• Huadian endorsed the Global Compact in 2008 (Source: http://www.chd.com.cn/news.do?cmd=showandid=69919).

• No information collected.

• According to Huadian, Chinese laws are stricter than the Cambodian laws. The EIA for the Project was primarily carried out in accordance with Cambodian laws. However, in some parts of the EIA (not specified) where requirements under Chinese laws and regulations are stricter, the EIA adopts Chinese standards (Source: Site visit, March 2015).
• No EIA was done and approved prior to approval of the project, which doesn’t comply with either Chinese or Cambodian law (Source: CDM PDD Report for the Lower Stung Russei Chrum Project).

• Huadian has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• In 2008, Huadian completed a total of five normative documents and model texts related to its hydroelectric projects, including 1) General Environmental Protection Design and Requirements for Compiling Implementation Plans, 2) Proposal for Tender Division Planning for Environmental Protection and Water and Soil Conservation, 3) Model Text for Environmental Protection, Water and Soil Conservation, Supervision and Management Services Tender Documents, 4) Model Text for Water and Soil Conservation Clauses in Tender Documents, and 5) Model Text for Assessment Methods for Environmental Protection and Water and Soil Conservation Performance. These documents were officially released in August 2009 and widely promoted within the company (Source: http://www.chd.com.cn/news.do?cmd=showandid=52566; Huadian’s Hydropower Sustainability Report). However, it is unclear whether these documents apply to its overseas projects.
• Under Huadian’s Regulation on Environmental Protection (Trial Version) Article 21: Initial design documents for electric power projects shall include a section dedicated to environmental protection and tender documents shall have clear environmental protection clauses. Measures to tackle pollution raised in the design documents shall be fully implemented. Article 25: All branches and wholly-owned holding companies shall, in accordance with national and local requirements for environmental protection as well as the group company’s general environmental objectives, establish sound environmental protection and management systems and, based on the company’s environmental protection plans, compile and implement their own annual action plans for environmental protection. Environmental objectives shall be divided in a top-down manner and responsibilities shall be assigned to individuals. However, it is unclear whether these Regulations apply to its overseas projects.

• According to Huadian, an EMP is included in the EIA, but it does not have any standardization certification. The EMP covers common issues such as wastewater, solid waste, air quality, erosion and sedimentation, etc. The EMP was not publicly disclosed. In our meeting with the company, we were not able to see a copy of the EMP (Source: Site visit, March 2015).

• Huadian has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• Huadian Regulation on Environmental Protection (Trial Version) Article 17: The group company’s electric power projects (including thermal power, hydropower, wind power, desulphurization projects, and other electric power projects) shall strictly follow the National Environmental Impact Assessment System. Electric power projects shall go through environmental approval procedures, and projects whose EIAs have not been reviewed or approved by authorities shall not be commenced. However, it is unclear whether the Regulation applies to its overseas projects.

• According to Huadian, the EIA was not publicly disclosed. In our meeting with the project company, we were not able to get or see a copy of the EIA. Mundul Seima District governor and Bak Khalang commune chief said they have never seen the EIA. Cambodian NGOs have not received the EIA either (Source: Site visit, March 2015).

• No information collected.

• The project is consistent with basin wide assessments and relevant plans according to Huadian (Source: Site visit, March 2015).

• Huadian has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• In the Hydropower Sustainability Report, it is noted that Huadian attaches equal importance to the construction of power stations and the ecological environment, carries out ecological protection projects, and makes efforts to establish ecological indicator systems for rivers. Ecological monitoring and restoration is carried out in order to minimize the biological impact of project construction. Huadian also published a Technical Guide on Tender of Fish Breeding and Releasing Stations and Operation Manual for Fish Breeding and Releasing Stations. However, it is unclear whether these practices, guides and manuals apply to its overseas projects.

• According to the Phnom Penh Post, “the construction of the dam will require the flooding of a 1,270-hectare area of protected forest and destroy the habitats of 184 species of animals, birds, fish and reptiles” (Source: http://www.phnompenhpost.com/national/dam-breaks-ground-amid-concerns).
• According to the TESCO study on the project in 2006, the Peam Krasop National Park and Pham Samkos Wildlife Sanctuary are likely to be impacted by the dam. (Source: Lower Stung Russei Chrum Hydropower Project Draft Final Report by Tokyo Electric Power Services Co. Ltd, August 2006). As we were unable to obtain the EIA, we are unable to review how these impacts were evaluated in the EIA report.
• According to Huadian, the project is located in the Cardamom Protected Area, but the biological impact is limited mainly to the construction area (Source: Site visit, March 2015).
• Timber Green, who was contracted by Huadian for reservoir cleaning, has reportedly abused dam reservoir-clearing permits to run illegal logging outside the boundaries of their license (Source: http://www.phnompenhpost.com/national/shooting-suspect-face-court).
• In the CDM PDD Report for the Lower Stung Russei Chrum Project, Huadian plans to strictly control the construction area and build camps within the project area to reduce the impact on wildlife. The company will also educate its staff to prevent poaching or illegal logging and, in cooperation with the Forestry Administration, train them about wildlife protection. The company will also invite experts to study the need for fish paths. In a public consultation meeting held in September 2009, relevant stakeholders believed that the company should cooperate with local authorities in natural resources monitoring and conservation as well as water management. The proposed solution was cooperation between the project company and Koh Kong forestry administration, fisheries administration and water resources management administration. In the meantime, a clear budget plan should be made specifically for natural conservation and environmental protection (Source: CDM PDD Report for the Lower Stung Russei Chrum Project). However, we didn’t find evidence of this cooperation.
• According to Huadian, the original amount of investment in environmental protection in the EMP is USD3 million, but actual investment has exceeded USD4 million. In addition, Huadian provides an environmental fund (amount unknown) to the government every year, but the company does not know how it has been used (Source: Site visit, March 2015).
• According to Huadian, noise pollution from explosions was identified as one of the main impacts on wildlife, which might drive wild animals away from the areas. To reduce this impact, the company followed standard procedures to reduce noise pollution. Additionally, the forest could help absorb or cancel the noise, so the biological impact was quite limited. The EIA results show there are no migrating fish in the area, so it is not necessary to build a fish path (Source: Site visit, March 2015).

• Huadian has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• Under Huadian’s Regulation on Environmental Protection (Trial Version) Article 20: For hydropower projects, ecological protection shall be strengthened, the reservoir site shall be cleaned up before water impoundment, and resettlement and environmental protection measures shall be in place. Article 26: Pollutants from electricity generation shall be controlled to meet the discharge standards. All branches and wholly-owned companies shall identify the types of pollutants and examine the amount. Discharges of four major pollutants, i.e. SO2, soot, COD and industrial solid waste, shall be integrated into the company’s production and operation indicator system. However, it is unclear whether the Regulation applies to its overseas projects.
• No information collected on specific policies about pollution control during construction.

• According to Huadian, relevant measures and plans are included in the EMP, which was not made available to us for verification (Source: Site visit, March 2015).
• According to the CDM PDD report, good quality machinery will be used to assure air quality in the project area and the company will spray water to reduce dirt and dust pollution. The company will build diversion channels to direct water downstream, bypassing work sites. Temporary dams will be built around work sites to avoid sedimentation. Earth works will be avoided in rainy seasons. The company will effectively manage solid waste and wastewater, install toilets, bathrooms and dump sites far from water sources, build septic tanks and other facilities, and educate all employees about solid waste and wastewater management. Huadian will also restrict blasting time and use low-noise machines to manage noise (Source: CDM PDD Report for the Lower Stung Russei Chrum Project).
• According to Huadian, degreasing tanks, septic tanks, water purifying and solid waste treatment facilities have been installed in various places in the project site. In addition, the water quality in the reservoir has improved because there were decayed leaves and rotting plants before the dam was built (Source: Site visit, March 2015).
• According to Huadian, blasting should only take place between 11:30 am and 5:30 pm (Source: Site visit, March 2015).

• No information collected.

• According to a TESCO report in 2006, there haven’t been any investigations into possible historical sites in the Russei Chrum Basin (Source: Lower Stung Russei Chrum Hydropower Project Draft Final Report by Tokyo Electric Power Services Co. Ltd, August 2006).
• Huadian verified that the project is located in an unpopulated area, therefore no cultural resources have been affected (Source: Site visit, March 2015).

• Huadian has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; and Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• In the Hydropower Sustainability Report, Huadian places emphasis on water and soil conservation in its hydroelectric project design and construction. In the project design process, open excavation is minimized to avoid the damage to the ground surface and project layout is guided by and optimized according to the principle of maximum environmental protection; in the construction process, focus is placed on the waste disposal area, material area and construction roads with grass and trees planted on soil slopes and waste disposal sites for the purpose of slope protection and greening. In the meantime, Huadian strengthens revegetation, restoration and post-construction management to restore the ecological environment, prevent soil erosion and protect rare plants.

• According to Huadian, relevant measures and plans are included in the EMP, which was not made available to us for verification (Source: Site visit, March 2015).
• According to the CDM PDD report, the company will restore rock excavation and soil excavation sites and plant grass in order to reduce soil erosion and prevent landslides. Construction will start in dry seasons to reduce soil erosion risks which are higher in rainy seasons (Source: CDM PDD Report for the Lower Stung Russei Chrum Project).
• According to Huadian, measures taken include carrying out excavation work in dry seasons, building drainage ditches on both sides of the roads, concretizing slopes and roads. During construction, sediment ponds were built but were removed after construction. During our Site visit, we observed concrete roads and drainage ditches as well as side slope protection measures in some areas. However, revegetation was very limited (Source: Site visit, March 2015).

• No information collected.

• According to Huadian, the company keeps a water flow of at least 0.5 m³/s during dry seasons. During our Site visit, we observed there was more water released from the upper dam (more than 0.5m³/s according to the company) than the water released from the lower dam. Our previous visit in early March found little water between the lower dam and the power house and riverway nearly dried up (Source: Site visit, March 2015).
• According to the CDM PDD report, however, the company plans to ensure a water flow of at least 1.1m³/s (Source: CDM PDD Report for the Lower Stung Russei Chrum Project).

• In the Hydropower Sustainability Report, Huadian sticks to the policy of “pre-resettlement compensation, post-resettlement support and development-oriented resettlement” as well as the principle of “original scale, original standards and restoration of original functions”. The company fully respects the will of affected people and ensures the resettled people have the same, if not better, living standards. Huadian also has a policy of “industry-fostered agriculture” and pursues the goal of “moving out, settling down and becoming rich” in its resettlement work. The company aims at transforming the resettlement area into xiaokang (well-off) and model villages with current laws and regulations as the guidance, a long-term compensation mechanism as the guarantee, multiple channels and forms of resettlement as the focus, the development of local competitive industries as the means, and the promotion of the local economy and people’s income as the motivation. However, it is unclear whether these policies and principles apply to its overseas projects.

• According to Huadian, a Social Impact Assessment (SIA) was included in the EIA. The project does not involve resettlement. The major downstream impact is on aquaculture as well as the inundation risks. No livelihood restoration plan for downstream impacted communities has been set up. However, a small fund (several thousand USD) will be provided according to the EIA and will be used through the government to compensate the downstream households. The fund has not yet been set up (Source: Site visit, March 2015).
• In the public consultation meeting held in September 2009, the people living around the project area, such as Koh Por village, requested the company to hire them as priority workers (Source: CDM PDD Report for the Lower Stung Russei Chrum Project).
• However, the company leader and employees we interviewed were neither aware of Koh Por village nor the above solution. According to information collected from other employees and local Cambodians, the Cambodian workers employed by the company were mainly from other provinces. It was also confirmed that some Koh Por villagers were also employed (Source: Site visit, March 2015).

• No information collected.

• According to Huadian, the EIA which includes the SIA was not publicly disclosed. In our meeting with the company, we were not able to get or see the copy of the EIA because the company said that other stakeholders would have to write an official letter to the Ministry of Environment to get the EIA. Therefore, we were not able to assess the SIA (Source: Site visit, March 2015).

• No information collected.

• According to Huadian, at least 3 consultations (the exact number unclear) have been carried out by the consulting firm (Source: Site visit, March 2015).
• According to the CDM PDD report, SAWAC company which completed the Initial Environmental Impact Assessment organized a stakeholder consultation meeting from September 19 to 24, 2009 (Source: CDM PDD Report for the Lower Stung Russei Chrum Project).
• In our interviews in March, local people in Koh Kong said they were not informed of any information about the dam construction and they were concerned about the safety issues (Source: Site visit, March 2015).
• Cambodian NGOs such as NGO Forum also said they knew little about the project due to lack of information disclosure (Source: Site visit, March 2015).
• The leaders at the district and commune levels said Huadian did not have any information exchanges with them (Source: Site visit, March 2015).

• No information collected.

• According to Huadian, there is no direct complaint mechanism for the project (Source: Site visit, March 2015).
• The family members of the Cambodian worker who was electrocuted and killed in July 2011 went to ADHOC (a famous human rights NGO in Cambodia) to prepare a complaint to submit to police because Huadian denied responsibility claiming the worker had died from fainting. The company later agreed to pay USD4,700 to the victim’s family after the police intervened (Source: http://www.phnompenhpost.com/national/third-worker-killed-hydrodam).

• No information collected.

• According to Huadian, there is no benefit sharing mechanism in place, but the company has provided other benefits to the community such as infrastructure (roads and three 120m long bridges), and power transmission lines (34.5km) which connect to Koh Kong province. The company is also ready to provide cheaper electricity to Koh Kong if requested (Source: Meeting with Project Managers during Site visit, March 2015).
• However, the Bak Khalang commune chief near the project area earlier said he did not see the transmission lines to Koh Kong (Source: Site visit, March 2015).

• Huadian has endorsed the Global Compact, whose human rights principles are: Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and Principle 2: Businesses should make sure that they are not complicit in human rights abuses. The labor principles in the Global Compact include: Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: Businesses should uphold the elimination of all forms of forced and compulsory labor; Principle 5: Businesses should uphold the effective abolition of child labor; and Principle 6: Businesses should uphold the elimination of discrimination in respect of employment and occupation.

• According to Huadian, the company has not had any labor-related disputes or fines. The project company offers an attractive salary to employees as well as free accommodation and transportation. A new building will be built in mid-April 2015 for Cambodian workers with air conditioning, private bathrooms and a decent living space. A canteen that serves Cambodian food will also be available. The company said they would build another building specifically for medical services and would staff it with doctors from Phnom Penh (Source: Site visit, March 2015).
• According to a Cambodian employee that has worked in the hydropower plant, the living conditions for Cambodian workers during construction were comparatively worse than the Chinese workers (Source: Site visit, March 2015).
• The majority of interviewed Cambodian workers kept on during operation period were generally satisfied with their living conditions, salaries and working conditions. However, some felt that the salary was low and feel that the language barriers are stressful to manage (Source: Site visit, March 2015).
• ADHOC, a local Cambodian NGO, commented in a news article in 2011 that about 100 Cambodian employed on the project didn’t have health insurance (Source: http://www.phnompenhpost.com/national/chinese-workers-die-hydro-site-rock-fall).

• Huadian Regulation on Intrinsic Safety of Working Environments for Power Generation Companies 2013 raises “General Requirements,” “Universal Requirements,” “Change Management” and “Special Requirements” for different types of working environments in different areas, though not covering all maintenance work. “Universal Requirements” are normal requirements applicable to certain types of hazardous maintenance working environments while “Special Requirements” are specific requirements for thermal power-, wind power-, and hydropower-related maintenance work.
• Huadian has developed an Occupational Diseases Prevention Plan (2010-2015).

• Two accidents occurred in July 2011 in which three people died. Two Chinese workers were smashed by falling rocks, and one Cambodian worker was electrocuted at the project site (Source: http://www.phnompenhpost.com/national/chinese-workers-die-hydro-site-rock-fall; http://www.phnompenhpost.com/national/third-worker-killed-hydrodam).
• The company does not have a specific occupational safety and health department. However, to ensure a healthy and safe working environment, the company provides protection equipment (helmets, shoes) to all workers as well as safety training. Air conditioning, insect repellent and clean drinking water are also provided to prevent disease (Source: Site visit, March 2015).

• No information collected.

• According to Huadian, during construction there were about 2,000 Cambodian workers and 300-400 Chinese workers. Cambodian workers did general or physical work and no Cambodian technical staff were hired. During the current operation period, 100 Cambodians, mainly working as drivers, cleaners, porters, chefs, translators, mechanics, operators, and maintenance workers, are employed on site. Technical staff account for about 30% of employees. The company provides safety equipment and training. The Cambodian employees we met during the Site visit also confirmed that they received training, especially safety training, before work and they were provided technical support when necessary by a manager (Source: Site visit, March 2015).
• After the Cambodian worker was electrocuted and killed in July 2011, the police questioned Huadian on why the Cambodian worker was made to do a job for which he had no experience (Source: http://www.phnompenhpost.com/national/third-worker-killed-hydrodam).

• Huadian has endorsed the Global Compact. The anti-corruption principle in the Global Compact is that ‘‘Businesses should work against corruption in all its forms, including extortion and bribery’’.

• No evidence of improper involvement in local political processes.
• Huadian analyzed corruption risks and concluded the risks were bearable and controllable. Internal control measures have been taken to prevent corruption. For instance, at least two people need to be present when making major decisions for the purpose of mutual supervision. Anti-corruption training is provided on a monthly basis (Source: Site visit, March 2015).

• No information collected.

• Relevant legal analysis was included in the feasibility study. The China headquarters are responsible for surveying relevant laws and regulations as well as legal compliance. The headquarters have also released country-specific risk reports (Source: Site visit, March 2015). Huadian started construction without a formal EIA approval, which violates Cambodian law (Source: CDM PDD Report for the Lower Stung Russei Chrum Project).

• No information collected.

• Not applicable.

• Huadian’s Regulation on Hydropower Project Management Article 8: the overall objective of hydropwer project safety management is to achieve zero personal deaths. The Regulation also provides safety management processes in the pre-construction and construction stages.
• Huadian has developed an Overall Emergency Plan. It notes that the group’s emergency plan system includes oveall emergency plans, specialized emergency plans, and emergency plans by headquarters and subsidiaries.
• Huadian’s Regulation on Intrinsic Safety of Working Environments for Power Generation Companies 2013 raises “General Requirements,” “Universal Requirments,” “Change Management” and “Special Requirements” for different types of working environments in different areas, not covering all maintenance work, though. “Universal Requirements” are normal requirements applicable to certain types of hazardous maintenance working environments while “Special Requirements” are specific requirements for thermal power-, wind power-, and hydropower-related maintenance work.
• Huadian Regulation on Technical Supervision Management of Hydropower and New Energies Projects focuses on a safety and quality requirements of technical supervision work. It notes that technical supervision work for hydropower projects covers reservoir, dams, water diversion structures and foundations, side slopes, gates and production buildings.
• Huadian’s Emergency Plan for Floods and Dams has been developed to provide procedures for water disasters prevention and emergency reponses within the group.

• According to Huadian, Chinese standard procedures and plans were adopted. They cover a variety of emergencies including dam collapse, grid collapse, storm rains, food poisoning, terrorism (Source: Site visit, March 2015).
• According to Huadian, emergency preparedness training is provided to all employees (Source: Site visit, March 2015).

• Huadian’s Emergency Plan for Flood Control and Dams Article 12 states that when the reservoir is in a dangerous situation, power generation companies should immediately warn the downstream in the first time, quickly deal with the risks, and report to the local government, the group, and flood prevention and dam safety management institute. When the reservoir has collaps risk due to a flood event beyond the design level or any other force majeure, the company should give warnings based on a dam collap flood risk map in advance so that the population has enough time to evacuate. Article 26 states that information about flood control and dam safety should be released in a timely, accurate, objective and comprehensive manner. Article 31 states different levels of responsibilities are adopted in terms of publicly releasing information of flood, disaster, flood prevention and dam safety. General public information can be released to the public through media.

• According to Huadian, there is no public disclosure mechanism in place. In our interviews in March, local people in Koh Kong said they were not informed of any information about dam construction and they were concerned about the safety issues. The leaders at district and commune levels said Huadian did not have any information exchange or communication with them (Source: Site visit, March 2015).