MYA: Myingyan Natural Gas Power Project

Stakeholder Engagement Plan Project Number: 48368-001 August 2018

MYA: Myingyan Natural Gas Power Project

Prepared by Sembcorp Myingyan Power Company Limited

The stakeholder engagement plan is a document of the borrower. The views expressed herein

do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may

be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website. In preparing any country program or strategy, financing any project, or by making any designation

of or reference to a particular territory or geographic area in this document, the Asian

Development Bank does not intend to make any judgments as to the legal or other status of any

territory or area.

GROUP COMMUNITY RELATIONS SEMBCORP INDUSTRIES LTD

Doc. No. SCI-HSSEC-SMP-001

Rev. No. 1.3

Effective Date: 23 Aug 2018

Project :

Myingyan 225MW Gas-fired Combined Cycle

Power Plant Project

Title:

Stakeholder Engagement Plan

Owner :

SEMBCORP MYINGYAN POWER COMPANY LIMITED

MYINGYAN CCGT POWER PLANT

STAKEHOLDER ENGAGEMENT PLAN

Doc No. Rev. No. Title

SCI-HSSEC-SMP-001 1.3 Stakeholder Engagement Plan Framework

Prepared By:

Approved By:

Revision History

Name Designation Signature Date

Tan Shi Han Jessica Group Community Relations-

Executive

28 July 2016

Name Designation Signature Date

HC Chew Group Community Relations-

Senior Vice President

28 July 2016

Date Version Reason for revision Author Approver

(Signature)

17 Jan

2018

1.1 Include Kenneth Ng as the

Counterpart at Group level

Kenneth Ng

23 Aug

2018

1.2 Adjust the plan for

operational stage

Kevin Heng

24 Aug

2018

1.3 Inserted Grievance

Committee from Additional

Documents to Appendix E

Kenneth Ng





CONTENTS

1 INTRODUCTION 5

1.1 CONTEXT OF THE DOCUMENT 5

1.2 SCOPE, PURPOSE AND OBJECTIVES 5

1.3 STRUCTURE OF THIS PLAN 6

2 PROJECT DESCRIPTION 7

3 KEY STANDARDS AND LEGISLATION 9

3.1 REPUBLIC OF THE UNION OF MYANMAR LEGISLATION 9

3.2 INTERNATIONAL FRAMEWORK 9

3.2.1 International Finance Corporation Performance Standards 9

3.2.2 Asian Development Bank Safeguard Policy Statement 10

3.3 SEMBCORP CORPORATE POLICIES 10

4 PROJECT STAKEHOLDERS 12

4.1 STAKEHOLDER IDENTIFICATION 12

4.2 STAKEHOLDER ISSUE IDENTIFICATION 14

4.3 STAKEHOLDER MAPPING 14

5 STAKEHOLDER ENGAGEMENT PLAN 16

5.1 PRE-OPERATIONS ENGAGEMENT 16

5.2 OPERATIONS PHASE ENGAGEMENT 17

5.3 INFORMAL ENGAGEMENT 18

5.4 STAKEHOLDER COMMITTEE 19

5.5 STAKEHOLDER DATABASE 19

6 GRIEVANCE MECHANISM 21

6.1 OBJECTIVES 21

6.2 THE PROCESS 21

7 MONITORING AND REPORTING 25

7.1 MONITORING OF STAKEHOLDER ENGAGEMENT ACTIVITIES 25

7.2 EVALUATION OF STAKEHOLDER ENGAGEMENT ACTIVITIES 25

8 ROLES AND RESPONSIBILITIES 27





8.1 PROJECT MANAGEMENT TEAM 27

8.2 COMPANY EMERGENCY RESPONSE TEAM (CERT) 29

9 APPENDIX 30

9.1 APPENDIX B: STAKEHOLDER TEMPLATE 30

9.2 APPENDIX C: STAKEHOLDER DATABASE TEMPLATE EXAMPLES 31

9.3 APPENDIX D: GRIEVANCE LOG AND CLOSE-OUT TEMPLATE 32

9.4 APPENDIX E: GRIEVANCE COMMITTEE 33

9.4.1 PURPOSE OF GRIEVANCE COMMITTEE 33

9.4.2 GRIEVANCE COMMITTEE COMPOSITION 33

9.5 APPENDIX F: GRIEVANCE DATABASE 39




SCI-HSSEC-SMP-001 1.3 Stakeholder Engagement Plan

THIS DOCUMENT IS THE PROPERTY OF SEMBCORP INDUSTRIES LTD. NEITHER WHOLE NOR ANY PART OF THE DOCUMENT SHALL BE DISCLOSED,

PRODUCED, TRANSMITTED IN ANY FORM OR BY ANY MEANS WITHOUT THE PRIOR WRITTEN CONSENT OF THE OWNER. Page 5 of 39

1 I

NTRODUCTION

1.1 CONTEXT OF THE DOCUMENT

Sembcorp has been selected by the Ministry of Electricity and Energy (MOEE)1 of the

Government of Myanmar (GOM) as a private sector Independent Power Producer (IPP) to

develop a 225MW Combined Cycle Gas Turbine (CCGT) power plant in Myingyan Township,

Mandalay Region, Myanmar (the Project). The Project is comprised of the following

components:

A 225MW CCGT power plant;

A 230kV overhead transmission line (construct but to handover to MOEE); and

Water supply pipeline, wastewater discharge pipeline and water intake and pumping

station.

The Project will use an efficient form of CCGT power generation technology, which is designed

for high reliability and efficient operation. The electricity generated by the Project, from natural

gas, will be sold under a 22-year Power Purchase Agreement (PPA), as agreed with the

Electric Power Generation Enterprise (EPGE)2.

The Project will proceed with international financing provided by Asian Development Bank

(ADB), International Finance Corporation (IFC), and other banks that have adopted the

Equator Principles (EPs).

This document forms the Stakeholder Engagement Plan (SEP) for the operations phase of

the Project. The SEP identifies the Project stakeholders and describes how these stakeholders

will be engaged throughout the operations phase. The SEP is a “living document” that will be updated and refined as the Project progresses. This will include a revision every 5 years after

the beginning of the operations phase.

1.2 SCOPE, PURPOSE AND OBJECTIVES

Stakeholder engagement refers to a process of sharing information and knowledge, seeking

to understand and respond to the concerns of stakeholders, and building relationships based

on trust. The Project team is committed to undertaking a process that delivers an inclusive

dialogue with the Project stakeholders. The objectives are to:

Provide relevant information to stakeholders in a timely manner;

Facilitate two-way discussions to cover stakeholder issues and priorities as well as

concerns and needs of the Project;

Ensure engagement is in a language and format that is understandable and accessible

to local stakeholders, including vulnerable groups, and is culturally appropriate;

Take into consideration stakeholder issues, concerns and priorities into Project

decision-making processes, and

1 Ministry of Electricity and Energy (MOEE) is formerly known as Ministry of Electric Power (MOEP). 2 Electric Power Generation Enterprise (EPGE) is formerly known as Ministry of Electric Power Enterprise (MEPE).







Provide a mechanism for grievances to be raised and resolved.

The SEP has been developed in line with international good practice, Sembcorp’s corporate guidelines, including Sembcorp’s Stakeholder and Community Engagement Policy, and the

outputs from previous engagement undertaken as part of the environmental and social impact

assessment.

1.3 STRUCTURE OF THIS PLAN

The remainder of this document is structured in the following manner:

Section 2: Project Description;

Section 3: Key Standards and Legislation;

Section 4: Project Stakeholders;

Section 5: The Stakeholder Engagement Process;

Section 6: Grievance Management Mechanism;

Section 7: Monitoring and Reporting; and

Section 8: Roles and Responsibilities.







2 PROJECT DESCRIPTION

Sembcorp is planning to develop a 225MW CCGT power plant in Myingyan Township,

Mandalay, Myanmar (Figure 2.1). The Project site is located adjacent to an existing steel mill

(Myingyan Steel Mill No.2), owned by Ministry of Industry (MOI).

Figure 2.1 Project Location

The Project will be comprised of the following infrastructure:

A 225MW CCGT power plant, which will include the following main components:

2 sets of gas turbine (GT) units;

2 sets of heat recovery system generator (HRSG);

1 steam turbine generating unit with associated auxiliary equipment;

Switchyard area;

Cooling water system;

Demineralised water system; and

Wastewater treatment facility.

The power plant will be located on a predominately green field site. The design life of the

power plant, after the construction phase, is estimated to be 25 years.







A 230kV overhead transmission line, which will connect the power plant to the upgraded

Myingyan Steel Mill sub-station located within the adjacent steel mill complex. The

transmission line will be approximately 2.5 km in length. Sembcorp will construct the 230kV

overhead transmission line and handover to MOEE after the completion of construction.

A water supply pipeline and wastewater discharge pipeline. The water supply pipeline, which

will be approximately 14 km in length, will connect the power plant to the water intake point

and a new pumping station at the Ayeyarwady River. The wastewater discharge pipeline will

connect the power plant to the existing Ayeyarwady River. The wastewater pipeline, which will

be approximately 14 km in length, will be run parallel to the water supply pipeline. Both

pipelines will share the 2 m easement.

There are a number of villages located in close proximity to the Project site boundary. These

include:

1. Sa Khar village;

2. Hnan village;

3. Hpet Taw village;

4. Nyaung Kan village;

5. Gyoke Pin village;

6. Thien village;

7. Tha Pyay Thar village;

8. Kyun U village*;

9. Ka Laing Chone village*;

10. Aye village*;

11. Seik Nyan village*;

12. Ma Yoe Kone village*; and

13. Hta Nyaung Thai*.

During the last engagement meeting undertaken for the environmental, social and health

impact assessment, six additional villages were identified (indicated above with an asterisk).

Project information has been disclosed to the six additional villages and social data has been

gathered for the villages to incorporate into this SEP.







3 KEY STANDARDS AND LEGISLATION

The Project will conform to the legal and administrative requirements of the Republic of the

Union of Myanmar, international treaties to which Myanmar is signatory, and to relevant

international standards, including the ADB Safeguard Policy Statements (2009) and the IFC

Performance Standards (2012). In addition, the Project will conform to Sembcorp’s corporate

policies, including those relating to stakeholder engagement, in particular the Stakeholder and

Community Engagement Policy.

3.1 REPUBLIC OF THE UNION OF MYANMAR LEGISLATION

Sembcorp aims to identify, assess, evaluate and comply with stakeholder engagement

requirements as per the prevailing regulations in the area of operation. This includes:

Relevant local, regional, and national constitutional and regulatory requirements for

each of its owned and/or managed projects and operations;

Guidelines, frameworks and approaches that may have been adopted in the area of

its operations; and

Commitments put forth on Sembcorp companies through agreements, approvals and

permits.

At the time of updating this SEP, no specific stakeholder engagement requirements existed

outside of environmental impact assessment (EIA) / initial environmental examination (IEE)

framework established by the Ministry of Natural Recourses and Environmental Conservation

and (MONREC). However, given the evolving legal environment in the country, regulatory

changes may occur that will influence the SEP. It will be important that regulatory changes are

monitored to ensure that this SEP continues to be compliant with the requirements of the

Republic of the Union of Myanmar. In the meantime, Sembcorp will continue to engage Project

stakeholders by observing the international good practice, as described below.

3.2 INTERNATIONAL FRAMEWORK

The Project considers a range of international standards when developing a SEP. This is

particularly important in the context of this Project, as the Project is receiving international

financing. This includes:

The IFC Performance Standards (2012);

The EPs (2013); and

The ADB Safeguard Policy Statements (2009).

3.2.1 International Finance Corporation Performance Standards

The IFC Performance Standards on Environmental and Social Sustainability and the IFC’s Stakeholder Engagement Handbook are generally accepted as a benchmark for good practice. Performance Standard 1 (PS1) requires project proponents to engage with affected

communities through disclosure of information, consultation, and informed participation. To







facilitate this, IFC PS1 requires the proponent to develop and implement a SEP that is scaled

to the project risks and impacts and development stage, and tailored to the characteristics and

interests of the affected communities. IFC PS1 requires a SEP to include differentiated

measures to enable effective participation of those identified as disadvantaged or vulnerable.

A grievance redressal mechanism and ongoing reports to affected communities are also

required.

In addition to PS1, the following standards must be considered by the Project, if applicable:

IFC PS 5: Stakeholder engagement as part of land acquisition process and

resettlement process; and

IFC PS 8: Engagement with regards to cultural heritage.

3.2.2 Asian Development Bank Safeguard Policy Statement

The ADB’s Safeguard Policy Statement (SPS) sets out the ADB’s expectations with regards to impact identification and management for new operations, including requirements relating

to stakeholder engagement. The SPS aims to promote sustainability of project outcomes by

protecting the environment and people from a project’s potential adverse impacts by avoiding

or minimising adverse impacts of projects on the environment and affected people and helping

project proponents to strengthen their capacity to manage environmental and social risks. A

key part of this project is ongoing engagement with stakeholders, from the project inception to

closure or decommissioning.

3.3 SEMBCORP CORPORATE POLICIES

Sembcorp’s Stakeholder and Community Engagement Policy states that ‘every Sembcorp Company endeavours to take cognizance of the needs and welfare of our stakeholders’. This is applied by committing to the following principles:

Congruence and materiality. The engagement activities undertaken shall be aligned to

the business objectives, priorities and the identified issues/impacts/risks associated

with the Sembcorp project;

Cultural appropriateness and inclusivity. The engagement activities undertaken shall

be in cognizance of the cultural norms and practices of the stakeholder groups as well

as the differences in social status of the various groups;

Transparency. In order to ensure that engagement activities are undertaken in a

collaborative manner, it is essential that the stakeholders have access to certain key

information; and

Rights compatibility. The stakeholder engagement activities and planning shall

promote processes and agreements based on decisions that promote equity and

human rights.

At the project level, project affected communities are an important stakeholder, as poor

engagement at this level may harm the overall reputation and operation of the businesses.







Sembcorp also has a Community Grievance Management Policy, which provides guidance

for the grievance management mechanism detailed in Section 6.







4 PROJECT STAKEHOLDERS

The first step in preparing a SEP is mapping the Project stakeholders. This involves identifying

the relevant Project stakeholders or groups of stakeholders, characterising the key

stakeholder issues and concerns, and mapping the Project stakeholders to determine the

appropriate level of engagement for each stakeholder. This section describes the outputs from

the stakeholder mapping process.

4.1 STAKEHOLDER IDENTIFICATION

For the purposes of this SEP, a stakeholder is defined as any individual, organisation or group

who is potentially affected by the Project operations phase, can themselves affect the

operations of the Project, or has an interest in the Project.

A host of stakeholders have been identified that will need to be engaged during the operations

phase. Table 4.1 has grouped the stakeholders by category. This includes the stakeholders

that were identified during preparation of the ESIA, as many of these stakeholders will continue

to be engaged during the operations phase.

Table 4.1 Stakeholders

Stakeholder Group Stakeholder

Union government Ministry of Electricity and Energy (MOEE)1

Electric Power Generation Enterprise (EPGE)2

Ministry of Natural Recourses and Environmental

Conservation and (MONREC)

Ministry of Industry (MOI)

Directorate of Water Resources & Improvement of River

systems(DWIR)

Regional government (Mandalay) Chief Minister

Steel Mill (1)

Township government (Myingyan

and Taung Thar)

General Administration Department (GAD)

Department of Livestock, Fisheries and Rural Development

Department of Irrigation and Agriculture

Department of Electric Power

Department of Industry and Trade

Department of Social Welfare, Relief and Resettlements

Department of Labour

Water Resources Utilization Department

Myingyan City Development Council

Income Tax and Revenue Department

Development Committee

Local villages/ communities* Village Tract Leaders

1 Ministry of Electricity and Energy (MOEE) is formerly known as Ministry of Electric Power (MOEP). 2Electric Power Generation Enterprise (EPGE) is formerly known as Myanma Electric Power Enterprise (MEPE).







Stakeholder Group Stakeholder

Local villagers - Sa Khar, Hnan, Hpet Taw, Nyaung Kan,

Gyoke Pin, Thien, Tha Pyay Thar, Kyun U, Ka Laing Chone,

Aye, Seik Nyan, Ma Yoe Kone, and Hta Nyaung Thai

Farmers within local villages

Fishermen within local villages

Women’s group representatives within local villages

Youth representatives within local villages

Healthcare workers within local villages and regional health

care facilities

Community-based organisations

General Manager at the Steel Mill

Steel Mill workers

Vulnerable groups (e.g. landless, poor, migrant workers and

women) within the local villages

*The stakeholder mapping exercise undertaken during the ESIA did not identify any Indigenous peoples or non-governmental

organisations in the Project area. This will need to be occasionally updated but as of the time of writing, there has been no

change in status.

Table 4.1 includes villages located around the Project site, as they are the individuals most

likely to be impacted (positively and/ or negatively) by the Project. This includes villagers from:

Sa Khar village. The village is located less than 1km north east of the Project site, and

is the closest village to the Project site. The village is also located along the road that

connects the Project site to Myingyan and Mandalay;

Hnan village. The village is located approximately 1.5km south east of the Project site;

Hpet Taw village. The village is located approximately 3.2km south of the Project site;

Nyaung Kan village. The village is located approximately 2.7km south west of the

Project site;

Gyoke Pin village. The village is located approximately 2.7km north west of the Project

site;

Thien village. The village is located approximately 2.7km north of the Project site;

Tha Pyay Thar village. The village is located approximately 650 m from the water

supply pipeline / wastewater discharge pipeline;

Seik Nyan village. The village is located approximately 50 m from the water supply

pipeline / wastewater discharge pipeline;

Ma Yoe Kone village. The village is located approximately 390 m from the water supply


Aye village. The village is located approximately 50 m from the water supply pipeline /

wastewater discharge pipeline;

Kyun U village. The village is located approximately 80 m from the water supply


Ka Laing Chone village. The village is located approximately 150 m from the water

supply pipeline / wastewater discharge pipeline;

Hta Nyaung Thai village. The village, found beside Gyoke Pin village, is located

approximately 625 m from the water supply pipeline / wastewater discharge pipeline;







4.2 STAKEHOLDER ISSUE IDENTIFICATION

During the ESIA, the following key issues relative to the construction phase were raised by

Project stakeholders:

Employment. Most of the villagers indicated that they would like to benefit from the

employment opportunities that will be created by the construction of the Project;

Availability and quality of surface and ground water. Stakeholders expressed concern

that construction of the Project construction may impact the quality of water;

Air emissions and health implications. Stakeholders indicated that they were

concerned about the health implications associated with air emissions that will be

generated by the Project during construction, and the potential for an increase in the

transmission of communicable diseases; and

Noise. Stakeholders expressed concern about the noise that will be generated by the

Project during construction, as it may disrupt local village activities.

Key messages (Table 5.2) have been developed so that a consistent response is provided to

stakeholders when these issues are raised. These messages will need to be rolled out across

the Project team so that when questions arise the same response is provided. See Section 5

for more details.

4.3 STAKEHOLDER MAPPING

Stakeholder mapping, illustrated in Figure 4.1, was undertaken to identify the level of

engagement required during the operations phase for each group of stakeholders based on

their level of interest and level of impact.

The stakeholders were mapped by group. However, where a stakeholder differed to the

remainder of the group, the stakeholder was identified and mapped separately (e.g. EPGE).

The mapping results are as follows:

The stakeholders that appear in the top right quadrant (i.e. in Q1 Figure 4.1) are those

that need to be managed closely (i.e. the stakeholders that need to be proactively

engaged on a regular basis and engagement efforts should be focused on this group).

This is because these are the stakeholders that are most interested in the Project and

have the potential to impact its outcome (i.e. the ability of the Project to go ahead).

The stakeholders that appear in next quadrants (i.e. in Q2 and Q3 Figure 4.1) need to

be kept informed – i.e. provided information and consulted on issues of interest to the

stakeholders.

The final stakeholders (i.e. in Q4 Figure 4.1) need to be monitored – i.e. informed of

key Project aspects. It is important to track if their level of interest or impact changes.

Stakeholder mapping process is an on-going process, which requires regular review and

update as the construction phase progresses. It is expected that the Project team will update

this matrix based on feedback as detailed in Section 7.







Figure 4.1 Construction Phase Stakeholder Matrix

High

Low

High Low

Q1 Q2

Q4

Influence

Interest

Local villages

Vulnerable groups

Township GADs

MOEE/ EPGE

MONREC

Chief Minister

Township government agencies

Steel Mill workers

Q1

Q2

Q3

Q4

Steel Mill

NGOs







5 STAKEHOLDER ENGAGEMENT PLAN

5.1 PRE-OPERATIONS ENGAGEMENT

Pre-construction engagement is designed to seamlessly continue the engagement process as the Project transitions from the ESIA to pre-construction. The aim is to:

Engage stakeholders on the outcomes of the ESIA report, including any changes to the Project;

Explain the ESMPs that have been designed, in particular the grievance management process, health and safety procedures, and local procurement and employment. and

Provide an update on future engagement activities, including the frequency in which activities will be undertaken during the construction phase, and the key points of contact within the Project team, should anyone have a questions or concern.

Pre-operations engagement will be held at union, regional, township and village levels and it will include all stakeholders impacted or interested in the construction phase. The complete list of stakeholders is contained in Section 4 (Table 4.1).

As part of the engagement process, responses have been developed for the key issues

identified during the stakeholder mapping process. This will help ensure a consistent response

is provided to stakeholders throughout the engagement process. Of particular note, are expectations regarding employment; it will be important that these expectations are managed and that a consistent response is provided when questions arise regarding employment. Table

5.1 provides key messages.

Table 5.1 Key Messages

Issue/ Topic Key Message

Employment The Project will generate job opportunities. Jobs will be advertised and

will be awarded to the applicant best suited to the advertised position.

There are regulations in place that require at least 25% of the workers

will be Myanmar nationals during the first 2 years of operation. During

years 2 to 4 of operation at least 50% of the workers will be Myanmar

nationals and after 5 years of operation a minimum of 75% will be

Myanmar nationals. It is important to clarify with stakeholders that the

regulations require the employment of Myanmar nationals, not

specifically local stakeholders.

Energy/ Electricity The Project will produce and sell electricity to EPGE1; and EPGE in turn

will be responsible for the distribution of the electricity.

Water A water intake point will be established on the Ayeyardwady River.

Cooling water will be discharged back to the river in accordance with the

Myanmar Guidelines for Thermal Power Plants2 and IFC EHS

Guidelines for Thermal Power Plants 20083.

1 Electric Power Generation Enterprise (EPGE) is formerly known as Myanma Electric Power Enterprise (MEPE). 2 Thermal Power Effluent Levels - Myanmar National Environmental Quality (Emission) Guidelines, 29th December 2015. 3 IFC EHS Guidelines for Thermal Power Plants, 2008.







Waste will be disposed of appropriately. Chemicals and fuels will be

properly stored and handled. A site specific emergency response plan

will be developed and implemented.

Air emissions The power plant will generate air emissions during operation. These

emissions will be line with the Myanmar Guidelines1 and World Health

Organisation Guidelines2 (i.e. international good practice standards) for

air quality.

Noise emissions During operation, the noise levels will be in accordance with the

International Finance Corporation (IFC) Guidelines3 and Myanmar

Guidelines4 for noise at residential properties.

5.2 OPERATIONS PHASE ENGAGEMENT

Engagement will be held at the regional, township and village levels. The frequency and

method of engagement will vary based on the targeted audience and key messages to be

presented. These are presented in Error! Reference source not found. below; this plan should

be updated as feedback is received from stakeholders.

Special measures will need to be taken to ensure that vulnerable groups are included in the

engagement activities. This will involve working with village leaders to ensure that invitations

are extended to vulnerable groups (e.g. women headed households) to participate. From time

to time, this may involve undertaking face-to-face meetings with key vulnerable groups (e.g.

women, elderly).

Examples of engagement methods are listed in Table 5.2. The relevant methods will be

selected based on the targeted stakeholders

Table 5.2 Examples of Stakeholder Engagement Methods

Engagement will be held at the regional, township and village levels. The frequency and

method of engagement will vary based on the targeted audience and key messages to be

presented. These are presented in Table 5.2 below; this plan should be updated as

feedback is received from stakeholders.

Method Description

Face-to-face individual meetings Individual briefings provide a high level of project detail, and allow for

concise feedback, in a personal environment. Individual briefings may

be held with Indigenous groups and high priority stakeholders to

discuss issues relevant to the stakeholder/s.

1 Annex 1 – Air Emissions - Myanmar National Environmental Quality (Emission) Guidelines, 29th December 2015. 2 IFC General EHS Guidelines: Air Emissions and Ambient Air Quality, April 30th 2007. 3 IFC General EHS Guidelines: Noise, April 30th 2007. 4 Annex 1 – Noise Levels - Myanmar National Environmental Quality (Emission) Guidelines, 29th December 2015.







Method Description

Face-to-face group meetings Group meetings may be used to communicate key strategies to

stakeholders, allowing many interested parties to attend. They could

also be used to help determine partnerships and collaboration

opportunities.

Workshops Workshops allow stakeholders to explore key issues, provide

feedback and develop action plans which are owned by those

affected by them or who will implement them.

Focus groups Focus group discussions are used when a project issue requires

specific discussion or exploration. A skilled facilitator is often needed

to ensure outcomes are achieved and to ensure appropriate

involvement. Timing and a neutral venue are also critical.

Correspondence (phone, letter,

email)

This is often the most common form of engagement used to establish

and maintain relationships with key stakeholders. Phone

conversations can be used on a regular basis to maintain

relationships. Letters can also be issued for invitations to briefings

and email alerts can be sent to invite comment or alert to project

updates.

Website A website can be used to provide relevant and timeline project

information. However, a website can also be used as a means of

collecting information from the community (e.g. via online discussion

forums, blogs etc.).

Appendix B provides a template to help plan day-to-day engagement with stakeholders.

Engagement will be guided by Table 5.2.

5.3 INFORMAL ENGAGEMENT

Official engagement activities are an important component of the operations phase. They

present the advantages of being organised, easy to advertise, recordable and demonstrate a

level of commitment by Sembcorp to the stakeholder engagement process. However, informal

engagement is also important. Regular informal engagement by the Project team with local

villagers helps to create, maintain and strengthen relationships and prevents grievances from

escalating.

Although informal, these engagement opportunities need to be captured in the stakeholder

database. There is a risk that commitments or promises will be made during informal

engagement opportunities that are not followed through (because they are not captured in

minutes of meetings or other similar record). To reduce this risk the outputs should be captured

in the stakeholder database and engagement should be undertaken by trained individuals.

Informal engagement should be considered to be conducted by the Project team and the CR

Manager on a regular basis – e.g. drop-ins to the local villages to provide updates or to see

how things are going.







5.4 STAKEHOLDER COMMITTEE

In addition to the activities set out above, a stakeholder committee will be formed and gather

for meetings when necessary. When there is a need to disseminate project –related

information to the affected communities, the stakeholder committee will gather to provide

updates and exchange of feedbacks and comments. This provides a channel for two-way

communication for clear updates and open feedback mechanism to facilitate flow of required

information.

Key stakeholder groups will be represented on the committee, including, at a minimum,

representatives from each of the surrounding villages and the Project team. If the

representatives from Myingyan and Taung Thar GADs are able to participate in the

stakeholder committee upon invite, they are welcome to join in the stakeholder committee

meeting. HR & Admin manager, HSE manager and Development Manager from Project

Company will be invited to join in the meetings in order to assist in the updates of project-

related matters. This will provide an opportunity for issues raised and decisions made during

the meetings to be actioned quickly and efficiently.

The committee will:

Build on the relationships already established between local stakeholders and the

Project;

Gain a better understanding of village priorities and concerns as they relate to the

Project;

Receive ongoing input regarding management and monitoring of impacts; and

Provide regular Project updates to key stakeholders.

It will be the responsibility of the committee members to disseminate the information provided

at the committee meetings to their villages. This will be one of the ways in which information

will be relayed to local villages.

Stakeholders will have the opportunity to raise Project related issues and concerns with

committee members. It will be the responsibility of committee members to relay the issues and

concerns to Sembcorp and to raise them during the committee meetings for discussion.

The committee will meet on a needed basis during construction. At the end of the construction

period, the frequency at which the committee meets will be reviewed. The committee will

provide a valuable mechanism to collect and disseminate information.

5.5 STAKEHOLDER DATABASE

Implementation of this SEP will be supported by a stakeholder database. (A stakeholder

database is a tool that can be used to track stakeholder activities and grievances.) The

stakeholder database will help track the following information:

The stakeholder – i.e. an organisation or individual;

A contact person’s name and position or title;

Contact details (address, telephone, email, website);







The main interests/issues/ concerns of the organisation as they may relate to the

Project; and

Details of engagement activities – i.e. date, location, attendees and key issues raised

– and responses/actions agreed.

The outputs from the mapping process (Section 4) should be captured in the stakeholder

database as well as the outputs from the engagement activities described above. This will

help ensure that issues and concerns are captured and can be fed into decision-making

process and that commitments made are met. Appendix C provides examples/ templates to

be utilised by the Development Manager to track engagement activities.







6 GRIEVANCE MECHANISM

This section details the grievance mechanism that will be used to identify, track, and manage

grievances raised by external Project stakeholders. The approach is based on international

good practice and Sembcorp’s Stakeholder and Community Engagement Policy and the

Community Grievance Management Policy.

6.1 OBJECTIVES

The grievance mechanism is designed to manage grievances from stakeholders affected by

the construction phase of the Project. Grievances are complaints raised by stakeholders

regarding the Project.

The grievance mechanism ensures that stakeholders concerns are registered and, where

possible, addressed. It allows Sembcorp to be informed of issues being raised by stakeholders

so that it can be proactive in implementing solutions. The roles & responsibilities of each

member (regardless of internal or external members) and the Organisation Chart of the

Grievance Committee are detailed under Appendix E Grievance Committee

6.2 THE PROCESS

A variety of methods will be available through which stakeholders can lodge grievances. This

will include:

Face-to-face meetings with the relevant Project representatives;

Written communication (e.g. email, letter) directed to relevant Project representative

or left in suggestion boxes, which are found located in the villages and at the plant site

office. Villagers may choose to speak to their village tract leader or relevant village

representative to help facilitate a written complaint; and

Telephone call placed to a relevant Project representative.

Input written grievances in the suggestion box placed in or near their village vicinity

All grievances will be recorded in the stakeholder database. This will include a summary of

the grievance, the resolution or agreement on proposed actions (between the Project and the

complainant), and monitoring actions taken in response to the grievance. The grievance log

and grievance close-out form will be stored in the stakeholder database (Appendix D).

The key steps of the Process are as follows (Figure 6.1):

1. Identification of grievances. This could be in person, by phone, letter, or email using

the contact details below:

Development Manager

Email: [email protected]; [email protected]

Telephone No. : +959 792608080

2. Grievance is recorded in a ‘grievance log’ (written and electronic) within 3 days of

identification. The grievance log will be held at Sembcorp’s plant site offices. The

mailto:[email protected]







significance of the grievance will then be assessed within five to seven working days using

the criteria outlined in Box 6.1.

Box 6.1 Significance Criteria

Level 1 Complaint: A complaint that is isolated or ‘one-off’ (within a given reporting period - 1 years) and

essentially local in nature (e.g. light traffic accident involving construction vehicle).

Note: Some one-off complaints may be significant enough to be assessed as a Level 3 complaint - e.g. when

a national or international law is broken (see Level 3).

Level 2 Complaint: A complaint which is widespread and repeated (e.g. dust from construction vehicles).

Level 3 Complaint: A one-off complaint, or one which is widespread and/or repeated that, in addition, has

resulted in a serious breach of Sembcorp policies or Myanmar law and/or has led to negative

national/international media attention, or is judged to have the potential to generate negative comment from

the media or other key stakeholders (e.g. inadequate waste management).

3. Grievance is acknowledged through a personal meeting, phone call, or letter as

appropriate, with the complainant 10-14 working days after submission. If the grievance

is not well understood or if additional information is required, clarification should be sought

from the complainant during this step.

4. The Development Manager is notified of Level 1, 2 or 3 grievance and the Project

Managing Director is notified of all Level 3 grievances. The senior management, will

support the Managing Director and the Development Manager in deciding who should

deal with the grievance, and determine whether additional support is required to respond

to the complainant.

5. The Project Development Manager delegates the grievance to the relevant

departments(s)/personnel to develop a response - e.g., HR, relevant medical or

administrative departments, contractors etc.

6. A response is developed by the Development Manager within 14 working days after

acknowledging the grievance, with input from the relevant Project personnel and others,

as necessary.

7. The response is signed-off by the Managing Director for level 3 grievances and the

Development Manager for Level 2 and Level 1 grievances within 14 working days of

issuing a response. The sign-off may be a signature on the grievance log or an e-mail

which indicates agreement, which should be filed by the Development Manager and

referred to in the grievance log.

Communication of the response should be carefully coordinated. The Development

Manager will ensure that an approach to communicating the response is agreed and

implemented, taking into consideration cultural sensitivities.

8. Record the response received from the complainant to help assess whether the

grievance is closed or whether further action is needed. The Project Development







Manager should use appropriate communication channels, most likely telephone or face

to face meeting, to confirm whether the complainant has understood and is satisfied with

the response. The complainant’s response should be recorded in the grievance log.

9. Close the grievance with sign-off from the Development Manager. The Development

Manager will assess whether a grievance can be closed or whether further attention is

required. If further attention is required the Development Manager should return to Step

2 to re-assess the grievance.

Once the Development Manager has assessed whether the grievance can be closed,

he/she will sign off or seek agreement from the Managing Director for level 3 grievances,

to approve closure of the grievance. The agreement may be a signature on the grievance

log or an equivalent e-mail, which should be filed by the Development Manager and

referred to in the grievance log. In additional, a ‘grievance closeout form’ will be used.

This process is outlined in Figure 6.1.

The grievance management process enables complaints to be lodged anonymously.

Complainants are not required to provide their name when lodging a grievance. This is

reflected in the grievance log and close-out template (Appendix D). All grievances will be

archived into the Grievance Database (Appendix F) All grievances will be recorded,

investigated and closed-out in the same manner – as described above and as set-out in

Figure 6.1.







Figure 6.1 Grievance Management Process

1. Identification of grievance (phone, letter, email, meeting,

others)

2. Grievance is recorded in grievance log within 3 working

days and its significance assessed within 5 to 7 working

days

3. Grievance is acknowledge 10 working days after

submission of the grievance

4. Development Manager is notified of the grievance

5. Development Manager delegates resolution of grievance

to relevant personnel

6. A response is developed within 14 working days of issuing

the acknowledgement

7. Sign-off of the resolution by Development Manager for

level 1 & 2 and the Managing Director for Level 3

grievances

8. Record complainant response in stakeholder database

9. Close out grievance using the grievance log and close out

form to update the status of the grievance in the

stakeholder database

Co

ord

ina

tio

n a

nd

do

cum

en

tati

on

by

De

ve

lop

me

nt

Ma

na

ge

r







7 MONITORING AND REPORTING

To ensure that the desired outcomes are being achieved, the SEP will be monitored

throughout the construction phase.

7.1 MONITORING OF STAKEHOLDER ENGAGEMENT ACTIVITIES

There are two methods through which the stakeholder engagement process will be monitored:

1. Review of engagement activities in the field:

During engagement with stakeholders, the engagement team will assess meetings

using a feedback evaluation forms or by asking questions of participations,

depending on the stakeholder group, to ensure that messages are being conveyed

clearly.

The engagement team will debrief with the Project team to assess whether the

required outcomes of the stakeholder engagement process are being achieved, and

to provide the opportunity to amend the process where necessary.

2. Systematic, formal evaluation, which will occur on an annual basis, if appropriate.

7.2 EVALUATION OF STAKEHOLDER ENGAGEMENT ACTIVITIES

Performance will be reviewed on an ongoing basis to determine the effectiveness of the SEP,

including the methods being used and the accuracy of the mapping results.

A formal evaluation will be done annually, during which the performance indicators set out in

Table 7.1 will be used to determine the extent to which the objectives of the SEP have been

met. Information from the stakeholder database and formal/informal feedback from

stakeholders will be used to assess the performance indicators. The evaluation results will be

used to update the SEP, and will be reported internally as well as to key external stakeholders,

as requested.

The annual review will also provide a timely opportunity to review the stakeholder mapping

results to ensure that the mapping results are still accurate.

Table 7.1 Performance Indicators

Objectives Performance Indicators

Stakeholders are provided information

about the Project construction in a timely

manner

Number and type of engagement occurred and

recorded

Stakeholders have an opportunity to share

their views and concerns about the

construction

Number and type of engagement opportunities occurred

and recorded







Objectives Performance Indicators

Positive working relationships are built and

maintained over time Number and type of grievances lodged by stakeholders

Number of resolved & closed out grievances

Engagement continues to be transparent,

inclusive and appropriate during

construction

Number and type of engagement opportunities occurred

& recorded

Number and type of grievances lodged by community

members

Number of resolved & closed out grievances







8 ROLES AND RESPONSIBILITIES

Responsibility for implementation and monitoring of the SEP during construction will sit with

the Development Manager. Specifically the Development Manager will be responsible for:

Interfacing between Sembcorp and the stakeholders;

Regularly engaging with Project stakeholders to ensure a transparent feedback

process exists;

Disclosing relevant information to Project stakeholders;

Ensuring meaningful and representative participation of stakeholders in decision-

making processes;

Establishing a transparent mechanism to obtain, report, redress, and monitor all

grievances from stakeholders; and

Monitoring and reporting on the SEP, including updates, as required, to the stakeholder

mapping results.

The Development Manager will work with the Managing Director to ensure that the SEP is

implemented and that grievances are resolved in a timely manner. The Managing Director will

be responsible for approving the SEP, including the annual budget required for

implementation.

8.1 PROJECT MANAGEMENT TEAM

In times of civil disturbance/unrest, the Project Management team will step in to take charge

of the situation in order to better manage and mitigate any risks that are posed by the abrupt

circumstances. The Project Management Team consists of Development Manager, Health

Safety and Environment (HSE) Manager and the other various engineering personnel (Figure

8.1). They will all report to the construction manager/plant manager during the construction

/operation phase. Once the civil disturbance or Unrest occurred, the Project Management

Team will have to ensure the protocol and act in accordance to the given guidelines in the

Emergency Response Management Plan.

Project activities during construction /operation phase can also increase risks and impacts to

the community health, safety and security that may arise from project activities. In order to

safeguard the risks to the identified vulnerable communities, the community emergency

response plan is prepared under the Project Emergency Preparedness & Response

Management Plan (including Community Emergency Response) to address any community

emergency situations. The Senior Management Team (Figure 8.2 & Figure 8.3) shall ensure

alongside with the management from the contractors that steps will be taken to avoid or

minimise risks and impacts to community health, safety and security that may arise from

project activities.







Figure 8.1 Operations and Maintenance Organisation Chart

Board of Directors

Plant ManagerLeonilo Caraos

ManagerTin Maung Thein*

HR ExecutiveHsu Pyeit Phyu

Managing DirectorDennis Foo

Manager

Aung Lwin Oo

Commercial

HR & Admin/OD

HSSE

ManagerHendra Kurniawan

Hairul Saleh

CSR ExecutiveHein Min Oo* HSSE

Executive Tin Ko Ko

HSSE Snr. Executive

Zaw Moe Aung

Security AdvisorLekh Bahadur

Shahi (total [incl. SA] 27 staff outsourced

from IDG)

O&M

Dy Plant ManagerYazar Myo Thein

ManagerNaing Naing Aung

Development

AnalystKevin Heng Tze

Chien Admin ExecutiveMyat Oo Lwin

Medical OfficerPyi Soe Thein

Logistics Executive

Ye Yint Thu

Government

Relation OfficerThura Aung

Figure 8.1.1 Reporting Workflow – Group and Local Community Relations

Reporting Workflow:

1. Community Relations Officer will report to the Development Manager 2. Development Manager will directly report to the Managing Director of the Project

Company 3. Development Manager will liaise and receive support from Group Strategic

Communications & Sustainability in Singapore

Community Relations Officer will receive training and able to seek advice from Group

Community Relations Manager in Singapore Figure

Ng Lay San Head, Senior Vice President, Group Strategic

Communications & Sustainability

Aung Lwin Oo Community Relations/ Development Manager

Gwendolyn Loh Assistant Vice President, Group

Strategic Communications & Sustainability

Dennis Foo MD of Sembcorp Myingyan

Koh Chiap Khiong

Head, Singapore, SEA and China (Energy Division)

Hein Min Oo @ Koyinthardu

Community Relations Officer







8.2 Company Emergency Response Team (CERT)







9 APPENDIX

9.1 APPENDIX B: STAKEHOLDER TEMPLATE

Day-to-day implementation of the approach will be determined by the Development Manager

(e.g. the Development Manager will determine the specific timing and content of the

engagement activities).

Table 9.3 provides a template to guide day-to-day engagement, and help the Development

Manager implement the approach outlined in Table 5.3.

Table 9.3 Planning Engagement Template

S/

N

Stakeholder Date/

Timing

Engagement

Method

Key

Issue(s)

Engagement

Purpose

Respons

ibility

Information to be

disclosed

Status of

Action

E.g.

MONREC

Septe

mber

2016

Face-to-face

meeting

Environ

mental

impacts

Bi-yearly

progress

update

GM e.g. Update on

construction

progress of CSR

infrastructure,

including

management of air

and noise

emissions

In progress







9.2 APPENDIX C: STAKEHOLDER DATABASE TEMPLATE EXAMPLES

A stakeholder database template example is provided in Table 9.4.

Table 9.4 Stakeholder Database Template Example

S/N

Date

Location / venue Stakeholder group

Stakeholder (Attendees/Participants)

No. of Attended/Participated Stakeholder ( IF ANY)

Contact Person (Individual name) IF ANY

Contact Details (Mobile No. / Email, Region/ District/ City/ Township/ Street/ Village)

Engagement Method (Meeting Type)

Name of Key Representatives

Engagement Purpose (Subject)

Information to be disclosed

Key Issues category

Key Issues & Responses Provided ( If Any)

Key Outcomes & Actions (Actions Agreed)

Status of Actions

Reference To Records

Note : Template will be in landscape format and much detailed and extensive based on the

displayed information. Current layout is for neat presentation of table.







9.3 APPENDIX D: GRIEVANCE LOG AND CLOSE-OUT TEMPLATE

The grievance log and close-out template is provided in Table 9.5.

Table 9.5 Grievance Log and Close-Out Template

Grievance Log (PART 1) -Contact and Details

Complaint number :

Date:

Recorded by:

Complainant details (Tick the box for anonymity )

Name:

Category [community/ contract worker/ supplier/ contractor]:

Telephone number:

Address:

Preferred method of contact:

Grievance Log (PART 2)- Description of grievance(s)

Describe the grievance below.

Mode of communication (written/ verbal/ meetings/ mediator):

Date of grievance:

Date of acknowledgement:

Signatures

Recorder:

Claimant:

Date:

Grievance Closed Out (PART 3)- Resolution

Describe the steps taken to resolve the grievance and the outcome.

Category of Grievance :

Human Right Impact Grievance Society Impact Grievance Indigenous People Others

Department:

Mode of communication for reply (meeting/ written/ verbal/ display):

Date closed:

Signatures

Complainant:

Project representative:

Date:







9.4 APPENDIX E: GRIEVANCE COMMITTEE

9.4.1 PURPOSE OF GRIEVANCE COMMITTEE

The Grievance Committee has accountability in reviewing and resolving the grievances. The Grievance Committee shall assure the received grievances and complaints to be handled in accordance to the grievance mechanism and evaluated fairly with the necessary resolution taken, when necessary. The Grievance Committee will receive a collated grievance list submitted at the end of every 2 weeks and the following week Tuesday will have to review and sent back the evaluation comments on the collated list of grievances. The leader of the Grievance Committee (Community Relations Officer, Hein Min Oo) will collate the comments and conclude the final evaluation and status of each complaint. He will be able to best conclude on the final decisive outcome for the complaints and grievance. 9.4.2 GRIEVANCE COMMITTEE COMPOSITION

The Grievance Committee will be supported internally by the Company and advised by the Group Community Relations. The Grievance Committee shall have the following representation to ensure fair and timely solutions to the submitted complaints and grievances:

Community Relations Officer (Plant personnel serving as Grievance Officer) - Hein Min Oo;

Development Manager (Plant personnel) - Aung Lwin Oo;

Human Resource Manager (Plant personnel) - Naing Naing Aung;

Operation Team and HSE Team – Yazar Myo Thein & Tin Maung Thein;

Group Strategic Communications & Sustainability (Singapore personnel) –

GAD Officer (Optional)

The key responsibilities of Grievance Committee are as follows: • Review, consider and comment on the possible resolutions for the submitted grievances

through email. • Community Relations Officer to resolve grievances with the collated advice from the

Grievance Committee using the Grievance Mechanism stated clearly in the Stakeholder Engagement Plan.

• Arrive at decisions through consensus. Any failed consensus which resolution will be based on majority vote. Any decision made by the Grievance Committee must be within the purview of Environmental Management Plan, Corporate EHS and Social Policies or any such documents of relevance of that matter.

• In case the grievance relates to environmental monitoring results or engineering matters, the GRC will validate the information available to it, as provided by the Project Company’s Project management team/ environmental monitoring team. However, Grievance Committee will not be in a position to question the validity of the data provided to it.

• The Grievance committee shall attend to the teleconference meeting initiated by the Community Relations Officer when necessary in order to have the final concluded resolution for more serious grievances (tier 3 grievances). The frequency of teleconference meeting may increase or decrease depending on the number and type of grievances received.







• If needed, Community Relations Officer may undertake field visits to verify and review the issues, dispute or other relevant matters. Field trip findings and results will be shared with all other members in the grievance committee.

GRIEVANCE COMMITTEE FOR 13 VILLAGES Grievance Committee for Sarkhaar Village

1. U Maung Myint – Village Head

2. U Than Htut Aung – EPGE

3. U Aung Lwin Oo – Development Manager (Site Personal)

4. Daw Naing Naing Aung – Human Resources Manager (Site Personal)

5. U Tin Aung Swe – HSSE Manager (Site Personal)

6. Hein Min Oo – Community Relation Officer

7. GAD Officer (Optional)

Grievance Committee for Hnan Village

1. U Hein Min Lwin – Village Head







Grievance Committee for Phet Taw Village

1. U Kyaw Htay Naing – Village Head













Grievance Committee for Nyaung Kan Village

1. U Shu Maung – Village Head







Grievance Committee for Thein Village

1. U San Lwin– Village Head







Grievance Committee for Gyoke Pin Village

1. U Win Hlaing – Village Head













Grievance Committee for Hta Naung Tai Village

1. U Nay Min Kyaw – Village Head







Grievance Committee for Aye Village

1. U Myint Swe – Village Head







Grievance Committee for Ma Yoe Gone Village

1. U Win Maung – Village Head







Grievance Committee for Tha Pyay Thar Village

1. U Win Shwe – Village Head













Grievance Committee for Sate Nyan Village

1. U Chit Win – Village Head







Grievance Committee for Ka Lane Chone Village

1. U Zaw Khin – Village Head







Grievance Committee for Ka Lane Chone Village

1. U Kyaw Toe – Village Head



















9.5 APPENDIX F: GRIEVANCE DATABASE

The grievance database is provided in Table 9.6.

Table 9.6 Grievance Database

ID No.

SI/ Complainant No.

Date of Grievance Recorded

Time of Grievance Recorded Grievance Recorder

Select Occurrence of incident

Explain occurrence of grievance

Complainant details

Name of Complainant

Stakeholder Category [Community/Villager Representative]

Complainant Tel No.

Address ( Filled in if details are given)

Preferred Contact Method

Nature of Grievance i.e Social, Pollution, Political, Media, Legal, Land, Others

Describe Grievance

Mode of communication (written/ verbal/ meetings/ mediator)

Date of Grievance Recorded

Date of Acknowledgement

Mode of acknowledgement

Classification of Grievance

Estimation of resolution

Brief Outline of Resolution

Actions proposed

Action Taken

Outcome

Remarks

Status Update

Mode of contact for reply to complainant

Acknowledge by

Date Closed

Third Tier CLOSED OUT (Date of acknowledgement to GM )

Third Tier CLOSED OUT (Date of update to GM)

Third Tier CLOSED OUT ( Closed out approval date by GM )

Third Tier CLOSED OUT (Other Remarks)

Human Right Impact Grievance/ Society Impact Grievance / Indigenous

People/ OTHERS

Note: Template will be in landscape format in excel