• Gezhouba has endorsed international agreements and conventions and has “identified, accessed, publicized and implemented” international instruments such as the Convention on Wetlands of International Importance especially as Waterfowl Habitat 1971, the Convention Concerning the Protection of the World Cultural and Natural Heritage, and the Convention on Biological Diversity (Sources: Notice on the 2010 List of Laws, Regulations and Other Requirements about Quality, Environment, and Occupational Health and Safety; Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).
• According to Gezhouba, ISO standards have been adopted since 1996. Gezhouba gained ISO 14001 Environmental Management Systems certification in 2005, with recertification in 2008, 2011 and 2014 (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).
• According to Gezhouba, the company holds the «Energy Saving and Environmental Protection Month» and carries out activities on World Environment Day event every year (Meeting with Gezhouba for comments on the draft, April 16, 2015).

• According to Gezhouba the company is committed to comply with the environmental and social standards of the host country, and the company incorporates the environmental and social standards set by Chinese law as a minimum standard (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).

• The environmental standards and labor standards adopted in the Sopladora project meet strict Ecuadorian laws, which are higher than the standards set by Chinese laws (Source: Site visit, Feburary 2015).

• According to Gezhouba, the environmental protection plans and measures were proposed by the marketing department and reviewed by the Health, Safety and Environment (HSE) Department. The HSE Department is also responsible for supervising and inspecting their implementation (Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).
• Gezhouba’s 2013 CSR Report notes that EIA reports for investment projects are compiled and reviewed by authorities; costs related to environmental management are included in the total investment cost during project assessment; The company makes efforts to apply for national environment-related subsidies; environmental issues in investment projects are included in a project’s management accountability mechanism and forms a project assessment indicator; Compliance with the EIA is assessed post-project evaluation; and relevant environmental regulations are formulated.
• Gezhouba’s Regulation on Environmental Protection requires that an “EIA must be carried out for construction projects and the environmental protection regulations shall be strictly followed. Besides, an environmental management system must be established in accordance with the GB/T24001-2004 Standard” (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).

• The EMP is part of the EIA, and was approved together with the EIA by the Ministry of Environment (Source: Site visit in Feburary 2015).
• A Chinese version of EMP can be obtained online, which includes 15 different plans: solid waste treatment, wastewater, water purification plant, air pollution monitoring, particle emission monitoring, noise monitoring, industrial water use and water body monitoring, construction and maintenance of passageways, maintenance of machinery and equipment, debris treatment, mining management, abandonment of camps and industrial facilities, training plan, environmental policy on community relationship, and vegetation restoration (Source: Environmental Protection Plan for Gezhouba-FOPECA Paute-Sopladora Project). According to Gezhouba, EIA and EMP documents for Sopladora Project were originally posted on Ecuador’s CONELEC website. However, only approval documents can now be found on the website (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).

• Gezhouba endorsed international agreements and conventions and has identified, accessed, publicized and implemented international instruments such as the Convention on Wetlands of International Importance especially as Waterfowl Habitat, Convention Concerning the Protection of the World Cultural and Natural Heritage and Convention on Biological Diversity, etc. (Source: Notice on the 2010 List of Laws, Regulations and Other Requirements about Quality, Environment, and Occupational Health and Safety; Meeting with Gezhouba for comments on the draft scorecard, April 16, 2015).
• According to Gezhouba, the company is very risk-sensitive and committed to reducing environmental and social impacts. For example, factors like the impact of damming on rivers, animals, environmental flow control and wildlife passages are taken into account at the design stage (Source: Meeting with Gezhouba in December 2014).
• It is mentioned in Gezhouba’s 2013 CSR Report that the company respects nature and safeguards biodiversity. During construction, scientific and normative measures have been taken to minimize the adverse effects on the surrounding environment, for instance, optimization of construction organization design, reduction in land use, prohibition of excessive deforestation and logging, prohibition of excessive animal hunting and killing, protection of the surrounding environment, wildlife and vegetation, preservation of the landform, etc.
• It is also mentioned in Gezhouba’s 2013 CSR Report that the company protects natural habitats, wetlands, forests, wildlife corridors, and agricultural land during construction. It sticks to the principle of “avoidance, less land occupancy, restoration and compensation” for ecological environmental protection and properly plans the construction area to use wasteland whenever possible instead of farmland, plough land or forest. If construction has to be done in natural habitats, wetlands, forests or other sensitive areas, requirements and measures raised in EIA reports, Water and Soil Conservation Plans and other documents are followed; warning signs tailored to the local environment and the project are set; construction organization design and planning is optimized; special environmental protection measures are designed and implemented. Temporarily cleared roads, spoiled ground, quarry sites, etc. are restored in a timely manner after construction and transplanting, seeding and other measures are taken to minimize the adverse environmental and ecological impact that construction might have caused.

• The project’s impacts included (but were not limited to) construction of roads, facilities and debris disposal area, soil removal, machinery noise, and vegetation removal has forced animals to leave the area (Source: Site visit, Feburary 2015).
• The diversion tunnel is located within a National Forest Park (Source: Chen, P. et al. (2013) “Some Views on the Environmental Protection in the Ecuadorian Paute-Sopladora Project,” Sichuan Water Conservancy, 5, pp52-55), during the Site visit we were not able to ascertain how successful re-vegetation activities of the tunnel construction site will be and special efforts to ensure its success (Source: Site visit, Feburary 2015).
• The company takes preventive measures and has not had any environmental incidents that require additional mitigation measures. The company has trained and educated the workers not to catch or harm the protected spectacled bears. Before construction, the inspection was completed to identify the important animal and plant species at the project site. Identified species were relocated or transplanted. In some cases, native vegetation was transplanted temporally to nursery sites and will be used in re-vegetation efforts in debris areas. However, we visited an older debris site, which has been re-vegetated and found it dominated by invasive species (Source: Site visit, Feburary 2015).

• Gezhouba’s 2013 CSR Report noted that during construction, scientific and normative measures are taken to minimize the adverse effects on the surrounding environment. Examples given include treatment of dust, noise, waste, sewage, effluents from construction, and reductions in pollutant discharge.
• Gezhouba’s 2013 CSR Report refers to company regulations in place, such as Regulation on Sewage Discharge, Regulation on Pollutant Emission, Regulation on Solid Waste Disposal, etc., to strictly control wastewater, emissions and solid waste.
• Gezhouba has pollutant discharges and environmental management standards set out in the Regulation on Environmental Protection. The company also has other regulations on environmental monitoring, wastewater, emissions, noise, solid waste, radioactive environments, soil and water conservation, etc. (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).

• The EMP includes waste treatment or disposal plans, wastewater and sewage treatment plans, emissions monitoring plans, noise monitoring and control plans and industrial water monitoring plans (Source: Environmental Protection Plan for Gezhouba-FOPECA Paute-Sopladora Project).
• Wastewater goes through the grease trap tank to remove grease and inorganic pollutants. Samples of wastewater from construction facilities are sent to a lab in Cuenca for testing every month. The company periodically measures noise level in the impacted area, and tests the particles in the cement plant and inside of the tunnel. The roads are watered to reduce particles (Source: Site visit, Feburary 2015).

• Despite the absence of formal policies, Gezhouba complies with relevant laws, regulations and standards in all projects and take measures in accordance with the EIA documents to protect tangible and intangible cultural heritage involved in its projects (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).

• The cultural assessment in the EIA verified the existence of historical and cultural sites before construction; the Institute of Cultural Heritage in Ecuador came to determine whether the cultural site needs to be preserved (Source: Site visit, Feburary 2015).
• There is an ancient cultural heritage site near the construction camp. Gezhouba established a fence around it and took measures to protect the hill and build drainage channels nearby to avoid the risks of erosion (Source: Chen, P. et al. (2013), “Some Views on the Environmental Protection in the Ecuadorian Paute-Sopladora Project,” Sichuan Water Conservancy, 5, pp. 52-55).

• Gezhouba’s 2013 CSR Report noted that during construction, scientific and normative measures are taken to minimize the adverse effects on the surrounding environment, which includes strengthened management of excavation slopes and prevention of flushing, water loss and soil erosion.
• Gezhuoba’s Regulation on the Conservation of Soil and Water follows the principle of “prevention first, treatment together” and set requirements for excavation, permanent slope treatment, waste storage and treatment, drainage facilities and revegetation (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).

• No plans to address erosion and sedimentation issues are contained in the Chinese version of the Handbook on Environmental Protection.
• According to Gezhouba, a set of measures was taken to manage the sedimentation and erosion issues during construction; for instance, excavating the slopes based on the design and in separate layers from top to bottom, strictly controlling the excavation within the allowed area, and stabilizing the slopes. In the debris area, they cleared the old humus, set up drainage ditches, added geo-membrane layers, and covered with new humus to prevent soil erosion. In the tunnel excavation process, sedimentation ponds were used at all the openings to prevent sediment from entering the rivers. We observed that the drainage from the hill needs to be better managed to reduce the erosion risks (Source: Site visit, Feburary 2015).

• Gezhouba’s Information Exchange, Consultation and Communication Control Procedures specifies relevant procedures and requires the company to establish smooth communication channels with stakeholders. It requires that the project department and other relevant departments convey environmental and occupational health and safety information to all stakeholders and reach agreement with them through consultation when the identified environmental factors or sources of hazard concern them. External stakeholders involved include mainly project owners, engineers, local government, embassy, etc. Mechanisms to involve other stakeholders such as communities or civil society are not clearly defined.
• According to Gezhouba, the company has inspection plans requiring headquarters to inspect a project once or twice a year, which includes meeting with project stakeholders to collect suggestions and advice on contract implementation, community relations and environmental protection. Views and suggestions including from local communities could be voiced through project owners or the local government (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).

• According to Gezhouba, the company keeps contact with local communities through emails and gives out small contributions to them. The company also pays occasional visits to the local government, holds weekly meetings with project owners and supervisors which can include discussion of comments from stakeholders, and convenes monthly human resources meetings mediated by supervisors. A Workers’ Protection Committee and a Workers’ Safety Committee are established as well (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).

• The company has a complaints filing procedure, which specifies response time limit, a punishment mechanism, and an accountability mechanism. The project department needs to report to headquarters within 24-48 hours after a complaint or dispute is received. The company’s inspection team visits the site twice a year to deal with people’s disputes and listen to their needs and demands (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).
• The Information Exchange, Consultation and Communication Control Procedures and Regulation on Complaints address the consultation and complaint mechanisms between employees and external stakeholders, which include mainly project owners, engineers, the local government, the embassy, etc. Mechanisms involving other stakeholders (such as communities or civil society) are not clearly defined. However, according to Gezhouba, the company will follow the same procedures when dealing with complaints through project owners or local government from those stakeholders (Source: Meeting with Gezhouba for comments on the draft scorecard, April 16, 2015).

• Daily complaints are addressed within the company’s framework through the Workers’ Protection Committee established by the project department and the labor union (Source: Comments from Gezhouba on draft scorecard on 16 April, 2015). Complaints from communities are addressed through dialogues and consultations. We were not able to collect information on how it was implemented (Source: Site visit, Feburary 2015). According to Gezhouba, no case of community complaint has been filed (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).
• Ecuadorian workers have launched a legal action against Gezhouba (Source: Site visit, Feburary 2015). There was a strike in February 2015 to demand equal pay between local and Chinese workers and better compensation for high-risk work like tunnel work (Source: www.dailymotion.com/video/x2i7nim). According to Gezhouba, the strike was dealt with using the established complaints mechanism. The strike was considered by the Ministry of Labor as illegal (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April 2015).

• The company promotes local people’s livelihoods in the host country, starting with their most urgent needs; supports, invests in and actively engages in programs for public good such as education and training, provision of medical services, disaster relief, environmental protection, community building, etc. (Source: Gezhouba website www.gzbgj.com/col/col7595/index.html).

• According to Gezhouba, the company has met its social responsibilities through the recruitment of disabled people, making donations to communities and providing community services. In the Collective Employment Contract for Ecuadorian workers, Gezhouba commits to the provision of grants to families with financial difficulties, educational funds, as well an end-of-job bonus (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).

• The company respects local culture and demands, fully utilizes local resources to promote local employment, and offers internationally recognized salaries in strict accordance with local regulations. Gezhouba’s Regulation on Recruitment of Foreign Employees for Overseas Units requires: all staff respect the laws of the host country and local culture; that labor contracts be signed with local employees; and provide training, compensation and benefits that are commensurate with local standards. Foreign employees shall also be provided with social insurance, be taxed, and be granted leave entitlement in compliance with local laws, regulations and policies (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).
• According to Gezhouba, the company holds employee representatives meetings every year to consult and receive complaints. Those results are disclosed internally. The company also collects employees’ options on company development and management, personal development and logistics (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).

• Both Ecuadorian and China Labor Laws are followed for Chinese workers. No instances of abuse of international human rights have been documented (Source: Site visit, Feburary 2015; Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015). Local employees base salary is determined according to the salary levels set by the Ministry of Labor. The minimum salary is no lower than the base salary, and the annual salary increase rate with inflation rate. 12 Ecuadorian workers tried to organize and demand better salary and living conditions, but were fired by the company. Ministry of Labor went to the site and gave a workshop to the workers about their rights. The Ecuadorian workers have since formed a union (Source: Site visit, Feburary 2015).
• Ecuadorian workers chose to work for the project because they can earn more money (about USD700 /month, rather than USD400/month as the normal monthly salary) by working overtime. But some workers reported that if they complain about anything, they will lose the opportunity of working overtime. The company provides free medication, free food, free laundry, free household items, special bonuses, entertainment and sport facilities to workers (Source: Site visit, Feburary 2015).

• Gezhouba’s environmental and occupational health guidelines address all types of hazards with a view to ensuring staff’s health and safety, carrying out environmental protection work, and creating harmonious conditions for development. The company has adopted goals of no-fatal-accident, no-new-occupational-disease incidences and no environmental accidents (Source: Company interview December 2014; Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015). Note: Gezhouba allowed International Rivers to scan procedural documents relating to Quality, Environment, and Occupational Health and Safety Management Systems Documents and Operation and Control Procedures for Occupational Health and Safety in Projects.

• On April 1, 2014, four Chinese workers were killed by an explosion at the construction site (Source: Xinhua Media reporting news.xinhuanet.com/English/world/2014-04/03/c_133233899.htm, http://wenku.baidu.com/view/59507d464a7302768e9939f7.html).
• According to Gezhouba, the company complies with local occupational health and safety regulations and has set up a hospital in the construction site and temporary medical centers in each construction area. Employees are provided with over 20 labor protection products. Local employees are provided with social insurances, as well as accident insurance and life insurance (Source: Site visit, Feburary 2015).
• Sopladora Project adopts OHSA18000 and ISO14000 Occupational Health and Safety Management Standards (Source: Chen, P. et al. (2013), “Some Views on the Environmental Protection in the Ecuadorian Paute-Sopladora Project,” Sichuan Water Conservancy, 5, pp. 52-55).

• Gezhouba’s website notes its strategy of “globalized resource allocation and localized labor management” for international projects so as to propel local economic growth, provide local employment opportunities and improve local labor skills (Source: Gezhouba website www.gzbgj.com/col/col7595/index.html).
• According to Gezhouba, the percentage of local employment is subject to local contract requirements and quota requirements. If local labor is available in the host country, no Chinese labor will be used (Source: Meeting with Gezhouba for comments on the draft scorecard, 16 April, 2015).

• The ratio of Chinese workers and Ecuadorian workers is 1:4. Local Ecuadorians are hired in the project’s human resources, safety management, environmental management, operation management, finance, and construction management departments. Ecuadorian workers mainly work as drivers, equipment repairmen, equipment operators, electric welders and porters. Safety, environmental, healthy and technical trainings are provided to the local hires (Source: Site visit, Feburary 2015).

• Anti-corruption and “clean” governance has been a long-term policy of the company. The company has specialized agencies and a discipline inspection department that is responsible for: 1. implementing instructions from higher authorities; 2. formulating the company’s internal regulatory frameworks; 3. supervising implementation by every employee; 4. handling complaints and acting against corruption; and 5. promoting anti-corruption education. Corruption is prevented in three transformational stages: first, people who are inclined to be corrupt refrain from corruption due to severe punishment for violations; second, institutional improvements are in place to rule out any opportunity for corruption; and third, a higher ideological level is achieved so that people are self-conscious in anti-corruption. Gezhouba is currently in the transition from Stage 2 to Stage 3 (Source: Company meeting, December 2014).

• According to Gezhouba, the company strictly abstained from improper involvement in local political processes. The anti-corruption and clean governance team is led by the Secretary of the Party Branch in the company, co-led by the project manager, and staffed by other members in leadership and departmental heads. The team consists of 22 people in total and has an annual budget of about RMB12,000 (USD2,000). Training about anti-corruption and clean governance policies is provided quarterly (Source: Meeting with Gezhouba for comments on the draft scorecard, April 16, 2015).

• According to Gezhouba, the company has established Evaluation Procedures for Laws, Regulations and Other Requirements, which holds the company’s legal affairs department responsible for the centralized management of access, identification, register, dissemination and update of relevant laws, regulations and other requirements. The company’s overseas units shall be responsible for identification, access and training on local laws, regulations and other requirements. The relevant departments/overseas units shall have a regular compliance check to ensure local and national laws are respected (Source: Meeting with Gezhouba for comments on the draft scorecard, April 16, 2015).

• According to Gezhouba, during the project tender phase, the company completed the initial survey and assessment of local laws and regulations with the assistance of local agencies. The project department has designated a deputy manager to manage legal affairs and hired local experienced lawyers, contract experts, and tax experts to assist in the legal survey to ensure full compliance with local laws and regulation (Source: Meeting with Gezhouba for comments on the draft scorecard, April 16, 2015; Site visit, Feburary 2015).
• Gezhouba said it has received a few labor complaints because the company and the workers have different understandings of some clauses in the Labor Law (Source: Site visit, Feburary 2015).

• Gezhouba has Procedures Concerning Planning for Hazard Identification, Risk Assessment and Control, Procedures Concerning Investigation and Handling of Accidents, Incidents and Non-compliance, and Procedures on Emergency Preparedness and Response Control (Source: Company Meeting, December 2014).
• Gezhouba has a Committee for Public Emergency Response and Management. The committee’s secretariat has issued 29 plans for the company level, including: Emergency Response and Rescue Plan for Production Accidents, Emergency Response Plan for Equipment Accidents, Emergency Response Plan for Major and Fatal Fire Accidents, Emergency Response Plan for Environmental Emergencies (Source: 2013 CSR Report).

• According to Gezhouba, the project department has compiled Emergency Plans for: Major Accidents, Landslide and Debris Flow, Burglary and Robbery, Electric Shock and Fire, Collapse inside the Tunnel, and Overseas Projects (Source: Meeting with Gezhouba for comments on the draft scorecard, April 16, 2015).
• The project department has established emergency organizations under the guidance of the Emergency Management Plan, including a leaders’ team, a rescue team, a medical team, and a communications team. The Plan has been updated and improved. Training and education are provided to both Chinese and Ecuadorian workers (Source: Site visit, Feburary 2015).

• Gezhouba’s Handbook on Environmental and Occupational Health Management contains a section on information exchange, consultation and communication, and requires that the project department and other relevant departments convey environmental and occupational health and safety information to all stakeholders and reach agreement with them through consultation when the identified environmental factors or sources of hazard concern them.
• Gezhouba has developed a Regulation on Public Disclosure of Workplace Hazards, which specifies how to publicize workplace hazards.

• According to Gezhouba, the project site is far from communities, so workplace risks are managed and reminders are placed on safety protection notice boards.