DUMMY STAKEHOLDER ENGAGEMENT PROCESS/FRAMEWORK FOR TDB

The project is being implemented under OP 4.03. As such, TDB has a working ESMS that
includes a stakeholder engagement framework in the form of External Communication
Mechanism (ECM). The TDB ESMS is adequate to guide the ESDD and monitoring of
projects financed under ASCENT. TDB has committed to review and update the ESMS
based on the Bank’s comments and recommendations to the satisfaction of the Bank
prior to disbursement of any funds. This has been made a disbursement condition in the
ESAP. Below is the ECM excerpt from the TDB integrated ESMS.

SECTION 8: STAKEHOLDER ENGAGEMENT

Stakeholder engagement measures will work pro-actively towards developing and
fostering positive relationships between the Client and stakeholders, particularly those
directly affected by the project activities. Stakeholder engagement will aim to:

▪   Provide stakeholders with project information at appropriate times and in accessible
    forms;

▪   Communicate planned project phases, developments and changes to all
    stakeholders in good time (e.g. opening of new operations);

▪   Involve stakeholders in project decision-making that will affect/influence their lives;

▪   Enhance stakeholders’ capacity to identify unanticipated projects impacts, and to
    be able to communicate these to the Client such that they can be resolved;

▪   Assist affected people in adapting to the social and economic changes brought
    about by the Project through information and participation;

▪   Ensure that stakeholders can report concerns and grievances easily;

The management of impacts through stakeholder engagement can be divided into two
main strategies.

▪ Proactive engagement where portfolio company goes out to stakeholders to elicit
  their involvement and to share information in order to address issues that may be of
  concern prior to their arising. This process is ongoing throughout the project
  implementation.

▪ Reactive engagement i.e. responding to concerns or grievances raised by
  stakeholders in a coherent and predetermined manner. This approach is facilitated
  through the establishment of a Grievance Procedure as described below.



SECTION 9: DISCLOSURE OF INFORMATION


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Disclosure of relevant project information helps Affected Communities and other
stakeholders understand the risks, impacts and opportunities of the project. The client will
provide Affected Communities with access to relevant information on:

(i)      the purpose, nature, and scale of the project;
(ii)     the duration of proposed project activities;
(iii)    any risks to and potential impacts on such communities and relevant mitigation
         measures;
(iv)     the envisaged stakeholder engagement process; and
(v)      the grievance mechanism.

SECTION 10:             GRIEVANCE PROCEDURE

Stakeholder engagement measures will work pro-actively towards identifying and
addressing E&S issues before they become grievances. However, when grievances are
reported they need to be addressed in a consistent and verifiable manner as part of the
implementation of the ESMS. For this reason a Grievance Procedure needs to be followed
to:

▪ Enable stakeholders to easily identify and report any grievance regarding the project’s
  performance; and
▪ Ensure that, through a defined process and within a predictable timeframe,
  stakeholders receive a response and/or resolution to the grievance.

A grievance is when stakeholders report a complaint or what they perceive to be poor
performance linked to an operation within a Client company, with the expectation of an
explanation, or a change to the activity that has caused the grievance, or
redress/compensation.

The Grievance Procedure (Appendix 18) should be followed for all grievances relating to
Client companies as a whole, as well as any issues related to any potential resettlement
and rehabilitation.

CONCLUSION

TDB recognises that E&S issues should be given early consideration prior to investment
(commitment). The foregoing procedures should reduce E&S risk of unexpected impacts
and should assist in ensuring the following.

▪       Ensuring that for each potential deal, TDB is convinced that the E&S assessment and
        due diligence made during the pre-investment period are accurate to demonstrate
        the nature and level of risk to make the Bank comfortable to make a decision from
        an E&S perspective.

▪       The Client is complying with at least the local and national environmental, social and
        labour regulations, and with TDB’S ESMS.



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▪   The client must be at least sensitive to the impact of the environment on sustainable
    development and profitability.

The implementation of this ESMS will ensure that TDB’s E&S performance is safeguarded,
strengthened, made more effective, brought in line with international best practice and
ensure adherence to lenders requirements.




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