Environmental Social Policy

This document sets out our beliefs and requirements as well as our approach to E&S. The framework covers the activities of all employees, (sub)contractors and other stakeholders working for TASC. We also encourage business partners and stakeholders to act in accordance with this framework or a similar standard and seek to support them to achieve this, where appropriate. At a site or investment level, more detailed, specific management systems are in place to cover daily operations and manage risks.

Our Approach:

1. Our operations should be safe for employees, (sub)contractors, the communities in which we operate and the environment.

2. We aim for a zero-harm approach – we commit to reporting, investigating and learning from incidents and near misses.

3. We recognize the importance and fragility of the environment – we commit to seeking to minimise our impact on the environment through upholding high E&S standards.

4. A risk-based approach is the most suitable to manage the complex environments and geographies in which we operate.

5. All our operations should be compliant with the applicable legislative and regulatory regimes and we ensure that the appropriate processes, resources and systems are in place.

6. We are committed to respecting all internationally recognized human rights – we will seek to conduct our business in accordance with the UN Guiding Principles on Business and Human

7. We monitor, track and disclose our performance to continuously improve our E&S

8. We commit to communicating appropriately with all key

Requirements:

1. Legal Compliance
TASC manages its operations, equipment and activities in compliance with relevant E&S laws, regulations and permits. Where specific laws or industry practice do not exist, a sensible approach to reduce risks is applied.

2. Excluded Activities
Neither TASC nor any of its affiliates will, directly or through its subsidiaries, enter into any of the excluded activities specified in the Exclusion List attached hereto as Annexure A.

3. Risk Management
TASC adopts a risk-based approach to E&S and operations management by identifying, monitoring, assessing and mitigating risks to an acceptable level as determined by business requirements.We ensure that high risk activities, such as transportation (for example by truck, rail, ship, mobile equipment) are well controlled by permits and/or safe systems of work.

4. Leadership, Training and Competency 

• TASC encourages staff to intervene, report unsafe situations so as to prevent occupational illnesses and incidents, whether directly involved or not.
• TASC provides appropriate and ongoing E&S information, training and supervision to employees, contractors and visitors to enable them to carry out their duties competently.

5. Management Systems
5.1 We establish, where appropriate, E&S management systems to cover:

• Personal and process safety risks
• Provision of suitable personal protective equipment (PPE), sanitary facilities, first aid kits and drinking water
• Environmental protection
• Health risks and exposure to potential health hazards
• Security related topics
• Complaints and grievance management
• Alcohol and drug testing
• Selection and management of contractors and suppliers

6. Targets and Measurement
6.1 We set measurable targets to improve E&S performance in which following should be considered, where relevant:

• Lagging and leading E&S related metrics (e.g. lost time injuries, process safety metrics, near misses)
• Noise, odour and other complaints
• Energy, waste and water management
• Pollution prevention

6.2 We collect and analyse business specific KPIs to monitor and measure E&S perfromance.

7. Human Rights

7.1 TASC is committed to respecting all internationally recognised human rights, including those contained in the International Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.

7.2 We aim to ensure a diverse and inclusive workplace, free from discrimination regardless of age, gender, race, cultural heritage, ethnicity, sexual orientation, religion or disability.

7.3 We ensure compliance with legal requirements regarding working hours, conditions and pay and additional attention to vulnerable or marginalised groups who may be at greater risk of adverse human rights impacts.

7.4 Forced, trafficked or child labour is prohibited and we do not tolerate any physical or verbal abuse or workplace harassment.

7.5 TASC respects employees’ rights to join, form or not to join a labour union and commit to bargaining in good faith with their representatives.

8. Security

8.1 We ensure that appropriate measures are in place to manage travel to high-risk destinations.

8.2 We aim to establish workplace security aimed at preventing violence, intimidation and other negative E&S conditions arising from internal and external sources.

8.3 TASC ensures that security management is consistent with international standards, local policies and laws.

8.4 We manage security arrangements in line with the United Nations Basic Principles for the Use of Force and Firearms by Law Enforcement Officials and the Voluntary Principles on Security and Human Rights where appropriate.

8.5We aim to mitigate any adverse impacts our security arrangements have on local communities.

9. Due Diligence

9.1 TASC applies a risk-based approach to E&S due diligence and focuses on the most severe potential E&S impacts.

9.2 We work towards conducting on-going human rights due diligence and ensuring that rightsholders and communities impacted by our business activities have access to remedies.

9.3 We undertake E&S impact assessments, where applicable.

10. Stakeholder Engagement and Communication

TASC develops two-way communication channels with relevant stakeholders to ensure awareness and understanding of our E&S frameworks and we build capability to improve prevention and mitigation of adverse impacts where appropriate.

11. Incident Reporting and Management

TASC will establish and test E&S incident management plans for major accident hazards e.g. for process safety events, loss of containment, transport emergencies etc. We also aim to have in place a process to report, investigate and learn from E&S incidents and high potential near misses to ascertain root causes and avoid reoccurrence.

12. Reviewing Performance

TASC initiates periodic audits of operations to benchmark progress against these and other requirements, using suitably qualified personnel.

Annexure A – List of Excluded Activities

African Development Bank Exclusion List

• Production of alcoholic beverages, tobacco, and luxury consumer
• Production or trade in weapons, ammunition and other goods used for military or paramilitary
• Production, trade in, or use of:
  • nuclear reactors and related products, radioactive materials (except in the case of medical materials and quality-control equipment where the radioactive source is in small quantities and is adequately shielded), combustible elements not exposed to irradiation (cartridges for reactors);
  • unbonded asbestos fibres or other products with bonded asbestos as a dominant material; or
  • harmful substances that are subject to international phase-outs or bans (including pharmaceuticals and pesticides classified as Class Ia (extremely hazardous); Class Ib (highly hazardous); Class II (moderately hazardous); and ozone-depleting substances.
• Trade in wildlife or wildlife products regulated under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).
• Speculative trade or investment in platinum, pearls, precious stones, gold and related
• Gambling, casinos and equivalent enterprises to the extent that such activities constitute the main business of the borrower / recipient.
• Use of logging equipment in unmanaged primary tropical
• Economic activities involving harmful or exploitative forms of forced labour (1) and/or child labour (2) as defined by international conventions and/or national regulations.
• Production or trade in any product or activity deemed illegal under host country laws or regulations or international conventions and agreements.

1 Forced labor means all work or service, not voluntarily performed, that is extracted from an individual under threat of force or penalty.

2 child labor means the employment of children that is economically exploitive, or is likely to be hazardous to, or to interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

European Development Finance Institutions (EDFI) Harmonized Exclusion List

EDFI Members will not finance any activity, production, use, distribution, business or trade involving:

• Forced labor(3) or child labor (4)
• Activities or materials deemed illegal under host country laws or regulations or international conventions and agreements, or subject to international phase-outs or bans, such as:
  • Ozone depleting substances, PCBs (Polychlorinated Biphenyls) and other specific, hazardous pharmaceuticals, pesticides/herbicides or chemicals;
  • wildlife or products regulated under the Convention on International Trade in Endangered Species or Wild Fauna and Flora (CITES); or
  • Unsustainable fishing methods (e.g. blast fishing and drift net fishing in the marine environment using nets in excess of 2.5 km in length).
• Cross-border trade in waste and waste products, unless compliant with the Basel Convention and the underlying regulations.
• Destruction (3) of High Conservation Value areas (4)
• Radioactive materials (5) and unbounded asbestos
• Pornography and/or prostitution
• Racist and/or anti-democratic media
• In the event that any of the following products form a substantial part of a project’s primary financed business activities (6):
  • Alcoholic Beverages (except beer and wine);
  • Tobacco;
  • Weapons and munitions; or
  • Gambling, casinos and equivalent

3 Forced labor means all work or service, not voluntarily performed, that is extracted from an individual under threat of force or penalty as defined by ILO conventions.

4 Persons may only be employed if they are at least 14 years old, as defined in the ILO Fundamental Human Rights Conventions (Minimum Age Convention C138, Art. 2), unless local legislation specifies compulsory school attendance or the minimum age for working. In such cases the higher age shall apply.

3 Destruction means the (1) elimination or severe diminution of the integrity of an area caused by a major, long-term change in land or water use or (2) modification of a habitat in such a way that the area’s ability to maintain its role is lost.

4 High Conservation Value (HCV) areas are defined as natural habitats where these values are considered to be of outstanding significance or critical importance (See http://www.hcvnetwork.org). 5 This does not apply to the purchase of medical equipment, quality control (measurement) equipment or any other equipment where the radioactive source is understood to be trivial and/or adequately shielded.

6 For companies, “substantial” means more than 10% of their consolidated balance sheets or earnings. For financial institutions and investment funds, “substantial” means more than 10% of their underlying portfolio volumes.

Furthermore, the following investment exclusions are considered as a minimum common requirement by all EDFI members for all new Direct Financing (Debt or Equity), for Indirect Equity through new commitments to investment funds, and new dedicated lending (7) via financial institutions:

• Coal prospection, exploration, mining or processing
• Oil exploration or production
• Standalone fossil gas exploration and/or production (8)
• Transport and related infrastructure primarily (9) used for coal for power generation
• Crude Oil Pipelines
• Oil Refineries
• Construction of new or refurbishment of any existing coal-fired power plant (including dual)
• Construction of new or refurbishment of any existing HFO-only or diesel-only power plant (10) producing energy for the public grid and leading to an increase of absolute CO2 emissions (11)
• Any business with planned expansion of captive coal used for power and/or heat generation(12)

7 ”Dedicated lending” is defined for these purposes as loans conditioned by a use of funds clause specifying that such financing will be used for one or more of the purposes described.

8 Gas extraction from limnically active lakes is excepted from this exclusion.

9 “Primarily” means more than 50% of the infrastructure’s handled tonnage.

10 For indirect equity through investment funds, investments (up to a maximum of 20% of the fund) in new or existing HFO-only or diesel-only power plants are allowed in countries that face challenges in terms of access to energy and under the condition that there is no economically and technically viable gas or renewable energy alternative.

11 I.e. where energy efficiency measures do not compensate any capacity or load factor increase.

12 This does not apply to coal used to initiate chemical reactions (e.g. metallurgical coal mixed with iron ore to produce iron and steel) or as an ingredient mixed with other materials, given the lack of feasible and commercially viable alternatives.