Vedanta Resources plc Second Progress Report on the ...
Transcript of Vedanta Resources plc Second Progress Report on the ...
Vedanta Resources plc Second Progress Report on the implementation of the Scott Wilson recommendations
Final Version
Vedanta Resources plc
3rd February 2012
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Executive Summary Vedanta Resources is committed to implementing all of the Scott Wilson recommendations within a wider program of fully integrating a new Sustainability framework and policies consistent with a multinational metal and mining enterprise operating 53 sites on four continents. This is the second progress report against the recommendations made by Scott Wilson in their report dated 17th November 2011. It will be publically available at http://www.vedantaresources.com/sustainability/scottwilson.html
At the Corporate / Group level, having modified the governance structure in the last period we have continued the development with the introduction of a new ExCo Subcommittee on Sustainability with a view to driving improved performance. The committee is chaired by Mr. MS Mehta the Group CEO and its members are subsidiary company CEOs /COOs and the company’s Chief Sustainability Officer. The Vedanta Board Sustainability Committee met twice during the latter half of 2011 and discussed sustainability performance, the sustainability framework, driving safety, capacity building, IT and target setting. The committee approved the sustainability framework and individual policies relating to social, human rights, biodiversity, water management, HIV/Aids, supplier and contractor management, energy & carbon management (including climate change) and stakeholder engagement with updates to our HSE policy. The ExCo Subcommittee met twice and focussed on safety issues within the plants reviewing specific audits of equipment permit to work systems that had been led by the corporate sustainability team.
During the last six months the Corporate Sustainability team has completed and rolled out 8 new policies and 34 Technical Standards as part of the Vedanta Sustainability Framework. It should be noted that all subsidiary companies have management systems in place and 29 out of 33 major sites are certified to ISO14001 and OHSAS 18001. Each site has carried out a GAP analysis and actions plans are in place to close any gaps found. The remaining technical standards will be rolled out as part of this programme during February and March and a suite of Guidance Documents is begin created to offer more details support in certain areas. To support this process a training programme has been developed and all CEOs have attended the summary session, while 17 operations and project managers plus 44 sustainability specialists are in process of completing the three day course. Of the eleven corporate recommendations we consider seven to be closed, three to be making excellent progress and one (the final sign off audit) to be completed in the future as per the original schedule.
During the period significant progress has been made at the group company level. Our new Project Development process is supported by the implementation of Technical standards on the Production of ESIAs to International Standards, Stakeholder Engagement, Water, Biodiversity, Cultural Heritage, Grievance Mechanisms and Land and Resettlement. These standards include specific sections on Vulnerable Social Groups. We have engaged competent environment and social consultants to support our work in this area. Further, we are reviewing all the land we own in order to assess risk to biodiversity. Of the seven company level recommendations we consider three to be completed and the remaining four to be well advanced.
At plant in Lanjigarh, we have continued to operate at or close to capacity without incident during the six month period. The plant has an excellent safety record and during the period was certified to ISO 50001 adding to the certifications of the environmental and safety systems to ISO 14000 and OHSAS 18001. During the period the HSES GAP analyses were completed as was the government approval of the site emergency preparedness and response plan which meets the Vedanta technical standard which reflects the UNEP requirements. Of the eleven recommendations we consider eight to be closed, two to be progressing very well and one (regarding the proposed expansion) to be on hold pending government approval.
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Table of Contents
Executive Summary _________________________________________________________ 1
Table of Contents ___________________________________________________________ 2
Background ________________________________________________________________ 4
Section 1 Corporate Level Progress __________________________________________ 6
Recommendation 2.5.7 Sustainability Committee _________________________________ 6
Appendix 1 – Meeting Minutes – Sustainability Committee ___________________________________ 6
Appendix 2 – Meeting Minutes – ExCo Sustainability Subcommittee ____________________________ 6
Recommendation 2.5.8 Chief Sustainability Officer ________________________________ 6
Appendix 3 – Job Description - Chief Sustainability Officer ____________________________________ 7
Recommendation 2.5.4 Value Statement ________________________________________ 7
Recommendation 2.5.2 Code of Conduct ________________________________________ 7
Recommendation 2.5.6 Policies ________________________________________________ 7
Appendix 4 – Policies _________________________________________________________________ 10
Appendix 5 – Vedanta Sustainability Framework Mapping Analysis versus IFC & ICMM ____________ 10
Appendix 6 – Sesa Goa and Balco Sustainability Policies _____________________________________ 10
Appendix 7 – Summary of Company GAP Assessments ______________________________________ 10
Appendix 8 – Vedanta Sustainability Framework Rollout Programme __________________________ 10
Appendix 9 – Vedanta Sustainability Framework T1 Training Programme (T1 Summary) ___________ 10
Recommendation 2.5.3 Stakeholder Engagement ________________________________ 10
Appendix 10 – Stakeholder Engagement Technical Standard _________________________________ 11
Recommendation 2.5.13 Reporting ____________________________________________ 11
Recommendation 2.5.8 Sustainability Committee Oversight _______________________ 11
Ref - Appendix 2 – Minutes of ExCo Sustainability Subcommittee _____________________________ 12
Recommendation 2.5.9 Professional Competency Review _________________________ 12
Appendix 11 – Sustainability Framework Training Rollout Programme (T1 Summary) _____________ 12
Appendix 12 – T1, T2 & T3 Training and Attendees _________________________________________ 12
Recommendation 2.5.16 Human Rights Policy ___________________________________ 13
Appendix 13 – Vedanta Resources plc Human Rights Policy __________________________________ 13
Appendix 14 – Guard Training Course Material ____________________________________________ 13
Recommendation 2.5.24 External Audit ________________________________________ 13
Internal Audit Programme _______________________________________________________________ 13
Appendix 15 – Draft Self Assessment Questionnaire ________________________________________ 13
Appendix 16 – Audit Programme 2012-13 ________________________________________________ 13
Final External Audit ____________________________________________________________________ 13
Section 2 Company Level Progress _________________________________________ 14
Recommendation 2.5.15 International Standard Best Practice ______________________ 14
Appendix 17 – New Project Risk Assessment ______________________________________________ 14
Recommendation 2.5.11 Land Management ____________________________________ 15
Appendix 18 – Biodiversity Risk Assessment ______________________________________________ 15
Recommendation 2.5.23 Register of Social and Labour Incidents ____________________ 15
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Appendix 19 – Social and Labour Incident Register _________________________________________ 15
Recommendation 2.5.12 Environmental Communication __________________________ 15
Appendix 20 – Stakeholder Engagement Plan – VAL-Lanjigarh ________________________________ 16
Recommendation 2.5.17 New project planning and development ___________________ 16
Appendix 21 – New Project Planning Process and Site Closure Management Standard ____________ 16
Appendix 22 – Vedanta Social Policy ____________________________________________________ 16
Ref - Appendix 10 – Stakeholder Engagement Technical Standard _____________________________ 16
Ref - Appendix 17 – New Project Database including Risk Assessment _________________________ 16
Recommendation 2.5.20 Vulnerable Social Groups _______________________________ 16
Appendix 23 – Vedanta Human Rights Policy ______________________________________________ 17
Appendix 24 – Conducting ESIAs to International Standards Technical Standard _________________ 17
Recommendation 2.5.22 Cultural Heritage ______________________________________ 17
Appendix 25 – Vedanta Cultural Heritage Technical Standard ________________________________ 17
Section 3 Lanjigarh Progress ______________________________________________ 18
Recommendation 3.3.20 Environmental and Social Management ___________________ 18
Appendix 26 – VAL–Lanjigarh HSE Policy _________________________________________________ 19
Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan _____________________________ 19
Recommendation 4.5.8 Grievance Mechanism __________________________________ 19
Appendix 28 – Vedanta Grievance Technical Standard ______________________________________ 20
Appendix 29 – Grievance Summary Data Analysis and Actions Taken __________________________ 20
Recommendation 3.3.3 Housekeeping _________________________________________ 20
Recommendation 3.4.3 Proposed expansion ____________________________________ 20
Recommendation 3.3.79 Disaster management plan ______________________________ 20
Appendix 30 – Lanjigarh Emergency Preparedness Management Plan _________________________ 21
Appendix 31 – Lanjigarh Emergency Preparedness Plan – Safety Handbook _____________________ 21
Appendix 32 – Lanjigarh Emergency Preparedness Plan – Drill Plan ____________________________ 21
Recommendation 3.3.32 Retrenchment Planning ________________________________ 21
Recommendation 3.3.48 Contractor accommodation _____________________________ 21
Appendix 33 – Vedanta Supplier and Contractor Management Technical Standard _______________ 22
Appendix 34 – VAL–Lanjigarh Contractor Accommodation Standard Operating Practice ___________ 22
Recommendation 4.5.5 Dust reduction plus health monitoring _____________________ 22
Recommendation 4.6.8 Additional livelihood programmes_________________________ 22
Recommendation 4.6.12 Integrated Community Development _____________________ 23
Appendix 35 – Integrated Livelihood Development Plan _____________________________________ 25
Recommendation 3.3.63 Contractor and Community Health and Safety ______________ 26
Ref - Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan _________________________ 26
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Background Vedanta Resources is a London Stock Exchange company with major assets in mining and processing
of copper, zinc, and aluminium and iron ore and oil and gas. Operations are located primarily in India
with mines and processing plants in South Africa, Zambia, Namibia, Liberia, Australia, Ireland and Sri
Lanka.
Vedanta Resources is committed to implementing all of the Scott Wilson recommendations within a
wider program of fully integrating a new sustainability framework of policies and standards
consistent with international standards such as the IFC, ICMM and OECD and consistent with
operating a multinational metals, mining and energy enterprise with 53 sites on four continents.
In 2010, the Vedanta board set the sustainability goal to be recognized internally and externally as
the global benchmark company in sustainability performance.
Of our 33 major metal and mining sites, 29 are approved to ISO14001 and OHSAS 18001 and Sesa
Goa, Hindustan Zinc Sterlite and Cairn India are companies quoted on major stock exchanges. Group
companies operate under their own Board of Directors.
This is the second progress report and details the actions we have taken since the Scott Wilson
Report was published on 17th November 2011. It contains supporting documentation where
relevant and possible.
At the corporate level we have developed an appropriate model for our business that has strong
subsidiaries and many operations in developing countries.
This model develops the Responsible Stewardship of all our the assets we manage including their
effect on the health and safety of our people and the environment but it goes further and
encourages us to develop Strong Relationships with all our stakeholders, be they shareholders or
lenders, employees, neighbours, members of our industry, the governments where we operate or
third parties with valid interests in our business. The goal of this second pillar is to create platforms
for creating sustainable development opportunities and hence support the third pillar in which we
The Vedanta
Sustainable
Development
Business Model
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aim to find ways to Add and Share Value with each of our stakeholder groups and thus meet the
Board’s sustainability objective.
Following the restructuring of a Sustainability Department in late 2010 and changes to our
governance structure in early 2011, we have embarked on a programme to make sure we manage
responsibly across all our businesses. We are fulfilling the recommendations of the Scott Wilson
report by the creation and group-wide implementation of a sustainability framework of eight
Vedanta policies and thirty five standards aligned to our sustainability model that will lead to a
consistency of process and to superior performance.
We intend to continue to develop our external reporting and to this end, we have taken the
opportunity to align our sustainability reporting calendar with the financial reporting timetable. We
published our Sustainable Development Report 2010-11 in June 2011.
http://www.vedantaresources.com/sustainability/griindex.html. This report was externally assured
by Det Norske Veritas (DNV) and received a B+ level against the GRI reporting framework.
Following our first six monthly progress report, Scott Wilson visited our sites at VAL - Lanjigarh and
Hindustan Zinc. They reported that of the eleven corporate level recommendations two were closed,
and two we substantially complete, three were progressing, three needed more attention and one
was not due being the final sign off audit. At the company level, of the eight recommendations, all
were progressing but extra attention was needed. This reflects the fact that we had focussed our
efforts on creating the complete framework before rolling it out. At Lanjigarh, one recommendation
was closed out and the rest will require further work as per the original timetable. During the last six
months, we have completed the sustainability framework and have rolled it out to all subsidiaries
who have reviewed the requirements against their own management systems. Where gaps have
been identified actions plans are now in place. We believe that seven corporate recommendations
are now closed and three are progressing on target (the final audit is still not due).
At the company level, we have made good progress on all seven recommendations and three are
closed as they have been covered by the sustainability framework and will be implemented on new
projects. We are in a good position to close the remaining four items in June. Most depend on the
completion of the implementation process of the Sustainability Framework and as previously
discussed this is progressing well.
At Lanjigarh, we have continued to make significant strides. A new position of Sustainability Officer
has been created and the team have made good progress such that we believe that eight of the
eleven recommendations are now closed and the rest in a good position for closure in June.
To strengthen the corporate systems we have recruited a head of assurance. Reporting to the Chief
Sustainably Officer, this position is responsible for developing the corporate sustainability assurance
programme that will begin implementation in March 2012. This is described in more detail later in
the report.
The following three sections describe in details our progress at the Corporate, Company and
Lanjigarh levels.
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Section 1 Corporate Level Progress During the period between June and December 2011, significant progress has been made. We have
continued to enhance sustainability governance with the formation of the new ExCo Subcommittee
of CEOs/COOs which meets monthly and supports the ExCo and board appointed Sustainability
Committee. The Sustainability Framework is substantially complete with all new policies approved
by the Sustainability Committee which has fully oversight of all sustainability matters. These policies
and their supporting technical and management standards have been progressively rolled out to the
companies. To support this process a training programme has been developed and all CEOs and
senior management have attended the summary session, while 31 operations and project managers
as well as 67 sustainability specialists will complete the full three day course.
Recommendation 2.5.7 Sustainability Committee 2.5.7 The title of the HSE Committee should be changed to the Sustainable Development Committee and its terms of reference expanded to reflect the breadth of its role covering all aspects of the environmental and social sustainability of the Group. Target: May 2011
Following a recommendation by the HSE committee, the Board of Directors evolved the HSE
Committee into the Sustainability Committee at their meeting on 17th March 2011. The
Sustainability Committee met twice between July and December. We now consider this committee
an integral part of the management of the company along with the other board appointed
committees. The committee has full ownership to oversee the process of implementation of the
Scott Wilson recommendations and approved the interim submission of information in September
2011.
During the period, we have formed an ExCo Sustainability Subcommittee, led by the Vedanta CEO
with subsidiary CEO/COOs as members. This committee meets monthly to champion the
implementation of the Sustainability Framework in particular improvements in our safety
performance.
We consider this recommendation closed.
Appendix 1 – Meeting Minutes – Sustainability Committee
Appendix 2 – Meeting Minutes – ExCo Sustainability Subcommittee
Recommendation 2.5.8 Chief Sustainability Officer 2.5.8 Appoint an appropriately qualified Chief Sustainability Officer with international experience to direct and coordinate the HSE, CSR and related functions. The CSO will act through single points of
contact in each subsidiary company. Target November 2011
A Chief Sustainability Officer was appointed on 8th November 2010. The Chief Sustainability Officer’s
position reports directly to the Vedanta Resources Chief Executive Officer.
The Chief Sustainability Officer’s team includes specialists, who head; sustainability assurance,
health and safety, environment and community investment. The Chief Sustainability Officer’s job
description is attached and his organisation chart and his operational contacts are shown below.
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We consider this recommendation closed.
Appendix 3 – Job Description - Chief Sustainability Officer
Recommendation 2.5.4 Value Statement 2.5.4 Revise the wording of the Value Statement on Sustainability to state: “We aim to contribute to the social and economic welfare of the communities where we work and to protect and conserve the environment.” Target: January 2011
Closed by Scott Wilson (Review of Progress Report - June 2011)
Recommendation 2.5.2 Code of Conduct 2.5.2 The preamble to the Code, “How We Do Business”, should include reference to local communities as a key element affecting Vedanta’s reputation along with customers, shareholders, competitors and suppliers. Target: January 2011
Closed by Scott Wilson (Review of Progress Report - June 2011)
Recommendation 2.5.6 Policies 2.5.6 Develop a series of policies to realise the aims stated for each of the four sustainability areas (environmental stewardship, nurturing people, health and safety and empowering communities). The policy statements should be succinct, should reflect best international practice and reflect a commitment to continuous improvement. Annual targets for progress and reporting should be considered wherever possible. Noise should be included as a policy issue. Target: To be implemented in time for the 2011 Annual Report and Sustainability Report to be published in June 2012.
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Under the umbrella of the Company’s, Vision, Values, Code of Conduct and Sustainability Model, the
Sustainability framework of policies, management and technical standards has been substantially
completed. Our policies are publically available at
http://www.vedantaresources.com/sustainability/our_strategy.html
This framework has been mapped against IFC and ICMM performance standards and guidelines and
our external assurance provider states the following:
“As part of the development and implementation of the Vedanta Sustainability Framework, ERM has
mapped the elements of the Framework to meet IFC and ICMM requirements. The IFC and ICMM
requirements are generally met by the Vedanta Framework elements as set out in the mapping
document attached. It is noted that some of the more technical elements of IFC Performance
Standard requirements are currently being addressed through the development of additional
Standards and/or Guidance Documents. It is anticipated that the remaining technical elements will
have been addressed during the first half of 2012”.
The management teams at our group companies, led by their CEO have reviewed the 8 policies and
34 (of 35) standards that have been rolled out to date (Our Sustainability Data Management
Technical Standard remains to be rolled out in March after a decision is taken on the choice and
implementation of a new Sustainability IT system ). A summary of the GAP analyses performed by
each group is attached and time bound action plans are in place to close the gaps identified. To help
with the closure of any gaps and to include some of the fine details within the IFC guidance notes
and EHS Guidelines, a series of Guidance Notes is being created to support the subsidiary
companies. These will be completed and be in full operation by June. As examples of the alignment
taking place within the group the Sustainability Policies of Sesa Goa and Balco can be found in
Appendix 6.
In order to enhance capacity across the group a training programme has been developed. The
summary programme has been attended by all CEOs and full three day programme by Operations
and Project Managers as well as Susintailbity specialists. Two courses have taken place, one in India
and one in Zambia and the third is planned again for India in February. The Sustainability specialists
had a further two days of train the trainer sessions to allow them to take the course back to their
companies for all to benefit. The roll out programme is attached in Appendix 9
Within the Corporate Sustainability team, the head of assurance has been instrumental in preparing
the Sustainability audit programme. This will consist of a Self Assessment Questionnaire to be
completed by all group companies and approved by their respective CEO annually in April, and then
again at the end of each following financial year. Following this first step, a programme of site visits
will take place to verify the group company’s records and confirm their assessment of compliance
with the Vedanta Sustainability Framework. A description of the framework and our Sustainability
Policies can be found on our website at
http://www.vedantaresources.com/sustainability/our_policies.html.
To better manage the systems associated with our sustainability performance we have completed
the selection process for a world class IT system that will be implemented at all group companies
during the rest of 2012. As the implementation progresses we will reduce our reliance on manual
systems and we expect it to be a major benefit to the company.
We expect the system to be fully implemented and all gaps closed by June 2012 at which time we
believe that this recommendation will be closed.
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The policies in the framework are titled as follows:
The global processes and management standards are titled as follows:
Group Policies
Responsible Stewardship Strong Relations Adding Value
HSE Policy
Biodiversity Policy
Water Management Policy
Energy and Carbon Management Policy
Social Policy
Supplier and Contractor Management Policy
Human Rights Policy
HIV/Aids Policy
Global Management Processes & Management Standards
GLOBAL MANAGEMENT PROCESSES
New Projects, Planning Processes & Site Closure
Stakeholder Materiality and Risk Management
Incident Reporting and Investigation
Management of Change
Documentation & Records Management
Corrective & Preventive Action Management
Auditing and Assurance
Acquisitions, Divestment and Joint Venture Due Diligence
MANAGEMENT STANDARDS
Compliance and Other Requirements
Leadership, Responsibilities and Resources
Objectives, Targets and Performance Improvement
Competency, Training and Awareness
Management Review and Continual Improvement
Audit and Assurance
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The technical standards, designed to support the policies are titled as follows:
Appendix 4 – Policies
Appendix 5 – Vedanta Sustainability Framework Mapping Analysis versus IFC & ICMM
Appendix 6 – Sesa Goa and Balco Sustainability Policies
Appendix 7 – Summary of Company GAP Assessments
Appendix 8 – Vedanta Sustainability Framework Rollout Programme
Appendix 9 – Vedanta Sustainability Framework T1 Training Programme (T1 Summary)
Recommendation 2.5.3 Stakeholder Engagement
2.5.3 Adopt internal procedures to ensure that all requests for information from stakeholders (including investors, NGOs, international organisations and the press) are dealt with a timely manner. We see this as an important part of a wider programme to inform and communicate with all stakeholders. To assist with transparency Vedanta should maintain a register of enquiries and responses and provide a summary in their Annual Sustainability Report/website. Target: April 2011
A key part of the new sustainability framework is the social policy and the supporting technical
standards. These standards require all operations to identify stakeholders and determine
engagement plans together with a method to record and reply to stakeholder enquiries and
grievances.
Technical Standards
Responsible Stewardship Strong Relations Adding Value
Health Management
Safety Management
Environmental Management
Conducting ESHIA to International Standards (includes EMPs)
Waste Management
Biodiversity Management (includes EMPs)
Water Management
Energy and Carbon Management
Land and Resettlement Management
Security Management
Emergency and Crisis Management
Transport and Logistics Management
Sustainability Data Management
Cultural Heritage
Supplier and Contractor Management
Employee Consultation & Participation
Stakeholder Engagement
Social Investment Management
Grievance Mechanisms
HIV/Aids Management
Site Closure
.
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At the Corporate level, we are developing our Stakeholder Engagement Plan and have set up an
email address [email protected] for enquiries which are registered. This address was
publicised in our latest sustainable development report and is available on our website at
http://www.vedantaresources.com/sustainability/griindex.html
Additionally, enquiries or correspondence to our Investor Relations group are also registered and
receive a reply.
An analysis of enquires received shows that of 163 emails received between January 2011 and
January 2012. Of this total, 30 are requesting information about Sustainability topics while 57 are
companies sending unsolicited marketing information, 32 are requests for speakers and 15 requests
for employment. Replies have been sent to all requests for information and employment while for
others appropriate action was taken or they did not require action. This process is now part of our
Sustainability Management system.
We consider this recommendation closed.
Appendix 10 – Stakeholder Engagement Technical Standard
Recommendation 2.5.13 Reporting 2.5.13 Report, where possible, on Group environmental and social performance as a whole and seek to benchmark performance against industry best practice and seek assurance from appropriate bodies with industry and sustainability expertise. Target June 2012
In their July progress report, Scott Wilson commented on the need for external benchmarking and this is in process. This recommendation will be completed by June 2012.
Recommendation 2.5.8 Sustainability Committee Oversight 2.5.8 The corporate Sustainability Development Committee should continue to ensure that subsidiary companies take a consistent approach to promoting sustainable development in accord with international best practice by monitoring performance, lesson learning and dissemination of best
practice. Target November 2011 The board appointed sustainability committee has full oversight of all issues regarding sustainability.
The committee approved the submission of documentation to Scott Wilson in September now
formally contained in this document.
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The committee has met four times so far in this financial year and has been instrumental in the
formation of the ExCo subcommittee as its executive arm. These meetings now from an important
part of the Vedanta Board’s oversight of sustainability issues and will form a permanent part of the
company’s governance structure.
During its meetings the Sustainability Committee approved our submissions to Scott Wilson
including this report and discussed the following subjects: Vedanta and subsidiary sustainability
performance, the sustainability framework and its roll out to subsidiaries, driving safety, capacity
building, IT and subsidiary target setting.
During its meetings, the ExCo subcommittee focussed on safety and reviewed the results of a
number of specific plant and equipment audits across the group. It also instigated an audit of near
misses. Both these actions have led to direct reduction of risk to our employees and contractors as
improvements have been implemented.
Sustainability oversight is fully within the Sustainability Committee remit and is an ongoing part of
the management of the company; as such we consider this recommendation closed.
Ref - Appendix 2 – Minutes of ExCo Sustainability Subcommittee
Recommendation 2.5.9 Professional Competency Review 2.5.9 Keep under review the full range of HSE and CSR competencies required across the business and consider the need for additional training, as appropriate, in relation to the IFC Performance Standards and Guidelines, human rights, vulnerable groups and the GRI Mining and Metals Sector
Supplement. Target November 2011. Across the group we employ a wide range of competent trained business and sustainability
professionals. To raise awareness of a training programme has been developed for management,
project and operations staff and technical experts to build capacity around the requirements of the
Vedanta Sustainability Framework and to raise awareness of international standards focusing on the
IFC performance standards, guidance notes and EHS guidelines.
All CEOs and senior managers have attended a summary course. 17 operations and project staff and
44 sustainability professionals have attended the two full courses held to date. This programme
included a section to train trainers who have returned to their respective companies and have begun
relaying the training and information from the courses to all staff. This programme complements the
wide range of training the company provides via the human resources development programme and
the roll out of the Vedanta Sustainability Framework.
While we have made significant progress, this work is ongoing and we expect it to be closed by
June 2012.
Appendix 11 – Sustainability Framework Training Rollout Programme (T1 Summary)
Appendix 12 – T1, T2 & T3 Training and Attendees
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Recommendation 2.5.16 Human Rights Policy 2.5.16 Adopt a specific human rights policy demonstrating its commitment to the UN Declaration of Rights and procedures to ensure its implementation. This should be communicated to all stakeholders
via its web site. Target November 2011.
Following the modifications to the Vedanta Code of Conduct and as a part of the Vedanta
Sustainability Framework we have developed and published the Vedanta Human Rights Policy,
reflecting our commitment to the UN Declaration of Rights. It was approved by the sustainability
committee in July 2011 and has been rolled out across the group as part of the Sustainability
Framework roll out programme. It is available for view at the Vedanta website at
http://www.vedantaresources.com/sustainability/our_policies.html
As part of our security management programme, training is given to guards at our group companies
and as part of the development of professional competencies we are developing training for all
employees.
Appendix 13 – Vedanta Resources plc Human Rights Policy
Appendix 14 – Guard Training Course Material
We consider this recommendation to be closed and future actions to be part of the roll out of the Sustainability Framework.
Recommendation 2.5.24 External Audit 2.5.24 Undertake an audit of Group and Company environmental and social performance against international standards (IFC, ICMM, OECED) after 12 months of implementing the recommendations in this report (i.e. June 2012). Recommendations which are not implemented will be included in a Remedial Action Plan and their compliance reviewed every 6 months. Target: November 2012/June 2013
Internal Audit Programme
An important part of the sustainability organisation at group level will be an assurance team to
develop and implement the group sustainability assurance programme. The new leader of this team
is in place and the Self Assessment Questionnaire will be sent to all CEO’s in February for completion
and signing at the end of the financial year. This will become an annual process and signal
compliance with the requirements of the group sustainability policies and standards within the
sustainability framework or detail a corrective action plan. In this way, a systematic programme of
continuous improvement will be created and compliance will be assured to the Vedanta Board and
to other stakeholders.
By the time of the June progress report, we expect to have the Self Assessment Questionnaires
completed and have begun the site visit programme. This will be a significant step in moving to the
last part of the programme and completing the final external audit.
Appendix 15 – Draft Self Assessment Questionnaire
Appendix 16 – Audit Programme 2012-13
Final External Audit
We fully expect the external audit to be commissioned within the suggested timeframe.
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Section 2 Company Level Progress During the latter half of 2011, significant progress has been made at the group company level. All
our new projects are following the new management standard for New Project Development; this
process is supported by the implementation of the following technical standards: Production of
ESIAs to International Standards, Stakeholder Engagement, Water, Biodiversity, Cultural Heritage,
Grievance Mechanisms and Land and Resettlement. These standards include specific sections on
vulnerable social groups. We have engaged competent environment and social consultants to
support our work in this area at each new project.
Further, all companies have carried out a GAP analysis between their own policies and management
systems and the requirements of the Vedanta Sustainability Framework. Where gaps have been
identified time-bound actions plans are in place. Examples of the Sesa Goa and Balco’s own
sustainability policies can be seen in Appendix 6.
Of the seven company level recommendations we consider three to be completed and the
remaining four to be well advanced.
Recommendation 2.5.15 International Standard Best Practice 2.5.15 Produce and test EIAs and EMPs against the IFC Performance Standards and ICMM best practice and define clear links between the EIAs, EMPs and Environmental Management Systems. Specifically EIAs should be expanded in relation to biodiversity and habitat identification, the identification of cultural heritage (scheduled and non-scheduled sites) and social and human rights impacts. Vedanta should commission independent reviews of one or more major EIAs each year in order to ensure compliance with IFC Standards. Immediate implementation
All our new projects will follow the Vedanta Sustainability Framework of Policies and Technical
Standards. As such they are aligned to the IFC Performance Standards and Guidance notes together
with the EHS guidelines.
Specific standards include:- New Projects, Planning Processes & Site Closure Management Process;
Stakeholder Materiality and Risk Management Standard; Land and Resettlement Management;
Security Management; Cultural Heritage; Stakeholder Engagement; Social Investment Management
and Grievance Mechanisms.
We have assessed our new project sustainability risks and the summary is attached in Appendix 17.
We will continue to test our EIAs against the IFC performance standards as a part of our audit
process and believe that all new ESIAs will meet the requirements of the Vedanta Framework.
We consider that using our sustainability framework as a guide all new projects will meet international standards and as such we consider this recommendation to be suitable for closure in July when the ESIAs will be available.
Appendix 17 – New Project Risk Assessment
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Recommendation 2.5.11 Land Management 2.5.11 Develop a policy and implementation practices to more proactively manage land in their ownership in order to maximise environmental gains and promote biodiversity. This would include the development of environmental management plans for all non-operational land and the carrying out of habitat surveys for all new sites prior to development. Target: To be implemented in time for the 2011 Annual Report and Sustainability Report to be published in June 2012
In order to promote the management of water and biodiversity, we have made a review across all
the company operations and mapped all our sites using the IBAT mapping tool
https://www.ibatforbusiness.org/ developed by a consortium of NGOs. This process has led to a risk
assessment which is being used to set priorities for the development of Biodiversity Action Plans. Of
the 47 sites we have reviewed using the tool; we have defined eight sites as a higher risk and
requiring further investigation because they are situated within one kilometre of an area of high
biodiversity value. A further fourteen sites are categorised as a medium risk as they are situated
between two and ten kilometres of a high biodiversity area and the remaining 25 sites are of lower
risk.
Further, we have joined forces with the World Business Council for Sustainable Development to help
refine the granularity of their World Water Tool for better use in India. This will take some time to
complete after which we intend to map all our sites and develop a risk assessment for water.
Whilst we have Biodiversity Action Plans in place at some of our higher risk sites, we expect BAPs
to be in place for all higher risk sites by June 2012 at which time we expect to close this item.
Appendix 18 – Biodiversity Risk Assessment
Recommendation 2.5.23 Register of Social and Labour Incidents 2.5.23 Maintain a register of major social and labour incidents at their plants and report to VRL Target:
April 2011
All group companies have developed a reporting process and database of incidents beginning 1st
April 2011 or earlier in the case of Lanjigarh. A monthly report is supplied to Vedanta Corporate,
where a full register is kept. The complete register is circulated back to all companies within the
group for awareness, learning and risk management purposes. We now consider this a fully
implemented part of our business management system.
We consider this recommendation now implemented the item to be closed.
Appendix 19 – Social and Labour Incident Register
Recommendation 2.5.12 Environmental Communication 2.5.12 Communicate environmental monitoring regimes at plants and regularly report to stakeholders, including local communities, on their environmental performance, benchmarking this against international standards (e.g. IFC Guidelines) and reporting in their 2012 Sustainability Report. Target November 2011
Following our Stakeholder Engagement Technical Standard, we are producing Stakeholder
Engagement plans at all group companies.
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Within these plans, we have developed meeting schedules and registers to maintain the records that
we already had in place and we are developing our Environmental and Social Performance Report.
We consider that this recommendation is progressing well and will be completed by June 2012.
Appendix 20 – Stakeholder Engagement Plan – VAL-Lanjigarh
Recommendation 2.5.17 New project planning and development Standard Community Consultation Processes within new project development 2.5.17 Develop a standardised approach to community consultation for new developments which responds to IFC guidance and communicate this to all stakeholders via its web site. Target November
2011
Solid progress has been made to develop the new project management process as a part of the
sustainability framework and the group is committed to following international standards,
particularly the IFC standards for producing EIAs and conducting public consultation for new
projects.
All our new projects will follow the New Project Development and Site Closure Process as part of the
Sustainability Framework. This is supported by our Stakeholder Engagement Technical Standard
which adheres to the IFC performance Standards and guidance notes. This requirement has been
included in the training courses given to operations, project and sustainability specialists.
We consider that this recommendation is now included in our Sustainability Management
programme for all new projects and thus closed.
Appendix 21 – New Project Planning Process and Site Closure Management Standard
Appendix 22 – Vedanta Social Policy
Ref - Appendix 10 – Stakeholder Engagement Technical Standard
Ref - Appendix 17 – New Project Database including Risk Assessment
Recommendation 2.5.20 Vulnerable Social Groups 2.5.20 Adopt a specific policy in relation to engagement with and assistance to social groups that may be vulnerable to change and communicate this to all stakeholders on its web site. Target November 2011
As part of the Stakeholder Framework we have adopted a Human Rights policy to support the
statements in our Code of Conduct. The “Conducting ESIAs to International Standards” technical
standard requires human rights considerations to be taken into account for all new projects.
This requirement has been included in the training courses given to operations, project and
sustainability specialists. Further, based on the results of the IFC mapping project that we used to
ensure the Sustainability Framework meets international standards, we are developing a technical
standard / guidance note in for Vulnerable Social Groups to provide more detailed support to our
group companies in this area.
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We expect the Technical Standard / Guidance note to be added to the Sustainability Framework
and we believe this recommendation will be closed in July.
Appendix 23 – Vedanta Human Rights Policy
Appendix 24 – Conducting ESIAs to International Standards Technical Standard
Recommendation 2.5.22 Cultural Heritage 2.5.22 In developing new sites adopt a standardised approach to the identification of sites of cultural heritage value involving formal documentary sources, site surveys and community consultation. Target
November 2011
Our New Project Development Process is a key part of the Sustainability Framework and as such it
must be considered in all new projects. Included in this process and specifically in the Conducting
ESIA to International Standards and Cultural Heritage Technical Standards are the Vedanta
Requirements for all companies and projects to follow.
Whilst the scope of the assessment will depend on the nature and scale of the project and
sensitivities in terms of cultural heritage, all our new projects require a cultural heritage feasibility
study to be carried out
This requirement has been included in the training courses given to operations, project and
sustainability specialists.
As this is now a part of the management system, we consider that this recommendation is now
closed.
Appendix 25 – Vedanta Cultural Heritage Technical Standard
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Section 3 Lanjigarh Progress At Lanjigarh the team takes all matters of Sustainability very seriously and a Sustainability Officer has
been appointed to increase focus in this area. The organisation chart for this position is shown
below.
A focussed effort to complete the improvement program at the VAL refinery in Lanjigarh has been
undertaken and the results to date are described below. These include a systematic gap analysis of
Health and Safety and, Environment and Social management against the Vedanta Sustainability
Framework and IFC and ICMM standards, the implementation of a grievance cell that operates a
weekly surgery managed by the VAL Lanjigarh community relations team, improvements to the
filtration system and air monitoring together with a housekeeping drive and a review and update of
the disaster management plan in line with UNEP recommendations.
Recommendation 3.3.20 Environmental and Social Management 3.2.20 Undertake a systematic gap analysis of the EMS against the Industry Best Practice criteria and update it accordingly. Target: April 2011 A gap analysis study with reference to Indian law, IFC Performance Standards, ICMM guidelines,
OECD guidelines and the UNGC has been completed by ERM India. Within this report 126 items were
checked which has led to two overarching actions to be completed in the coming six months. These
are:
i) the creation of an Environmental and Social Management Plan to summarise all the work we
have completed to develop the VAL-Lanjigarh sustainability management system including
guidelines for contractor camps, development of organisational capacity, procurement of
local content, waste management and resource efficiency. The goal is to create a world class
management programme.
ii) The creation of a stakeholder engagement plan to include all the work we have completed
on our grievance mechanism, engagement with all stakeholders and the continued
development of an integrated development plan for the area.
This work will be completed by June 2012 when we expect this recommendation to be closed.
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Appendix 26 – VAL–Lanjigarh HSE Policy
Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan
Recommendation 4.5.8 Grievance Mechanism 4.5.8 Establish and strengthen a simple and accessible grievance mechanism by which villagers can identify any concerns about the operation of the refinery by using the village coordinators already deployed by VAL. Target: May 2011
The public grievance system has been implemented in Lanjigarh by the Rehabilitation & Peripheral
Development Advisory Committee (RPDAC), we have implemented our own public grievance and
open communication mechanism. Every Friday, the vice president of human resources holds an open
forum to hear issues and complaints & take-up the issues with concerned parties.
A total of 634 people were seen between April 2011 and January 2012. In case of issues related to
the government, such as; a local community requesting a special relief package over and above the
package previously announced by the government and agreed during the public consultation before
the plant was built, then the matter is referred to the Government of Orissa for direction and
Vedanta facilitated meeting with the person and the government representatives. In the cases of
requested for employment we were able to help some people but not all. All other issues have been
resolved amicably.
The Grievance Mechanism and documentation has been upgraded and modified based on the
feedback given during last Scott Wilson visit. All the grievances have been complied into categories:
education, land, livelihood, financial support, employment etc. The manual registers are being
replaced with computerized documentation for easy access.
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Appendix 28 – Vedanta Grievance Technical Standard
Appendix 29 – Grievance Summary Data Analysis and Actions Taken
We consider this now recommendation to be a part of the ongoing management of the site and as
such it is closed
Recommendation 3.3.3 Housekeeping
Closed by Scott Wilson Review of Progress Report - June 2011
Recommendation 3.4.3 Proposed expansion
If the expansion of the refinery is to proceed, a supplementary report be prepared to augment
and update the existing EIA, thus meeting international best practice. This report would be
used to guide further development and would be made available to key stakeholders (No
defined target date = dependent upon court approval to proceed).
The Expansion Project currently remains ‘on hold’ and there is no certainty when the court order
might be lifted. The company has committed to preparing a supplementary report, which should
reflect the requirements of Recommendation 2.5.15 (company level example on international best
practice) and the detailed findings of the updated gap analyses required for Recommendation 3.3.20
(Lanjigarh).
As and when the project is approved we shall implement the action of a supplementary report.
Recommendation 3.3.79 Disaster management plan
Review the Disaster Management Plan against recognised industry guidance (such as the
ICMM / UNEP publication “Good practice in emergency preparedness and response”, 2005)
and upgrade its emergency prevention and response arrangements including improved drill
and simulation exercises (Original target = April 2011).
Alumina refineries are classed as potentially hazardous plants and are therefore obliged to have a
Disaster Management Plan (DMP) that deals with any significant risks including those associated
with ‘off-site’ facilities like red mud and ash ponds.
VAL-Lanjigarh has updated its Disaster Management Plan. The revised DMP has been submitted to
the Director of Factories and Boilers, the regulatory body, and final approval is awaited.
We believe that the plan meets the Vedanta Technical Standard, Emergency and Crisis Management
and the Emergency Preparedness criteria of the UNEP recommendations as follows:
1. Roles & responsibilities - covered on page number: 87 of DMP.
2. Risks & hazards - covered on page numbers: 2,28,31,92 of DMP.
3. Emergency plan - covered on page numbers: 71, 77 of DMP.
4. Identify required response tasks – covered in page numbers: 87-91 &132-142 of DMP.
5. Match task to resource availability - covered in page numbers: 144, 161 of DMP.
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6. Improve the Plan using drills and integrate it into the overall Community Plan – see Stakeholder
Engagement Plan and Drill Plan
7. Endorsement & approval – internally approved, government approval received.
8. Emergency plan training – covered in page numbers: 77 of DMP
9. Establishing procedures for periodic testing – see Drill Plan.
10. Communicate to general community - as part of communication "Safety hand book” was made.
Appendix 30 – Lanjigarh Emergency Preparedness Management Plan
Appendix 31 – Lanjigarh Emergency Preparedness Plan – Safety Handbook
Appendix 32 – Lanjigarh Emergency Preparedness Plan – Drill Plan
We consider Emergency Preparedness to be a part of the ongoing management of the site and as
such it is closed.
Recommendation 3.3.32 Retrenchment Planning 3.2.32 Develop suitable and sufficient retrenchment plans to mitigate the adverse impacts of future suspension or closure of the refinery on both direct and indirect employees. Target: November 2011
There is a robust an established legal framework and retrenchment can only be made after obtaining
approvals from the government (except termination on account of disciplinary/integrity issues). The
procedure and standing orders that have been set up by the government and are jointly signed by
VAL & the Government of Orissa’s director of factories have been and will be followed.
We consider management of retrenchment to be a part of the ongoing management of the site
and as such it is closed.
Recommendation 3.3.48 Contractor accommodation 3.3.48 Undertake a gap analysis for contractors’ labour accommodation against IFC/EBRD guidance and any serious deficiencies addressed. VAL should therefore amend its contractual documentation to specify minimum expectations for contractors in regard to labour accommodation, and then enforce contractors’ adherence to its specified requirements. Target: November 2011
The labour camps in Lanjigarh were built by contractors on private land and it is not possible for us
to remove or dismantle these camps at present. However, our CSR team regularly visit the camps to
ensure that proper hygiene & sanitation conditions are maintained. We continue to organize health
camps through our mobile health units. We are developing a camp checklist for the CSR specialists to
use on their visits and this will be used to maintain standards if the camps are used in future. We
have also developed a VAL standard operating practice for the minimum requirements of contractor
facilities in line with IFC guidelines. This will be used when the expansion project begins.
We consider management of contractor accommodation to be a part of the ongoing management
of the site and as such it is closed
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Appendix 33 – Vedanta Supplier and Contractor Management Technical Standard
Appendix 34 – VAL–Lanjigarh Contractor Accommodation Standard Operating Practice
Recommendation 4.5.5 Dust reduction plus health monitoring 4.5.5 Review the issue of sporadic dust nuisance, seek to reduce such pollution and monitor both dust emissions and incidence of respiratory infections in the immediate locality of the refinery. Target:
November 2011
In 2011, as part of our continuous improvement programme, US$10 million was invested for the
installation of vacuum dust collection systems, bag filters, various dust suppression systems such as,
sprinklers, dry fog etc. and continuous online monitoring is being made for ambient air quality as per
international norms. This information is being displayed at the plant gate and is continuously online
at the government offices in Bhubaneswar.
Scott Wilson commented that this is item can be closed with the plan for roadside dust control. To
this end, alumina transportation by road has been stopped completely and the road transfer of
bauxite from the nearby railway station has already been reduced. Presently, one full train per day is
now received directly in the plant reducing dust by 33% and by March 2012. All trains will be
received in the plant ending vehicular movement for bauxite transportation by road. In the
meantime, we will continue to use trucks with tarpaulin covers and with water sprinkling to
minimize any dust.
We consider this recommendation now implemented and the item closed.
Recommendation 4.6.8 Additional livelihood programmes 4.6.8 Give further consideration to accelerating livelihood training programmes for villagers via self-help and business start-up support, especially in those villages close to the refinery and monitor local employment creation in these villages and the Lanjigarh block. Target: November 2011
We are continuing to work with the LPADF and others in the region to help support people in the
villages near to our refinery.
In addition, to the work we do with the LPADF, a detailed action plan has been prepared in
consultation with the Government of Orissa and a Human Development specialist. The basic
objective of the plan is to improve livelihood opportunities by linking Government schemes with the
needs of the area. Vedanta’s role will be to provide a bridge between the villagers and the
government and to ensure the adoption of the latest systems in agriculture, health, marketing agro
products etc.
VAL-Lanjigarh is also developing many other important projects, the first is the new school nearby,
which now has 450 pupils and a new infant section that opened recently and which is
oversubscribed. It should be noted that over 50% of the pupils are from the tribal communities. The
second major project is a hospital, open and free to anyone, that treats about 150 people per day,
market days being particularly busy. Details of other projects are available on the VAL website
http://lanjigarhproject.vedantaaluminium.com/community.htm
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We consider that this recommendation is part of 4.6.12 and we consider this is now an integrated
part of the site management and thus the item closed.
Recommendation 4.6.12 Integrated Community Development 4.6.12 Work together with local government to develop and publicise an integrated rural development strategy for the area. Target: April 2012
Vedanta is a long term player and will continue to actively seek ways to help develop the area
around Lanjigarh. The work of the LPADF and the coordination with the Dongria Kondh Development
Agency (DKDA) will play an important role in the future. Further, our Integrated Village Development
Plan is attached and further discussions are in progress to merge the finding with the Livelihood
Development plan discussed above.
The wider community
The wider community is vital to the success of any business like ours. For Vedanta, a company with
strong Indian roots, working in our homeland; we feel a strong obligation for our business to be a
force for good and development in the community as well as being a commercial success. It is the
practical manifestation of our view that we must add to India’s development, not only through our
business activities, but also through active “bottom-up” community programmes.
Our community engagement vision is:
“Sustainable development of the local community living in the core and periphery habitations and
emerging as a responsible corporate partner of the government and the people at large”
Since the earliest days of the project we have had a professional community outreach department
with staff specialised in diverse areas including a professional anthropologist. They are supported by
a network of outreach workers recruited from the Dongria Kondh and the Kutia Kondh. In addition
to the jobs we have created directly, our strategic areas of focus in community development are:
Infrastructure development:
This has included extensions to rural areas through the building 50 kms of approach roads to isolated
villages, culverts, dams, check dams, 43 tube wells eight community centres and seven places of
worship, in addition to the general improvements to local roads, rail, water and power systems for
business reasons. We have also invested extensively in the development of the town of Lanjigarh.
Access to water is a key issue in this drought prone area and the 2007 District Statistical Handbook
records that there were no villages in Lanjigarh that had access to tube wells and other sources of
piped water at that time.
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Education, sports and culture
We have set up 36 childcare centres, have supported the State of Orissa’s fortified food supplement
scheme in 400 pre primary schools (known as Aganwadi) in Kalahandi and 678 in Rayagada. We are
opening a mid-day meals centre to provide food and reduce school drop out in the 166 schools of
Lanjigarh. We have supported 31 tribal schools to get their first computers and in addition have
built the only English language school in Lanjigarh with 400 students of which roughly half are from
tribal families.
We are very committed to the maintenance and enrichment of local culture and festivals and
support religious and cultural events as well as provide and sports grounds and activities.
Health and sanitation
We have partnered with the government to significantly upgrade the Lanjigarh hospital and we have
built our own hospital on site for staff which also provides free services for the community catering
for about 200 patients a day of who over 50% are from the tribal groups. We provide mobile health
units to travel to the villages of the Dongria Kondh and other surrounding areas. We also run health
awareness and education camps over a wide area to promote interventions on child feeding,
vaccinations, family planning, and protection against malaria and communicable diseases. As the
paragraphs below show, we are making progress in improving health indicators. The hospital houses
the only equipment for detecting sickle cell anaemia in Orissa.
Sustainable livelihoods
Our programme of support for sustainable livelihoods covers several areas. Firstly, we work with
farmers to improve their agriculture. We have a vegetable growing project with 150 farmers in 13
villages, sunflower cultivation with 150 farmers in 8 villages and for the first time in Kalahandi, the
commercial production of organic cotton with 150 farmers in 8 villages. For women, we have
project Sashakti to help women’s self employment and have provided sewing machines and skills
training and specifically for tribal women we have built on their traditional skills to make and market
leaf plates that are sold in surrounding districts and about 600 participate in the project.
All this work includes a degree of environmental awareness and the protection of natural resources
and bio-diversity is also part of our programmes. For us this work is not philanthropy or old style
benevolent paternalism. It is community investment and development. Which means we want to
see real returns for the inputs we make and by working with others in key projects, we have helped
achieve measurable improvement in community well being through active partnerships. For
example;
The rate of child immunization in Kalahandi has risen from 35% to 71% between 2005 and 2008,
Child malnutrition has dropped from 58% in 2005 to 31% in 2008.
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Diagrammatic depiction of Vedanta’s Community Development methodology concerning participation
and feedback of consultations.
School attendance rates have increased from 45% in 2005 to 70% in 2008 while drop out rates have reduce from 70% to 20% over the same period and we have played a role in this progress.
We can also measure the increase in the incomes of the farmers and women we work with and they are significant for a district where half the population use to live on less than $US1 per day.
We have subjected our community programmes to independent review by the non-profit Xavier
Institute of Social Service and to further expand on our performance.
In addition, we have reviewed our programmes in light of the priorities set by the Millennium
Development Goals (MDG) as an important international benchmark of social performance. For
example, we contribute to six of the 10 MDG goals such as eradicating poverty and hunger,
empowering women and combating HIV/AIDS, malaria and other diseases. We have helped double
the local immunisation rate and 20,000 people have attended the HIV/AIDS awareness workshops
we sponsor. As part of our planning for future engagement and to understand the needs of the
poorest in a district which has a history of drought and famine; we have commissioned an
independent study into food insecurity and vulnerability in Lanjigarh and it give a good insight into
the lives of the poor who are our neighbours.
The diagram below shows the feedback loop we use to develop the community projects we design
and implement.
We feel that this recommendation is now closed.
Appendix 35 – Integrated Livelihood Development Plan
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Recommendation 3.3.63 Contractor and Community Health and Safety 3.3.63 Undertake a gap analysis against the occupational and community health and safety
requirements set out in the Lender’s Industry Best Practice criteria (specifically the IFC’s General and applicable sector EHS Guidelines) and take appropriate measures to address any outstanding gaps. Target: November 2011
Vedanta is committed to providing a safe working environment for all our employees and contractors and for surrounding communities. The safety management systems at Lanjigarh have been certified to OHSAS 18001 and we remain dedicated to continuous improvement. The VAL Lanjigarh HSE Policy is attached. A gap analysis has been completed as a part of Recommendation 3.2.20 Environment and Social Management and actions arising are included in the action plan associated with this analysis, see Appendix 17 This work will be completed by June 2012 when we expect this recommendation to be closed.
Ref - Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan