acquired or taken up by Altyn will be conform to the standards adopted and being put in place at Sekisovskoye.
The regulatory framework provided by the government of the Republic of Kazakhstan is relevant to our approach to stakeholder engagement. In this context, it is important to note that the government of Kazakhstan has ratified the UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters, also known as the Aarhus Convention. The Aarhus Convention requires the government to grant the public rights regarding access to information on the environment, including information on the environmental impacts of corporate activities, access to which is available only to the relevant environmental authority. This ecological information should be provided in advance to any affected party.
Accordingly to the legal regulations information disclosure and dissemination, as well as public consultation, are a part of the development process, especially if the project impacts the environment.
The following legislative acts relate to public participation in decision making within Kazakhstan:
— Environmental Code of RK No. 212-III of 09.01.2007 (as amended on 17.07.2009);
— Instruction of Environmental Impact Assessment Conduction of Proposed Economical or
— Other Activities during Development of Pre-planning, Planning, Pre-design and Design Documentation, approved by Order of Minister of Environmental Protection of RK No.204-p of 28.06.2007;
— Rules on Public Hearing Conduction, approved by Order of Minister of Environmental Protection of RK No.135-p of 07.05.2007;
— Rules on Access to Environmental Information Relevant to Environmental Impact Assessment (EIA) Procedure and Decision-Making Process on Proposed Economical and Other Activities, approved by Order of Minister of Environmental Protection of RK No.233-p of 25.07.2007;
— Rules on Conduction of Public Hearing while Considering Application for Approval or Change of Tariffs (Prices, Rates) of Entities which are Natural Monopolies. Approved by Decree of RK Government No. 376 of 21.04.2003;
— As such the current legislative system provides guidelines for public consultation and participation in decision-making, although the scale of such activities is dependent on the type and scale of the proposed project and degree of public interest.
IFC/ World Bank Guidelines
The IFC Handbook “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets” forms a principal reference setting out the principles and practice for the establishment of good stakeholder engagement focussing on stakeholder groups “external” to the core operation of the business, such as affected communities, local government authorities, non-governmental and other civil society organizations, local institutions and other interested or affected parties. It does not address engagement with suppliers, contractors, distributors, or customers, because interaction with these parties is a core business function for most companies and subject to national regulations and/or established corporate policies and procedures. The handbook stresses that the stakeholder engagement programme must be tailored to fit each individual project in order to achieve the programme’s aims but notes that in order to foster transparency and openness stakeholder participation should be pro-active and should be commenced as early as practicable, rather than driven by the onset of problems. The relationships between company and stakeholders take some time to establish and early engagement provides a valuable opportunity to influence public perception and set an early positive tone with stakeholders. The early interactions with stakeholders can be used as a predictor of potential issues and risks, and to help generate ideas and alternative solutions on design questions.
It is Altyn intention to fulfil the recommendations of the IFC guidelines.
The EBRD Performance Requirement 10 “Information Disclosure and Stakeholder Engagement” is contained in the Bank’s Environmental and Social Policy which covers the environmental and social issues associated with sustainability and sustainable development. Stakeholder engagement forms an integral part of corporate social responsibility and is held by EBRD as a cornerstone of the effective management of the potential environmental and social impacts of a project on a community and the achievement of community benefit. This Performance Requirement emphasises that the on-going and progressive process of stakeholder engagement and participation must involve transparent public disclosure of relevant information so that open and meaningful dialogue, consultation and discussion can take place with stakeholders and affected parties. Effective procedures and mechanisms must be established and put in place to facilitate and allow the reception, investigation and consideration of complaints received from the stakeholders. EBRD requires that communication with stakeholders should take place on a regular on-going basis and include disclosure of information, consultation and informed participation in a meaningful and culturally appropriate manner.
The impact assessment draft documents should be disclosed to the public for review before decisions are taken when options remain so that stakeholders may have the opportunity to comment on the potential risks, impacts and mitigation measures and their perceptions of those issues. Altyn should consider the comments and respond to stakeholders, taking them into account in the finalisation of the proposals.
As part of the Kazakh OVOS process, Altyn will utilise the associated public hearings to communicate and engage the stakeholders.
It is Altyn intention to fulfil the requirements of the EBRD E&S policy and that intention is set out in this SEP.
Since the acquisition of the previous holding and mining company in 1998 and the mining licence in 2000 and throughout the development of the Sekisovskoye project including the granting of the subsoil exploitation licence in 2006 and the start of mining of the open pit in 2007, Altyn has undertaken extensive consultation with key stakeholders and in particular with the Kazakhstan Government and its Authorities, the East Kazakhstan oblast (province) Authorities, the Akim (or mayor) and representatives of the Glubokovskiy district, and the local Akim of Sekisovka village together with the regulatory and environmental bodies involved with the licensing and monitoring of the operations. All the bodies consulted have given constructive assistance to Altyn and full and free exchange of views, ideas, suggestions and requirements has taken place, with all relationships remaining cordial.
Public Consultation is a key part of the stakeholder engagement and participation process and it is recognised that more extensive consultation with the inhabitants and people of the local Sekisovka village and local environs is necessary and required, having so far been generally confined to the Akim who is an official appointed by the Glubokovskiy District Akim, rather than elected by the populace. However consultation and discussion of the proposals for the upgrading of the Sekisovskoye operation is being planned to take place with the local stakeholders and also the employees. These consultations which will also inform the ESIA process and the finalised EIA and SIA will include details of the consultations and results of the discussions to include both the positive and negative comments, the hopes and aspirations and the doubts and fears which the community express about the project, together with the answering comments and any provisions or statements made by Altyn.
It is the company’s intention to set up robust local stakeholder participation. To achieve this, the company has identified the major stakeholders in the wider Kazakhstan national and East Kazakhstan regional (oblast) settings in addition to the more local Glubokovskiy district (raion). However the stakeholder identification process for the local Sekisovka village is hindered by the apparent lack of village elders or senior figures in Sekisovka who would be able to represent the local inhabitants, apart from the unelected Akim.
Stakeholders can be either external or internal to the company and can be defined as people or groups of people that are:
- — directly or indirectly affected by the project;
- — have interests in the projects and its activities; or
- — have the ability to affect the project and its planned outcome.
Stakeholders have been identified as the following:
- — Inhabitants of Sekisovka village directly impacted by land acquisition and living in close proximity to project activities within 300m of the mines boundary fence;
- — Inhabitants of Sekisovka village;
- — Inhabitants in the wider local community which would include those living in the Glubokovskiy district and the adjacent sections of the East Kazakhstan Oblast. It may also be necessary to consider adjacent areas of Kazakhstan or Russia where new workers may originate.
- — Entrepreneurs and owners of local businesses;
- — Local, District, Regional and National official Government bodies including statutory and regulatory departments which may include the agencies that regulate economic and social development, education, crime suppression, tourism and culture development. An assessment of the agencies’ involvement and relevance will form part of the stakeholder identification programme.
- — Non-Government Organizations and concerned International Institutions, which may include organised local, national and international environmental pressure groups, trans-border organisations and international human rights organisations. The stakeholder identification programme will identify the NGOs operating in the area with both interested and relevant local and international NGOs and institutions located outside of the Republic of Kazakhstan being considered.
- — Financial institutional investors and lenders and other investors and shareholders;
- — Media stakeholders in the local and national realm such as newspapers, television and radio stations, and information newsletters and the social internet media such as blogs and social networking sites, etc, together with the international media such as the world mining, environmental and business press and the wider international television networks.
- — Staff and employees of Altyn and its subsidiaries;
- — Altyn contractors, suppliers and customers.
- — Other interested parties including potentially ethnic spiritual, cultural and religious groups.
- — vulnerable groups will be particularly noted as part of the stakeholder identification programme and specific and appropriate engagement methods applied to ensure that these vulnerable groups can play a full part in the engagement process.
5.1 Corporate citizenship plan
To facilitate the design and implementation of the Social Development Plan, a community participation process will be established to enable the community to be involved in the project and to discuss their needs expectations and concerns. Suggested areas of involvement which may be sponsored by the company will include health, education, village infrastructure and projects for socio-economic development including encouragement of local entrepreneurship and the fostering of new local businesses, together with the wherewithal to achieve the aims, such as external micro- finance initiatives.
5.2 Goals for on-going stakeholder engagement
The Altyn stakeholder engagement programme aims to:
- — Increase the awareness of all employees with regard to the environmental, social and other issues which may affect the local community and also the culture and aspirations of the larger community surrounding the operation’s activities;
- — Transparent and open liaison with the local community in order to positively benefit their standard of life and living by the mitigation of potential adverse impacts and through the development of sustainable community projects;
- — Engage and consult with all stakeholders affected by or with an interest in the project;
- — Communicate with stakeholders in a transparent, timely, informative and easily understood manner;
- — Community relations and social policies will be implemented in parallel with environmental and H&S policies in order to safeguard both employees and the surrounding communities in which they live.
The achievement of the above goals will require Altyn to:
- — Identify information and communication needs between the company and its stakeholders;
- — Develop activities to meet these needs;
- — Identify the external stakeholders;
- — Develop material to address the stakeholder information needs;
- — Develop appropriate key messages for both internal and external stakeholders;
- — Develop good relations with both internal and external stakeholders;
- — Regularly assess effectiveness of the programmes;
- — Develop and raise the environmental, H&S and social awareness of the workforce; and
- — Encourage the participation of the stakeholders in the sustainable development of the project and its associated effects.
To enable a consistent approach, the SEP will form an integral part of the company’s Environmental Management System (EMS), Occupational Health and Safety Management System (OHSMS), Social Development (SD), Corporate Social Responsibility (CSR) and Environmental and Safety (E&S) policies. Regular internal and external audits will assist in maintaining high levels of compliance and allow regular review and amendment of the policies, where required in the light of operational experience.
Altyn will consult with stakeholders in relation to the Project and will use appropriate and reasonable resources to ensure that all consultation activities are conducted to the standards required and at appropriate levels of engagement. Stakeholder engagement and participation activities will be will be led and managed by the Chief Executive Officer (CEO), who will devolve the main tasks and responsibilities of the process to the appropriate senior managers at the mine through the Operations Manager of the Sekisovskoye Mine, while retaining overall responsibility and accountability for the programme and its success. A senior manager will be appointed at Sekisovskoye to be responsible for the day to day operation of the process and as the main contact for the stakeholders. This manager will be responsible for the appropriate disclosure of project information, public consultation activities and the management of the Public Grievance procedure.
Stakeholder engagement activities at Sekisovskoye Mine will be led by:
Name: Eric Aripzhanov, Operations Manager
Address: 10 Novostroevskaya Street, Sekisovka Village
Tel.: +7 72331 27920
And coordinated by:
Name: Alem Daniyarov, Stakeholder Coordinator and Government Liaison
Address: 10 Novostroevskaya Street, Sekisovka Village
Tel.: +7 72331 27920
In order to fulfil the requirements of the proposed SEP, it is likely that Altyn will have to provide and employ additional resources to implement the plan. This could include a part time role for a local resident of Sekisovka coordinating day to day stakeholder engagement activities, who would be accessible and approachable by the stakeholders and could support implementation of the grievance mechanism. A senior manager reporting to the GD and CEO would have responsibility for overseeing of all external stakeholder engagement activities, developing of communication materials and coordination with the local liaison officer.
A comprehensive, effective and well-advertised communications procedure to inform stakeholders and the local community is a requirement of both the International Finance Corporation and EBRD Performance Standards and is also a pre-requisite of good business practice and good management. The procedure is designed, provided and implemented to be a method of identifying and addressing the environmental and social issues, questions, concerns and grievances of the stakeholders and the affected community. The aim of the procedure is to address all concerns and issues promptly using an understandable and transparent process which is culturally appropriate. It must be readily accessible to all stakeholders and segments of the affected community at no cost, without fear and without retribution.
Scope of Procedure:
This procedure is open to all community members and stakeholders, including:
Inhabitants of Sekisovka village;
Inhabitants in the wider local community;
Entrepreneurs and owners of local businesses;
Local, District, Regional and National official Government bodies including statutory and regulatory departments;
Non-Government Organizations and concerned International Institutions; and
Financial institutional investors and lenders and other investors and shareholders.
A separate, but essentially identical, internal grievance procedure is open to the following:
Staff and employees of Altyn and its subsidiaries; and
Altyn contractors, suppliers and customers.
Submitting Grievances, Issues and Complaints
Issues can be raised by any of the stakeholders using any of the following methods:
Submission in writing or email or verbally by telephone or in person to the Sekisovskoye Mine offices;
Completion and submission of a public grievance form (see attached);
Notification of grievance through a public participation meeting;
Deposit comments in a suggestion box at the Sekisovskoye offices and mine, which may be made anonymously; or
Direct contact during public meetings, by phone or by e-mail with the responsible senior managers of the operations including the Community Relations Manager, Environmental Manager, H&S Manager and Operations Manager.
Grievances raised under the internal mechanism should initially be routed through the employee’s line manager or the HR department, while grievances raised from contractors, suppliers and customers should be routed through their Altyn business contact.
A grievance procedure has been developed through which complaints, grievances and issues will be managed. When a grievance or complaint is received the following steps will be taken:
Recording of the grievance in the complaints register;
Acknowledgement of the grievance sent to the respondent, including notification of the timescale for investigation;
Appointment of the official responsible for investigation;
Investigation of the complaint;
Internal reporting and discussion of the investigation, with agreement on the way forward;
Notification of result to complainant and suggestion for resolution;
Internal follow up to rectify the root cause of the complaint if appropriate and review of the procedure; and
External follow up with the complainant to discuss satisfaction with the resolution and the process.
The following summarises and adds detail to the above requirements for dealing with complaints and grievances:
Requests for information and complaints should be acknowledged within 5-10 days and, where possible, the information requested should be provided within 10-20 days from acknowledgement date depending on the complexity of information requested or complaints received.
All complaints, and requests for information received will be recorded in a register to ensure that each issue is assigned an individual number and that consistent tracking and corrective actions are carried out. The register will be used by Altyn to analyze the frequency, as well as for prevailing subjects and any recurrent trend of complaint.
All complaint documentation will be kept on a file for a period of at least eight years and then archived. When a resolution to the grievance cannot be provided within the timescales specified above, Altyn will inform the respondent and agree a timescale for completion. Once investigations have been completed, the company will contact the person making the grievance to discuss and agree on the resolution. The company will undertake follow-up monitoring to check that the problem does not recur.
Persons lodging grievance will have an opportunity to maintain their confidentiality. The company will ensure that the name and contact details of the person are not disclosed without their consent and only the team directly working on the investigation of the grievance will be aware of the respondent’s identity.
In the event that resolution of the complaint or grievance cannot be satisfactorily achieved or agreed with the respondent, the complainant would be able to pursue the issue through the normal official Kazakhstan legal framework to achieve a legal remedy, which may be defended by the company in appropriate circumstances.
The SEP will be reviewed at least once a year and revised and updated as required to improve its performance and increase its efficacy. The process itself and its results and records will be audited annually.
Periodical summaries of incidents, complaints and grievances, their investigation and the status of implementation of any corrective and preventive actions will be reported to responsible management at Sekisovskoye. Reporting to external parties such as regulatory will be responsibility of the Sekisovskoye Operations Manager with the support of the CEO who will report to the main Altyn Board of Directors. Reports will be also submitted to EBRD in a form and period to be agreed. An internal newsletter for distribution to employees will be developed to disseminate company and operational information including H&S and environmental issues and other general and social material which may be of interest to the workforce. In addition, a newsletter for distribution to external stakeholders will be developed and published on a regular basis to inform stakeholders of progress and issues at the project. All communications will be made available in both the Kazakh and Russian languages. This will also be made available on the Altyn website. All records and documents will remain available for examination and audit for a period to be agreed.
The records of stakeholder engagement should include the following information:
Place and time of stakeholder participation activities and meetings;
Records of attendance, agendas and minutes of these meetings;
Issues and grievances raised and the actions taken to resolve them, together withconfirmation of those actions and the subsequent closure of the issue;
Records and reporting of unresolved grievances.
The CEO will lead the company’s overall stakeholder engagement process supported by the other Directors of Altyn. Stakeholder participation at the Sekisovskoye mine itself will be led and managed by the CEO, who will devolve the main tasks and responsibilities of the process to the appropriate senior managers at the mine through the Operations Manager of the Sekisovskoye Mine, while retaining overall responsibility and accountability for the programme and its success. Altyn stakeholder engagement activities and processes will form an integral part of its management systems including the planned Environment Management System (EMS), Occupational Health and Safety Management System (OHSMS) and Social and Community Policy. The stakeholder engagement strategy and policies will be communicated and disseminated through regular newsletters, stakeholder participation meetings and the Altyn website with documents available in both Kazakh and Russian. Management tools utilised to manage the stakeholder engagement process will include a stakeholder database, a record of meetings including minutes and attendance details, records of issues, complaints and grievances together with details of investigations and a grievance/complaint resolution logs. All records will be retained and available for inspection and audit. Stakeholder engagement activities will be reported as a regular agenda item at Sekisovskoye management meetings and at Altyn main board meetings on a regular basis as required. The process and its progress will be reported in the Altyn Annual Report and the company’s annual CSR report. Audit of the overall stakeholder engagement process will take place annually and the process itself reviewed and amended as necessary following this audit.