Twenty members of the “Malagasy Economists’ Reflection Circle,” or CREM, toured Ambatovy’s sites in Moramanga and Toamasina on April 23-24, 2013. Ambatovy’s specific objective was to continue its efforts for transparency and for informing organizations and various public and private entities. This opennesscomes from Ambatovy’s interest to enrich the economic and social exchanges that Madagascar needs. The company’s aim is to educate others about the environment in which Ambatovy is developing andto contribute to the understanding of evolving issues surrounding major mining investments.

In Moramanga, the visitors saw the mine and the Ambatovy Information Center. In Toamasina, they toured the Processing Plant in Tanandava, the Ambatovy Training Centre, and the Agricultural Training Centre, as well as the Purchasing Centre, which supplies the company’s catering serviceswith produce from 8,000 farmers. The Vice-President of CREM, Jonah Andrianantoanina, stressed the importance of such a tour. “We saw, heard, learned, and received a lot of information and facts during this tour,” he said. Ambatovy continues to open itself to the public to supply informationabout its activities and the overall environment of its operations.

As a part of Ambatovy’s commitment to the VPSHR, the Company hosted a five-day seminar from February 4-8, 2013, in Toamsina, framed within the context of the Voluntary Principles on Human Rights.

Over 50 attendees were present including representation from the Army,the Gendarmerie, the Police, the Judiciary, BIANCO (National Independent Anti-Corruption Office), and the Chiefs of the District of Toamasina and Brickaville as well as Ambatovy’s Private Security contractors.

The seminar was organized in partnership between Ambatovy, the United Nations, the Ministry of Justice, and the International Committee of the Red Cross. The goal was to refresh the knowledge of, and create new understanding on human rights, specifically in the context of respect for the right of life and protection of rights during arrests and detention as well as standards for use of force during public demonstrations.

Sherritt International Corporation, the operator of Ambatovy, is currently preparing to submit an application to join the Voluntary Principles Association. Formal participation provides an invaluable platform for dialogue and the sharing of best practices with other companies, governments, and non-governmental organizations and serves as a critical mechanism for avoiding and diffusing potential conflicts. As part of this process, Ambatovy is developing and implementing criteria and programs involving Public and Private Security as well as administrative and judicial officials and communities to raise support and awareness for Human Rights. Among other actions, this involves embedding the Voluntary Principles on Security and Human Rights (VPSHR) into company policies, memorandums of understanding with Public Security, and specific exhibits in Private Security contracts.

Company Policy and Codes of Conduct

The Voluntary Principles on Security and Human Rights are reflected in Ambatovy’s Security Policy and to reinforce shared commitment to the Principles, Ambatovy is in the process of developing and implementing the following actions:

• An Ambatovy/Government Security Forces Convention between Ambatovy and the National Ministries responsible for security (The Armed Forces Ministry, Ministry of the Interior for Security and the Secretary of State for the Gendarmerie). The Convention contains clear reference to the shared expectations of Public Security Forces and Ambatovy under the VPSHR.
• An Ambatovy/Government Security Forces Operational Order between Ambatovy and Government Security Forces at the operational level in Ambatovy’s areas of operation. The Operational Order contains clear reference to the shared expectations of Public Security Forces and Ambatovy under the VPSHR.
• A VPSHR/Use of Force Contract exhibit that articulates Ambatovy’s expectations of its Private Security Contractors.

Implementation of Security and Human Rights and/or Practices

Ambatovy is continuously engaging with local and national entities to educate and raise awareness for the promotion of Human Rights. To this end Ambatovy has:

• Exchanged dialogue and conducted VPSHR presentations that have led to participation in Ambatovy’s VPSHR program by:
  - The Ministry of Armed Forces
  - The Secretary of State for the Gendarmerie
  - The Ministry of the Interior for Security (Police)
  - The Madagascar National Defense Council (All Government Security Forces)
• Delivered, in partnership with the United Nations and Ministry of Justice, a 2 day Security and Human Rights awareness seminar, in February 2013, for Administrative, Judicial, and Government Security Forces and Private Security Contractors working under contract at Ambatovy.
• Delivered, in a partnership with the International Committee of the Red Cross, a 3 day workshop, in February 2013, for Government Security Forces operating in Ambatovy areas of operation.

Additional workshops, seminars, and training sessions are already scheduled for the latter half of 2013.

Existing Cooperation with VPs pillars and other entities

Ambatovy realizes that it is part of the national and international community and as such, it is working with organizations at all levels to deliver initiatives under the VPSHR. Ambatovy participates in regular information sharing and meetings with diplomatic representations in Madagascar as well as Rio Tinto, another large mining operation conducting works in the south of the island. Partnerships have been formed with the United Nations, the Ministry of Justice, and the International Committee of the Red Cross to facilitate and deliver Security and Human Rights awareness and training. In 2012, Ambatovy facilitated the conduct of a Security and Human Rights risk assessment by subject matter experts with wide internal and external stakeholder consultation, the recommendations of which largely contributed to the development of its VPSHR program. Ambatovy is continuously looking to develop further partnerships in order to strengthen its commitments and support for the VPSHR initiatives.

As part of its goal to support the communities neighboring its operations, Ambatovy is continuously collaborating with the Regional Directorate of Technical Education to contribute to and support education. The Lycée Technique of Moramanga is one beneficiary of this partnership. On February 15th, 2013 the Lycée inaugurated a new three room library as well as a three room school extension which were materially funded by Ambatovy. This donation totaled over 37 million Ariary. This included not only the construction of the buildings but also 10 computers with technical software and about fifty technical books were also offered to the Lycée. The ceremony was a dedication to education as not only did the new buildings open their doors, but 13 students of the “FITSINJO” program for management and business graduated. Prizes were also distributed by Ambatovy for the top students of the academic year.
Over 2,000 students will benefit from the 130 books that were donated by Ambatovy to the new library, and 120 students will be able to enjoy the new classrooms.

Initially, in late 2011, Ambatovy, in partnership with a local NGO, began to support the Commune Urbaine of Moramanga through funding a feasibility study, conducted by an independent firm from October 2011 to February 2012, on technical and financial options to implement an urban waste management system in the city. The results of the study were discussed in a meeting that included representatives of the Alaotra Mangoro Region, the executive head and members of the Commune urbaine, the chiefs of 13 fokontany that compose the city, representatives of the health district, and other economic and technical stakeholders. From this meeting an ad-hoc waste committee was established. The phases of the project have been outlined to include the initial pre-collection process, purchasing of a garbage truck, assisting in sustainability, and eventually enhancing the Landfill structure and organization.

Already, the preliminary phase of the pilot project, the pre collection process, has begun. Prior to implementing the house to house collection, all trash is being collected from the community dumpsters and deposited at the land fill. In the pre collection system, citizens of the community will pay a small fee to have their trash regularly collected from their homes. The money collected will be used to pay for the components of the collection service (salary wages, incentives, equipment, etc.). All waste will be taken to a land fill that has been established by the municipality and that is capable of receiving the volume of trash the community produces. There, members of DEFI, a local NGO, are on hand to sort the refuse into waste materials and compost components. The compost is sold back to the community for use in their farming activities and the proceeds then help contribute to the cost of the program.

This project is estimated to create 65 permanent jobs in the community. The successful processing and collecting of waste from the streets and neighborhoods of Moramanga will not only positively affect the image of the city, but also the health of its citizens while providing employment opportunities and sustainable measures for a cleaner future.

Security Policy

Ambatovy is committed to safeguarding its people, assets, operations, and reputation.
It is the intent of Ambatovy to create a safe and secure business environment within which personnel can deliver their full potential without hindrance from criminal activity, physical danger, or disruption to operations.

Ambatovy strives to conduct security operations in full compliance with national and international legal requirements, international standards, and law enforcement principles, and in accordance with the Voluntary Principles on Security and Human Rights (VPSHR) which provide practical guidance for companies on maintaining the safety and security of their operations within an operating framework that ensures respect for human rights and fundamental freedoms..

Ambatovy will strive to ensure that our security concept is oriented toward potential security risks, that effective security measures are in place, and that all personnel contribute to security in order to protect employees, contractors, other stakeholders, and company assets including information, our brand, and our reputation.

In order to realize this commitment, Ambatovy will:

• Look to identify security threats and risks to people, assets, operations, and reputation – recognizing that risks may emanate from political, economic, or social factors – and take appropriate measures to minimize those risks;
• Seek to identify and understand the causes and nature of security risks and appropriately address issues of concern to internal and external stakeholders;
• Assess whether actions of the company or members of its staff heighten risk and act appropriately to minimize any such risks;
• Promote personal accountability by taking corrective and/or disciplinary action against personnel breaking the law or violating their terms of employment;
• Work with local law enforcement authorities to ensure appropriate responses to security incidents involving Ambatovy people or assets;
• Investigate security incidents appropriately and take necessary action to minimize the probability of recurrence;
• Investigate and manage expeditiously security related grievances that may be raised by employees, contractors or affected communities;

Security Management System

In order to achieve its Security Policy objective of promoting the respect for human rights while simultaneously creating a safe and secure business environment, Ambatovy has adopted a three-tier Security Management System (SMS).

The SMS and related documentation define the system that has been adopted and clearly establishes Ambatovy’s security policy and principles. This is required in order that Ambatovy’s approach to security management appropriately addresses security threats and risks and provides a framework for the consistent delivery of appropriate levels of security across all of Ambatovy operations.

Ambatovy’s SMS is an integrated management tool that defines the company’s policy and principles, providing management, employees, and contractors with guidelines and standards for the entire business.

It ensures:

• Clear assignment of responsibilities;
• Effective management of risks;
• Compliance with related Ambatovy policy and relevant government legislation;
• Continuous improvement;
• Efficient and cost-effective planning and operations;

Part 1: Security Management Manual

At the apex of the Security Management System is direction on Security Management activities performed in order to achieve Ambatovy’s Strategic Security aims and Security Policy objectives. Ambatovy will continuously strive to mitigate Security Risks by prudently identifying, anticipating, preventing, investigating, and responding to internal and external threats.

Part 2: Security Standards, Processes, Procedures, and Programs Manual

In support of Part 1, the Security Management Manual is a range of Security Standards, Procedures, Processes, and Programs in Part 2. These lay out the systematic approach to Security Management designed to achieve Policy objectives at the strategic level as well as provide the framework within which Security activities will be conducted at the Facility or operational level.

Part 3: Security Directory of Assessments, Plans, Procedures, and Registers

The Directory contains completed and management approved documents providing localised and specific Assessments, Plans, Procedures, and Registers pertaining to the safeguard of Ambatovy people, assets, operations and reputation. All Facility Security Plans are included in the Directory.
Component parts and documents are available to Ambatovy Management and staff as appropriate.

Through adhering to established security principles that emphasis human rights, open communication, and planning, Ambatovy is setting the foundation for a sustainable, secure business future. Engagement and facilitation with host communities, organizations, and governmental agencies is essential to our security plan. In respecting human rights and the culture of our local communities we are facilitating relationships and networks that can be pivotal in any security situation. Ambatovy looks forward to a stable, viable, and bright future working alongside the people of Madagascar.

The Quality topic trainer with some participants

Ambatovy, through the Ambatovy Local Business Initiative (ALBI), has initiated a win-win partnership with local businesses through Ambatovy’s Business Training Center (BTCA). Training and “mentorship” are offered as free programs not only for companies working as suppliers / contractors for Ambatovy, but also for companies wishing to work with Ambatovy in the future as well as university students and young and prospect entrepreneurs.

Ambatovy’s Business Training Center (BTCA) started its training activities in July 2012. Quality, Entrepreneurship, Finance, and HSE (Health, Safety, and Environment) are the main training topics provided at the center.

Besides the 17 topics which were already offered by the BTCA last year, more have been designed to assist Ambatovy’s contractors to meet the company’s requirements and to develop the capabilities of local resources.

For the Entrepreneurship subject, the curriculum focuses on internal rules establishment, recruitment policy and procedure, and specific modules relating to the supply of Ambatovy: identification forms and pre-qualification questionnaires, Ambatovy’s procurement rules, and how to become an Ambatovy supplier. Courses on tendering procedures (how to respond effectively to a tender) and business development management are also among those included in the Entrepreneurship topic.

In the Finance curriculum, classes on the establishment of a bank loan file, working capital analysis, and financial statements and their uses are part of the newly developed modules.

This year the Quality topic includes courses on traceability, customer satisfaction measurement, a program for continuous improvement, and corrective and preventive measures as well as the internal audit program.

For the HSE topic, the same classes offered in 2012 are planned for this year.

As of January 2013, new categories of participants will take part in classes along with Ambatovy’s contractors. These new participants are from companies that are not among Ambatovy’s suppliers but are individuals who plan to develop their businesses and students at the end of their university studies who are interested in entering the world of entrepreneurship.

As an additional benefit, each course offered at the BTCA will include professionals, individuals, and students. This encourages experience sharing between the participants.

Training « Decentralization »

Ambatovy's Business Training Center

In March 2013, Moramanga, the location of Ambatovy’s Mine Site, will benefit from training sessions on Ambatovy’s tendering procedures and responses to a tender: the Entrepreneurship topic.

In April 2013, the Union of Building and Public Works Companies (S.E.B.T.P), which includes thirty members, will have the opportunity to follow training on Health, Safety, and Environment taught by a trainer from BTCA in Antananarivo. HS-1001 standards, Policy and Scoreboard, Risks Analysis, Personal Protective Equipment, Defensive Driving, Hygiene, and Work at Heights are among the courses that will be offered to the participants.

Ambatovy’s commitment to the environment was acknowledged with the presentation of a new ant species discovered by Brian Fisher, Ph.D., a renowned entomologist known for the identification and discovery of African ant species, and Chairman of the Department of Entomology at the California Academy of Sciences. Dr. Fisher presented a photograph of the new species to Ambatovy President, Mark Plamondon, on November 21, 2012 at the Ambatovy Plant Site.

The ant, Tetramorium Ambatovy, was discovered in one of Ambatovy’s conservation zones surrounding the Mine site that is protected as a part of Ambatovy’s offset conservation program in its areas of operations. The name Ambatovy was bestowed on the newly discovered species by Dr. Fisher as a recognition of Ambatovy’s dedication to biodiversity conservation and sustainability.

Ambatovy’s offset program is based on the Business and Biodiversity Offset Program (BBOP) and was a pilot project used in developing the BBOP Standards. Through partnerships like the one between Ambatovy and the California Academy of the Sciences, Ambatovy’s offset areas have been the subject of scientific expeditions, biodiversity research, and conservation activities which work with local people to safeguard natural resource sustainability.