Addendum to <strong>EMPR</strong> for Concessions 8(a), 9(a) and 8(b) 7levels will include Managers (4) and Supervisors (2), as well as additional 12 work stationsoperating 24/7 at the processing facility. A further 14 short-term contracts will be required forthe pipeline launch and preparation of the reclamation site. Technical training will beprovided for all personnel as required.Indirectly, the proposed dredging and processing operations will add to the general economicactivity in the region, as operations will be provisioned from local suppliers and will utiliselocal services. This will help to create and/or maintain businesses and associated employmentin local population centres. It is also planned to renovate a hostel formerly used by Trans Hexpersonnel, thereby providing improved accommodation facilities in the town.Decades of terrestrial mining operations along the Namaqualand coastline have significantlyaltered the coastal landscape between the Orange and Olifants River mouths. Prior to theminerals Act of 1991, no rehabilitation and restoration of mining-impacted areas was required,and much of the prospecting/mining conducted on the coastal plain and fore dune area wasuninformed, unscientific and uncontrolled. On the Farm Hondeklip, for example, past miningoperations have resulted in severe disturbance and alteration of the physical profile of thecoastal strip by extensive excavations, and tailings disposal. Although the Trans Hex Grouphold the mining licence for the farm, they are not accountable for the rehabilitation ofenvironmental damage or disturbance created prior to 1980. Rehabilitation and re-vegetationof such areas will have to be conducted in co-operation between those responsible for creatingthe impact, and the relevant national and regional authorities. As a consequence many ofthese past impacts have resulted in severe long-term/permanent scarring of the landscapethereby significantly impacting both the visual quality and topographic form of the coastalenvironment. By back-filling some of the historic excavations with tailings resulting from theprocessing of dredged sediments, the proposed project represents an important milestone inthe rehabilitation of past damage to the coastal environment by terrestrial mining operations.2.2 Compatibility with policies, plans, strategies etc.The project is compatible with other marine diamond mining operations in the area. However,the coastal strip between the Spoeg and Groen Rivers is part of a proposed National Park. Theland is partly owned by the State, and partly by De Beers Consolidated Mines, who have leasedout the farms between the Spoeg and Groen Rivers, on a 99-year lease, to South AfricanNational Parks to create the national park. The seaward extent of the park has not beenfinalised, and its proclamation is undecided at present. Although situated directly offshore ofthe proposed national park, proposed dredging operations in Concessions 8(a), 9(a) and 8(b)should in no way interact with the Groen-Spoeg coastal National Park. The coastal habitats ofthe national park would only be at risk from mining operations in an emergency situation suchas the wrecking of the dredger and the associated pollution. Should a Marine Protected Areabe proclaimed offshore of the coastal National Park, conflict can be expected as regardsimpeding and prevention of mining development and expansion, particularly in concessionareas that fall within the proposed conservation areas and for which Namagroen hold indefinitemining licences.Namagroen Prospecting & Investments October 2008
Addendum to <strong>EMPR</strong> for Concessions 8(a), 9(a) and 8(b) 82.2.1 Namagroen’s Environmental Policy StatementNamagroen recognises its responsibility for the stewardship of the natural environment andresources, and is committed to sound environmental management by designating theenvironment as high operational priority to be integrated into the Company’s businessactivities. Namagroen’s environmental policy statement is provided below.<strong>NAMAGROEN</strong> PROSPECTING & INVESTMENTS (PTY) LTDENVIRONMENTAL POLICY STATEMENTIt is the policy of Namagroen Prospecting and Investments (Pty) Ltd to conduct theexploitation of marine diamond resources in an environmentally responsible manner,so as to achieve sustainable development.The management and staff of Namagroen, and all its partners and associates, arecommitted to maintain a high standard of environmental management of all shorebasedand marine prospecting and mining operations.In this regard, Namagroen undertakes to ensure the following:• Compliance with all relevant existing and forthcoming statutory obligations.• Implementation of international standards of best practice.• Proper environmental impact assessment prior to all operations.• Identification of additional environmental risks during operations.• Formulation of a proper environmental management programme (EMP).• Efficient monitoring and control of all environmental risk factors.• Conservation of natural resources through recycling and reduced wastage.• Prevention of pollution, leakages and spillages as far as possible.• Monitoring and proper containment of potentially harmful substances.• Maintenance of good relations with all interested and affected parties.• Training of all employees on environmental management procedures.• Compliance of contractors with the Namagroen environmental policy.• Regular audits to evaluate compliance with and efficiency of the EMP.• Protection of breeding grounds of all indigenous fauna.• Protection of cultural and archaeological heritages.These commitments have guided the compilation of this project-specific <strong>EMPR</strong> amendment.The Environmental Policy is specific to the Company, based upon compliance with applicablelegal, regulatory and consent requirements of the governmental authorities in South Africa,and other requirements.Namagroen Prospecting & Investments October 2008