ENVIRONMENTAL STUDIES, PERMITTING AND SOCIAL OR COMMUNITY IMPACT

The Project is located within the Boto concession block, in the south-east of
Senegal. The Boto sector of the OUEST DIKOUJI exploration permit covers 500
HECTAR and is bounded to the east by the Malian border, and to the east by the
Guinean border. The Project is located near the Bantaco commune, Makou
,Department, Kédougou region .

Legal Requirements Relevant to Environmental and Social Aspects

Many legal and regulatory requirements relevant to environmental and social

aspects apply to mining projects. The key applicable legal texts in Senegal for
developing a mining project are:

• Act No. 2003-36 of November 24, 2003, on the Mining Code.

• Act No. 2001-01 of January 15, 2001, on the Environment Code.
• Act No. 1998-03 of January 8, 1998, on the Forestry Code.
• Decree No. 98-164 of February 20, 1998, on the application of the Forestry
Code.
• Decree No. 2001-282 of April 12, 2001, on the application of the
Environment Code .
• Decree No. 2004-647 of May 17, 2004, establishing the terms of application
of Act No. 2003-36 of November 24, 2003, on the Mining Code.
• Act No. 2009-24 of July 8, 2009, on the Sanitation Code.
• Act 81-13 of March 4, 1981, on the Water Code.

The main environmental and social requirements in accordance with the Mining
Code are :
• Completing an ESIA in compliance with the Environment Code and its
regulations (Section 83-CM).
• Creating a mine site reclamation fund at the Caisse de dépôt et de
consignation (Deposit and Consignment Office) (Section 84-CM).

As for the main environmental and social requirements in accordance with the
Environment Code, they are :
• The necessity of completing an impact study and implementing an
Environmental and Social Management Plan (ESMP) (Section L. 44 et seq. of
the Code and its regulations).
• The acquisition of an environmental compliance certification granted by the
Directorate of Environment and Classified Establishments (DEEC) of Senegal
after: i) completion of the ESIA by a certified studies office (by the DEEC); ii)
validation of the ESIA report by the technical committee; and public
hearing. The ESIA’s Terms of Reference must be approved in advance by the
DEEC.
• As part of the environmental assessment, there is a requirement to notify
the authorities of neighbouring countries of a mining operation i) if
operations are liable to have a cross-border impact (section L44 of the
Environment Code), or ii) if the mining operation must use shared
infrastructures or resources (e.g. drawing water from a river on the border).
• Compliance with safe distance rules: a mining operation is a classified
establishment, i.e. it can include facilities deemed classified for the
protection of the environment (grinder, crusher, hydrocarbon or chemical
depot, etc.). Section L 13 stipulates that a first class classified facility
(applicable to the mining project) must be located at least 500 m from a
watercourse, habitations, thoroughfares, and water catchment areas. After
verification with the Directorate of Classified Facilities, it was determined
that pits are also considered classified facilities, but their distance to
watercourses and habitations can be discussed.

• A requirement to consult local communities as part of the ESIA procedure

for a mining project, because the Environmental and Social Management
Plan (ESMP), which is part of the ESIA, must take into account their
concerns (Section L 52-CE). Public consultation is done upstream and
downstream (Section 2 – Order No. 9468 MJEHP-DEEC of November 28,
2001, on the regulation of public involvement in the environmental impact
study).
Upstream procedure (Section 1, Order No. 9468 MJEHP-DEEC of November 28,
2001, on the regulation of public involvement in the environmental impact study):
o Announcement of the initiative via posting at the town hall and/or regional
office .
o Press release (written or spoken).
o Filing of documents at the town hall or local community involved.
o Organization of an information meeting.
o Collection of written and spoken comments.
o Negotiations, if needed.
o Development of the report.

Downstream procedure (Section 6 et seq., Order No. 9468 MJEHP-DEEC of

November 28, 2001, on the regulation of public involvement in the environmental
impact study):
▪ Preparation of public hearing with DEEC and the local community.
▪ Information in the media and any means appropriate to inform the public.
▪ Public hearing in the local community that will host the project.
▪ Collection of comments from the populations.

Environmental and Social Impact Study.

In order to comply with these legal and regulatory requirements as well as the
World Bank Group Guidelines, an environmental and social impact study process
was initiated in June 2015 and to be completed in 2018 for the Project. The
mandate to complete the impact study was awarded to Norda Stelo, who
collaborated with the Senegalese study firm Synergie Environnement.
To properly understand the Project’s human, physical and biological context,
baseline environmental studies on social sanitation conditions, public health,
fauna, flora and biodiversity, surface water and ground water quality, the water
regime, and the cultural heritage were completed in 2015, in the first half of 2016,
and in the second half of 2017. Tailings and waste geochemical characterization
studies were also conducted during these periods.
The highlights of the baseline environmental studies and the impact study are
presented in the following sections. The complete ESIA report contains more
detailed information. It must be noted that the information presented in the
following sections are filed in 2018.
Physical Environment
Landscape
In the permit zone, the landscape’s altitude varies between less than 100 m and
more than 250 m, compared with the flat, low elevation geography of the rest of
the country, where the altitude is rarely over 50 m in the uplands, plains and
alluvial valleys of the sedimentary basin. There are four main landscape entities:
hills, cuirass plateaus, plains, and riverbanks.
Each of these entities is characterized by a specific vegetation cover type, use, or
human activities. Hills are covered with shrubs with a rather limited human
presence, while riverbanks, which are densely wooded, remain bio-corridors and
major biodiversity areas with significant human activities. Plains are the preferred
areas for habitation. Cuirass plateaus often host a grass savannah type vegetation
used for pasture.
Climate
Climate data for the site comes from the closest weather station, which is at
Kédougou. For the purposes of the study, the most recent data from the National
Agency of Civil Aviation and Meteorology (ANACIM) over the 1985-2014 period.
This data comes from the Kédougou station. The climate of the Kédougou region
which hosts the Project is of the Sudano-Guinean type. It is located between 7°
and 12° north latitude and constitutes a transitional zone toward Guinean humid
subtropical climate. The Boto zone’s climate is characterized by seasonal
variations (a four-month humid season and an eight-month dry season),
reinforced by a continental touch with effects discernible late in the dry season. To
obtain climate data specific to the Project’s site, a latest generation
meteorological station was installed in Spring 2016, which provides real-time data.

Temperature
The analysis of monthly temperature averages charts for the 1968-2014 period
shows that temperatures are at their lowest at the end and beginning of the year,
and they gradually increase during the year. There is a relative drop in
temperature in July, August and September and the highest temperatures are
observed in April and May, as shown in the figure below.
Heat Regime at the Kédougou Weather Station (1968- 2014)

Kédougou’s annual temperature average is 28.4°C, and the annual temperature

range average is 14°C. Diurnal variations are between 14°C (April) and 17°C
(December). Kédougou’s temperature extremes during the 1978- 2007 period are
41.4°C (April 2007) and 14.6°C (December 2002).

Relative Humidity
Relative humidity is the ratio of water vapour in the air to the air’s absorption
capacity at a given temperature. It varies based on seasons. During the rainy
season (June to October), it is affected by the monsoon, while during the dry
season, it is affected by continental trade winds.
In the region studied, average annual relative humidity is at its highest in August
(81%) and at its lowest in February (29.1%). Maximum relative humidity is at its
highest in September (97.5%) and at its lowest in February (44.9%). As for
minimum relative humidity, it varies between 64% in August and 13.4% in
February.
 Monthly Relative Humidity (%) in the Kédougou Region (1978-2007)

Winds
Wind conditions are characterized by seasonal variations in prevailing wind
directions, with easterly winds or the harmattan, which blows for practically the
entire year and the maritime trade winds from the west (December, January).
Wind speed rarely exceeds 3 m/s. But the wind can reach speeds of 3.3 m/s in
May and 2.8 m/s in June, decreasing to 1.5 m/s in August.
The harmattan can be felt in this zone starting in February. In May-June, it meets
the monsoon from the Gulf of Guinea, which brings humidity. This is the period of
tornadoes and storms, followed by the rainy season until October. In November,
the monsoon is replaced with westerly winds (maritime trade winds).

Insolation
Insolation is the factor that directly affects temperature. In the region studied,
over the period of 1968 to 2005, average insolation is at its highest in April (9.1
h/d) and May (8.3 h/d), and drops to its lowest in August (6.2 h/d), July (6.7 h/d)
and September (7.0 h/d). The monthly average rarely exceeds 10 h, especially
during the dry season.
Evaporation
Evaporation depends on temperature, insolation, wind speed and relative
humidity. It increases with temperature, insolation and wind speed, but decreases
with relative humidity. In Kédougou, over the period of 1985 to 2014, the monthly
average for evaporated water varies similarly to insolation and temperature. It is
at its highest in March with 307 mm and at its lowest in September with 49 mm.
The annual average during this period is 2,089 mm. There seems to be a slight
increase in evaporation between the period of 1968-2005 and the period of 1985-
2014. This could be partially attributable to the higher temperatures recorded in
the past few years.

Rainfall
Rainfall in the region hosting the permit is distinctive of the Sudanese zone with a
two-season regime: a humid season from June to September-October, and a dry
non-rainy season from November to April. Rainfalls are only observed during five
or six months (May to September or October), and can continue until November
in the event of a late season. Annual pluviometry varies between 600 mm and
1,900 mm. The average pluviometry for the period of 1923-2006 is 1,247 mm,
while the one for the period of 1985-2014 is 1,191 mm. The highest pluviometry
was recorded in 2006 (1,966 mm), and the lowest, in 2007 (685 mm). There seems
to have been a decrease in average annual rainfall from the period of 1923-2006
to the period of 1985-2014. This decrease is mainly observed in June and October.
However, pluviometry is characterized by high internal variability, as the average
annual total can be below average by over 400 mm (1990, 1992, and 2007), or
above average by nearly 950 mm (1954).
 Unimodal Rainfall Regime at the Kédougou Station (1930- 2014)

Surface Water Hydrology

The oeust Dijkoue exploration area is located in the hydrological basin of the
Falémé River, which is a tributary to the Gambie River, and it is the largest
watercourse in the zone.
Gambbie water regime combines a rising stage during the rainy period, and falling
stage during the dry period. The rising stage lasts four months (May to August),
including three months of high water (July, August, and September). Hydrology is
at its highest in September, out of sync with the highest rainfall, which is in
August. This one-month difference is due to periods of capillary retention and
runoff organization. The falling stage starts in September and continues until May,
which is the beginning of the rainy season on the basin.
Gambie River is essentially fed by rain water, and its drainage is characterized by
high irregularity and high interannual variability. Drainage is generally observed
throughout the year. The table below shows the Falémé River’s flow for three
hydrometric stations located on the river, based on recurrences of dry and humid
years. It must be noted that the Fadougou station is located directly downstream
from the location where it is planned to draw fresh water to feed the mine site.
 Gambie River Flow Frequency at the Hydrometric Stations (m3/sec)

Surface water resources in the project zone are mainly used to meet the local
populations’ domestic needs. These mainly include consumption by the
populations and cattle, laundry and swimming. Surface water resources are also
used by local populations for gold washing at small-scale mining sites.
Two sampling campaigns (June 2015 and February 2016) were carried out to
establish the current surface water quality status. Broadly, surface waters are of
poor quality due to the generalized presence of fecal and total coliforms.
However, chemical metrics such as cyanide and heavy metals are generally
present in low or undetectable concentrations.
Hydrogeology
The permit zone is located in the hydrogeological basin of the Falémé River and
the ground water resources depend of the formations in place, of their
weathering, of tectonic accidents such as faults and of food conditions, which
depend on the climate. Two types of ground water formations are observed: high
ground water contained in perched colluvial-alluvial water tables and in clay or
sand alterites, and deep ground water from the fissure or fault zone of the
crystalline or foliated crystalline bedrock.
Ground water is used for the local populations’ domestic needs and provided by
the few existing wells and boreholes in the area.
A series of piezometers were installed in the Boto sector at the location of the
future mining facilities to establish ground water quality before conducting the
project. These piezometers will be used to monitor the water table’s quality based
on the sensitivity of each type of ground water formation.
Biological Environment
Flora
Existing plant formations vary based on topographical units. They include
savannah woodland, as well as grassland savannah, on cuirass plateaus, and dry
woodland and wooded savannah on hills. On more extended slope biotopes,
there are wooded savannahs and open forests, while the thalweg hosts gallery
forests with arborescence around the stream system.
Two main strata are observed: the grass cover made up of the species
Andropogon pseudapricus and Andropogon gayanus characterized by its
vulnerability to bush fires and the wood population including Sudanese and
Sudan-Sahelian species.
Recent studies in the Boto sector list 205 plant species, including 80 woody
species and 125 herbaceous species. In addition to the ecosystemic diversity,
there is also intraspecific diversity. The vegetation cover rate is important
because the average density is 446 individuals per hectare, but it is not
homogenous as it varies between 266 and 136 individuals per hectare, Plant
formations are mainly represented by the shrub to wooded savannah (74.1%)
and the grass savannah (13.5%). Gallery forest and open forest cover
respectively 5.2% and 3.6% of the total area of the study zone.
Out of the identified species, 11 are threatened, 9 are partially protected, and 3
are fully protected, under the national legislation.
A few habitats with an ecological potential were also identified as part of the
ESIA. They are:
▪ The silty banks of watercourses, which include threatened and rare
species, such as Borassuss aethiopum, Celtis toka, Cola laurifoli, Diospyros
mespiliformis, and Saba senegalensis.
▪ Bamboo groves, which are the specific habitats of a threatened species of
the Senegalese flora, Oxytenanthera abyssinica.
▪ The open forest, which includes Holarrhena floribunda.
▪ Wooded savannahs of low plains, which include Acalypha senensis.
▪ Shrub savannahs with boval, which can host Lepidagathis capilliformis,
Indigofera leptoclada and Ozoroa pulcherrima.
Gallery forests include threatened or rare species, such as Cassia sieberiana,
Diospyros mespiliformis, Khaya senegalensis, Saba senegalensis, and Pavetta
cinereifolia. These forest resources are exploited, namely by the local
communities, for various uses: food (edible fruits, culinary usage), medication,
construction, source of energy, etc.
Regarding protected areas, the permit is located in part in the Zone d’Intérêt
Cynégétique (ZIC) (hunting zone) of Falémé. It covers 177.5 ha of this ZIC, which
has a total area of 1,360,000 ha. In a ZIC, the fauna has a partial protection for
its development, but certain species have particular statuses (full protection,
partial protection, protection of endemic species, etc.). Additionally, the permit
zone is located at more than 100 km south-west of Niokolo-Koba National Park
(PNNK).
Figures show the various plant formations and locations where special status
plant species were identified in the study zone.
Plant Formations
 Locations where Special Status Plant Species were Identified

Fauna
The diversity of biotopes or habitats in the zone affects the diversity of the fauna.
This fauna, more specifically mammals, has been subject to a regression during
the past decades due to several natural or human factors, including climate
change, increased rural population, poaching, and disruptive activities such as
small-scale mining.
The wildlife is subject to various threats and constraints, the most significant ones
being small-scale mining activities, which progressively developing in the
Kédougou region, namely near the Adama 5 deposit, Sénégal, the forest agrarian
system in which new lands are progressively being cleared, logging conducted as
part of the exploitation of forest resources, bush fires, transhumance, the early
depletion of ponds and poaching.
The latest inventories from July and November 2015 identified four reptile
species: a garter snake species (Psammophis sp.), the red-sided skink (Trachylepis
(Mabuya) perrotetii), the African spurred tortoise (Centrochelys (Geochelone)
sulcata) and the Nile monitor (Varanus niloticus).
The number of bird species listed in Senegal varies based on the sources.
According to Bird Life international (2016), there are 548 bird species in Senegal,
including 135 species of water birds. Migratory species, i.e. those with populations
that move to other regions on a seasonal basis, account for 44% of avian species
observed in Senegal, or 242 species (Bird Life International, 2016). More than half
of these migratory species are of Palearctic origin and migrate to Senegal during
the northern winter (Coulthard, 2001).
16 bird species in Senegal are internationally considered critically endangered,
endangered, or vulnerable by the International Union for Conservation of Nature
(IUCN, 2016). 17 additional species are considered threatened by the IUCN (2016).
Based on the known distribution area, 13 of these species could be observed in
the Project’s study zone. Out of these, nine are resident species in the region and
three are Palearctic species that winter in Africa. The red-footed falcon is a
Palearctic species that could be observed during its migration to Southern Africa.
A total of 38 fish species from 12 families were listed during the two experimental
fishery campaigns carried out in the study zone by Norda Stelo and Synergie in
July 2015 (high water period) and in December 2015 (recession period). The most
species-rich families are the Mochokidae (nine species), representing nearly 25%
of all captured species, followed by the Cichlidae (five species), the Claroteidae
(five species), the Cyprinidae (five species), the Alestidae (five species) and the
Mormyridae (three species). The other families are represented by one or two
species. By comparison, as part of a study performed in 2011 in the Boto permit
zone, a total of 21 species were collected in the Falémé and Koïla Kabé rivers
(Tropica, 2013). The Cichlidae family was the most represented, with four species,
following by the Alestidae, with three species. The number of fish species
captured was greater during the second fishery campaign, with 30 species from 11
families, compared with 22 species divided into 10 families during the first
campaign, in July 2015.
The composition of the fish communities differs markedly between the two listing
seasons. Out of the 38 fish species listed in total for both listings, less than half, or
14 species, are common to both campaigns. Combining the fishery results for both
seasons shows that fish communities are richer in the Falémé (24 species) and
Balinko (23 species) rivers than in the Koïla Kabé River (13 species). The
communities of the three rivers are relatively more diverse, with only nine
common species out of a total of 38 listed species. Finally, the communities of the
Falémé and Balinko rivers are the ones with the most similarities, with 16 fish
species in common.
According to IUCN (2016), Senegal has 187 mammal species, including sea
mammals (whales, dolphins, manatees). Out of those species, one is extinct in the
wild (scimitar oryx), one is critically endangered (dama gazelle), four are
endangered, twelve are vulnerable and five are near threatened, based on the
IUCN Red List.
The 2015 field inventories identified twelve mammal species in the Project’s study
zone. The most common species are the green monkey and the striped ground
squirrel. Two of these observed species, the Cape bushbuck and the Gambian sun
squirrel, were not reported as present in the region during the inquiry conducted
among local communities. None of species observed have a special status on the
IUCN Red List. However, the hippopotamus is fully protected in accordance with
Decree No. 86-844 on Hunting and Fauna Protection Code.
Meetings with the local communities in 2017 confirmed the presence of
chimpanzees around the majority of villages visited. The presence of chimpanzees
was also confirmed by observing several indications of indirect presence along the
transects made in 2017 on the concession: nests (140 in total), fecies, and scraps
of food. Additionally, images obtained from camera traps confirmed the presence
of 19 species of mammals in the study zone, including the chimpanzee and two
other species with a precarious status: the common hippopotamus and the
Guinea baboon. Based on the results from camera traps, gallery forests represent
the habitat with the richest biodiversity. In total, 20 species of mammals were
identified during the 2017 inventories, which brings the total number of
confirmed species in the study zone to 22 mammals, including the results from
the 2015 inventories (small mammals included). Several additional species were
added to the list of large and medium mammal species present in the study zone,
including the chimpanzee, the jackal, the greater cane rat, the Guinea baboon and
the civet. Out of the 20 mammal species still observed today, five have a special
status in the IUCN Red List: the chimpanzee (endangered), the common
hippopotamus and the lion (vulnerable), and the leopard and the Guinea baboon
(near threatened).
Human Environment
Based on the 2013 census, the population of the Saraya Department was 50,724,
or 33.5% of the total population of the Kédougou region. The Saraya commune,
administrative centre of the department, had a population of barely over 2,700
inhabitants, far less than the rural communities of Bantaco.
The rural community of Bantaco, where the permit zone is located, covers an area
of 500 km2, for an average population density of approximately seven inhabitants
per km2.
In the permit zone, there are two major villages and six hamlets with a total
population of more than 3,000 inhabitants, or nearly 50% of the population of the
rural community.
The population present in the Project zone is relatively young and is 98% Muslim;
majority ethnic groups are, respectively, the Malinkés and the Djallonkés and
Peuls. The settlement of the villages and hamlets was done through the
movement of populations looking for fertile lands.
Human settlements are very dispersed, certainly due to the logic of being close to
fertile lands. Accommodations are mainly huts built in adobe, bamboo and straw.
Agriculture is the main socio-economic activity, followed by small-scale mining,
husbandry – which has clearly declined as a result of cattle theft and recurrent
animal diseases – and fishing, which is done scarcely on the Gambie River or the
Koila Kobé. Agriculture is of the subsistence type, and it barely provides self-
sufficiency due to constraints related to its rudimentary nature, the lack of inputs
and its abandonment in favour of small-scale mining, which unfortunately does
not guarantee gains to compensate agricultural shortfalls.
In terms of health, the predominant diseases are malaria, pulmonary diseases,
infectious diarrhea, and malnutrition and they appear on a seasonal basis. The
main health facility is the Madina Baffé health centre, which faces certain
challenges during the rainy season due to its remote location. In addition, there
are challenges related to the mobility of communities, whose access to the facility
is particularly hindered during the rainy season.
In terms of education, the multitude of temporary shelters and/or multigrade
classes, the insufficient equipment, the lack of support infrastructures, such as
toilets and waterworks, and the difficulty of accessing school supplies due to
poverty are all obstacles to schooling in the zone.
Regarding access to potable water, some villages have boreholes, but traditional
wells, marshes and rivers are the most frequently used sources of water.
It must be noted that the zone, due to its geographical position (borders with
Guinea and Mali) and the existence of small-scale mining sites, which are points of
convergence for foreigners from the region or the bordering countries, is faced
with serious, constantly growing insecurity.
Archaeology and Cultural Heritage
The permit zone fits perfectly in the culture of eastern Senegal, where one of the
most ancient stone industries in Senegal was developed.
Sacred sites including cemeteries, sacred trees, rock shelters and rocks were
listed. Most villages have mosques, but aside from Saroudia, a marabout village
that seems well resourced, the mosques of the other villages are built in bamboo.
Archaeological sites and isolated finds in the zone show a highly variable material
culture and includes lithic industries and pottery industries, predominant in the
assemblages. Grinding stones collected on several sites suggest activities related
to processing grains, leaves, etc., for food or medical purposes.
Waste and Tailings Geochemistry
Tailings
The geochemical characterization of 43 tailings samples from the treatment of
samples representative of the ore was completed in 2016. The main components
of the tailings are iron, calcium, magnesium, aluminium and potassium. Tailings
have low levels of heavy metals (nickel, copper, chrome, zinc and cobalt).
According to Price’s classification (2009) used in Canada to determine acid
generating potential (AGP), the materials that show an acid neutralizing capacity
(ANC) twice as significant as the acidifying potential (AP) (ANC/AP > 2) are not
likely to generate acid mine water. As a whole, samples presented an average AP
of 26.1 kg CaCO3/t and an average ANC of 128 kg CaCO3/t, for an average ANC/AP
ratio of 4.9. Tailings sent to the tailings storage facility are not likely to generate
acid water.
Leaching kinetic tests conducted over a period of 20 weeks on 3 tailings samples
corroborated the absence of a mine drainage potential. Indeed, leachates
collected were still alkaline (pH > 7.0), and sulphate concentrations (indicator of
the extent of sulphide oxidation) at the end of the tests were low (< 50 mg/l).
Regarding heavy metals, nickel and copper concentrations remained low after the
initial leaching period.
Waste
As a whole, the project’s waste does not present an acid generating potential.
Both composite samples used for the leaching kinetic tests also showed an
absence of metal leaching potential.
None of Adama ’s eleven individual samples from non-consolidated horizons
(saprolite and transition) and collected at less than 30 m showed an acid
generating potential. Three non-consolidated material samples collected between
30 m and 40 m from the surface showed an acid generating potential. However,
the average sulphide content of these three samples is 1.36%, which is not very
high compared with many other acid generating mine materials. But these three
samples were from the same drill core. Therefore, one can suspect that these
samples are representative of a very limited portion of the total non-consolidated
materials of the deposit and that they constitute a nugget effect. In fact, samples
collected closer to the surface (19 m -20 m) and deeper (50 m 51 m) in the same
drill core showed very low sulphide contents (<0.01% and 0.03%, respectively),
which tends to confirm the very localized and limited presence of sulphide
materials.
If an acid mine drainage issue were to be identified, mitigation measures would be
implemented to manage potentially acid generating waste, in accordance with the
best environmental practices recognized in the mining industry.
It must be noted that additional static and kinetic tests are currently in progress,
and the results will be used to better document the Adama deposit’s surface
horizon geochemical behaviour.
Potential Impacts of the Project and Mitigation Measures
The Project was designed to minimize impacts on the population and the
environment. First, the 500 m safety distance prescribed by Senegal’s
Environmental Code will be complied with for all project components. Indeed, the
Project’s various infrastructures and components were positioned so that they are
at more than 500 m from permanent watercourses and population centres. These
include waste dumps, TMF, explosive magazines, the process plant, the FWP, etc.
The only exception is the Adama 5 pit, which is located at less than 500 m from
some of the residences.
storage area, the ore processing mill, the open pits and the waste dumps.
Additionally, a linear 50 m wide buffer zone was proposed around the ore hauling
road connecting the Boto 5 pit to the processing plant. Measures will be taken to
ensure the safety of community members who cross this road at the two points
where it crosses paths currently used by the inhabitants. Figure 20.12 shows the
location of infrastructure planned in the original feasibility study and the 500 m
safety radii around them.
Various common mitigation measures were integrated to the Project during its
design. The storage and handling areas for petroleum products and reagents will
have a secondary spill retention capacity, run-off water from waste dumps and
drainage water from pits will be collected and directed to settling ponds to reduce
its concentration of suspended solids and septic waste water will be treated by a
proven technology before it is released in the environment.
A model of the noise level of ground vibration and excess air pressure resulting
from blasts was completed. The noise at the Kouloumindé hamlet will reach levels
of 35 to 42 dBA during the day. These levels comply with the 55 dBA limit for
daytime. Operations at the northern portion of the Boto 5 pit during the night will
produce maximum noise levels of 30 to 39 dBA in the Kouloumindé village. These
levels comply with Senegal’s 40 dBA limit for night time as well as with the
IFC/World Bank’s guidelines (45 dB for night time).
Relocation and Compensation Strategy

While the Project had been designed to minimize encroachment of infrastructures

and components on inhabited sectors and fields, its completion will inevitably
lead to impacts in that regard.
Additionally, lands currently used for agriculture, husbandry or market gardens
and lands that have a good agronomic potential will be impacted by the Project.
This is namely the case for the sectors of the pit, of the waste dump and of the ore
processing mill.
In compliance with Senegalese regulatory requirements and World Bank
guidelines, measures will need to be taken to mitigation the effects of these
involuntary relocations. Thus, a relocation and compensation strategy was
developed for the Project by the specialized firm RePlan, which supported several
developers with relocation and compensation programs in Senegal.
Should the displacement of revenue-generating activities or of people to other
revenue-generating activities be required to complete the Project, AGEM will
implement a relocation and compensation program in compliance with the
requirements of Senegalese regulations and international standards. For the
development and implementation of the provisional relocation and compensation
program, a four-phase process will be implemented:
Phase 1: The provisional program published as part of the current ESIA will be the
main output of this phase.
Phase 2: Comprehensive investigation to document the impacts of relocations and
to identify all affected persons.
Phase 3: Implementation and individual negotiations
Phase 4: Monitoring and support, including implementation of the agreed upon
livelihood restoration program, the vulnerable person assistance program, and the
monitoring-assessment program.
The activities necessary to achieve a comprehensive and operational relocation
and compensation program are as follows:
• Development of a stakeholder engagement strategy specific to relocations
and compensation, including the creation of a forum for discussions about
issues related to land acquisition, relocation, and livelihood restoration.
• Development of a compensation framework, including defining a policy and
eligibility criteria, rules, and specific compensation types.
• Selection of relocation sites and action planning to facilitate the relocation.
• Development of a livelihood restoration program.
• Development of a support plan for vulnerable people and groups.
• Implementation of a grievance management system.
Local Community Development Support Program
The guiding principles of the local community development support program are
as follows:
• Act in partnership with the State, public agencies and specialize non-
governmental organizations
• Invest in the sustainable development of local communities. Act in
partnership with local communities.
• Give preference to one-time investment in projects already identified in
priority action plans and other development plans from the authorities.
• Establish an agreement for each investment.
The priorities that the company intends to support as part of the program are as
follows:
o Population health.
o Water supply.
o Food security.
o Education and training.
o Population safety.
o Income-generating activities and local economy.
o Energy.
o Collective sanitation of villages and districts.
o Leisure and population retention.
 o Income-generating activities.
Reclamation, Restoration and Closure Plan
As required by Senegalese authorities, volume II of the report details the
reclamation, restoration and closure activities planned for the Project. The main
activities planned are the following:
• At the end of operations, all infrastructures and service buildings will be
dismantled, unless the State formally acquires them, without any civil
liability .
• Concrete foundations will be crushed and integrated into the soil in place.
Lands will return to a state similar to their original state.
• Soil characterization will be carried out at locations that may have been
contaminated (e.g. fuel storage zone). Contaminated soil management will
be done in compliance with authorities’ requirements and/or good
practices. Waste dumps, TMF and FWP will be revegetalized using, among
other things, the accumulated topsoil. The use of endemic plant species
that cattle do not feed on will be favoured. It should be noted that the
reclamation strategy will be progressive for waste dumps.
• As soon as water quality is established, a breach will be made in the process
water pond of the TMF to allow the free flow of water. A breach will also be
made in the FWP to allow the free flow of water.
• The open pits’ access ramps will be dismantled. Berms will be made at the
edge of the pits to prevent animals and people from accidentally entering.
• Site monitoring will continue for five years after the end of production. The
quality of water, air and soils will be monitored to confirm that all
parameters studies return to their pre-mining levels. The success of
revegetation will be monitored to make sure the new vegetation is self-
sufficient.