• Sinohydro International has committed to behave in an accountable, transparent, ethical and fair manner in its marketing and contractual and operating processes (Source: Sustainable Development Policy).
• They also committed to limiting the impact of business activities on the environment (Source: Sustainable Development Policy).
• They further committed to “govern its business by adopting management systems in accordance with ISO14001, OHSAS18001, ISO 26000 to improve resources efficiency, protect the natural environmental, community benefits, and employees’ health and safety at the workplace” (Source: Sustainable Development Policy).
• The most typical ongoing environmental initiatives are “save energy and reduce emissions” inside the company, and “save water and electricity” in the project sites (Source: Sinohydro International HSE Department Interview, March 27, 2014).

• Sinohydro International committed to full compliance with local legislation, international standards and Sinohydro International’s requirements (Source: Q/SHL. 101-2010 QSHE Management System).
• They have also committed to complying with Chinese laws and local laws, whichever are higher (Source: Sinohydro International HSE Department Interview, March 27, 2014).

• According to Sinohydro International, the environmental standards and labor standards adopted in the CCS project meet strict Ecuadorian laws, which are higher than the standards set by Chinese laws (Source: Site visit, October 2014).

• Sinohydro International first launched QHSE Management System (Chinese version) in 2010, and lauched a new HSE Management Guidance (English version) late 2014 (Source: Q/SHL. 101-2010 QSHE Management System; Sinohydro International HSE Department Interview March 27, 2014; Company meeting, April 22, 2015).
• Sinohydro International complies with OHSAS 18001, ISO 9001 and ISO 14001. The QHSE system was developed based on these three standards. A qualified third party does annual auditing every year (Source: Q/SHL. 101-2010 QSHE Management System; Sinohydro International HSE Department Interview, March 27, 2014).

• The EMP covers topics such as water quality, solid waste management, noise, air quality, and gas and fuel disposal. The EMP hasn’t been publicly disclosed, but according to Sinohydro International, the Ecuadorian government, the local government and communities should have all received copies (Source: Site visit, October 2014).
• The EMP was developed to comply with ISO 14000. Due to the project size, Sinohydro International regularly develops EMP updates to reflect the changing needs of impacts management. We were able to review the hard copy of the Chinese and Spanish EMP updates developed in 2013 (Source: Company Meeting, April 22, 2015).

• Sinohydro International committed to continue to take steps to preserve biodiversity and affected ecosystem, protect World Heritage areas, and restore any disturbed areas in a timely manner. (Source: Statement of Ethical Principles 2014)
• The Wildlife Control Procedure of the 2014 Sinohydro International HSE Management Guidance says the operations of construction will be restricted to the construction site allocated lands and construction activities will be performed in compliance with applicable national regulations and international conventions in terms of wildlife biodiversity and protecting vegetative ecosystem.

• The small adjustable reservoir and an associated 28 km road built within the Sumaco Galeras National Park have negative impacts on the environment. It was reported by Sinohydro International that there is mitigation for the park area. The Ecuadorian government’s CCS company is in charge of addressing this issue. Other environmental impacts are associated with general construction, e.g.tailings (Source: Site visit, October 2014).
• According to Sinohydro International, the EIA identified impacted flora and fauna (Source: Site visit, October 2014).
• The contract requires Sinohydro International to rehabilitate the area intervened and return it to its primary condition. Sinohydro International does annual studies on fauna, but they are not publicly available (Source: Site visit, October 2014).
• Sinohydro International has developed revegetaion and reforestation plan (Source: Plan De Revegetacion Y Reforestacion En La Via Embalse Compensador, 05/12/2013).
• As agreed with the government, some debris sites will be planted with native vegetation species, which will be done in conjunction with a university team from Quito and the Ministry of the Environment (Source: Site visit, October 2014).

• Sinohydro International is committed to the health and safety of any one who may be affected by their operations. They are committed to preventing injury, ill health, damage and loss arising from their operations as well as complying with all regulatory or other legal requirements pertaining to safety, health and the environment (Source: Statement of Ethical Principles 2014)
• In 2014, Sinohydro International approved new HSE Management Guidance, which includes procedures of noise management, waste management, dust control, air emissions control, hazardous waste, water quality control, and contaminated land, etc. (Source: HSE Management Guidance, 2014).

• The EMP covers topics such as water quality, solid waste management, noise, air quality, and gas and fuel disposal (Source: Site visit, October 2014).
• Sinohydro International contracted an Ecuadorian company to do secondary water treatment for the wastewater from both the construction and work camps (Source: Site visit, October 2014).
• Sinohydro International tests water quality (for both discharges to the river and potable water) and air quality onsite, and has to provide monthly reports to the project developer (Source: Site visit, October 2014).
• Sinohydro International develops monthly reports on contract compliance and environmental quality monitoring. A third party is invited to monitor water quality of wastewater discharge and drinking water, and air quality (Source: Site visit, October 2014).

• Sinohydro International is committed to compliance with the rule of law, respecting for local culture, religion and customs, providing locals with skills training and equal employment and business opportunities, and contributing to local society’s development (Source: Sustainable Development Policy).
• The Cultural Heritage Control Procedure of 2014 Sinohydro International HSE Management Guidance requires the company to: check the list of UNESCO World Heritage Sites prior to commencing work at the site and identify physical cultural resources; consult concerned government authorities, relevant NGOs, experts and local people in documenting the presence and significance of physical cultural resources, assessing the nature and extent of potential impacts on these resources, and designing and implementing mitigation plans; and disclose draft mitigation plans in a timely manner, before appraisal formally begins, in an accessible place and in a form and language that are understandable to key stakeholders.
• The Environmental Management-Public Relations Procedure of 2014 Sinohydro International HSE Management Procedure requires the company to implement an appropriate action plan of measures to avoid and mitigate for adverse effects concerning indigenous people, preserve cultural heritage and physical cultural resources; and avoid their destruction or damage.

• Sinohydro International reported that no archaeological vestiges were found within the construction area (Source: Site visit, October 2014).

• In 2014, Sinohydro International approved a new HSE Management Guidance, which includes an Erosion and Sedimentation Control Procedure.

• Sinohydro International has developed a revegetaion and reforestation plan (Source: Plan De Revegetacion Y Reforestacion En La Via Embalse Compensador, 05/12/2013).
• We were shown three debris site deposits that are already covered with vegetation. As agreed with the government, some debris sites will be left alone to let vegetation grow and other sites will be planted with native vegetation. The latter will be done in conjunction with a university in Quito and the Ministry of the Environment (Source: Site visit, October 2014).
• Construction has been divided into different phases to avoid the sedimentation problem potentially caused by massive construction (Source: Site visit, October 2014).
• Sinohydro International has adopted sedimentation prevention and protection measures (Source: Site visit, October 2014).

• Sinohydro International has committed to defining an open and effective dialogue and communication mechanism to facilitate information exchange with customers, employees, subcontractors, communities and authorities on matters of common interests relating to health and safety at the workplace, the environment, and the concerns of economy and society (Source: Sustainable Development Policy 2014).
• Sinohydro International committed to an open dialogue with all stakeholders, including owners as well as local partners, public, governmental institutions, NGOs, and local associations, to mitigate disturbances created by operations, working in compliance with local cultural and community practices (Source: Statement of Ethical Principles 2014).
• They also committed to publishing their environmental efforts and their progress on the implementation of their environmental policy and maintaining relations with the local authorities and communities in the countries where they operate (Source: Q/SHL. 101-2010 QSHE Management System).
• The Environmental Management-Public Relations Procedure of 2014 Sinohydro International HSE Management Procedure requires the company to conduct effective consultations with Affected Populations on their livelihoods that allow for participation in planning, implementation and monitoring by all affected groups.

• Sinohydro International did not conduct a community survey prior to commencing construction (Source: Site visit, October 2014).
• There is a lack of systematic and meaningful reporting and information disclosure mechanisms to local communities and organizations (Source: Site visit, October 2014).

• Sinohydro International is committed to responding in an active manner to any complaints and/or grievances that arise from customers, employees, subcontractors, communities and authorities (Source: Sustainable Development Policy 2014).
• 2014 Sinohydro International HSE Management Guidance includes a Grievance and Complaint Mechanism Procedure.
• The Environmental Management-Public Relations Procedure of 2014 Sinohydro International HSE Management Procedure says that all of Sinohydro International’s business will have community complaints, conflicts and grievance procedures and the grievance procedure will be publicized through village chiefs and throughout the local population. In case farmers suffer damage from construction or operation activities on acquired lands, they shall be entitled to claim damages through the Environmental Management and Monitoring Unit. Conflicts between workers and villagers must be tracked and signed off by relevant managers. The villagers who suffer from road dust and excessive traffic or accidents should have a functional channel to make complaints and claims for compensation.

• Communities and staff can submit disputes and complaints through two channels in either verbal or written form to the Human Resources Department and Labor Union. The Union carries out monthly meetings to collect complaints from the staff. The HR Department will deal with the complaints. If the union and HR cannot resolve a complaint, a higher management team will discuss and solve the complaints (Source: Site visit, October 2014).
• According to Sinohydro International, no community complaints have been reported. We were unable to check on this information with communities (Source: Site visit, October 2014).
• Sinohydro International has received complaints and requests from employees, mainly about salary and benefits (Source: Site visit, October 2014).

• Sinohydro International committed to compliance with the rule of law, respecting for local culture, religion and customs, providing the locals with skills training and equal employment and business opportunities, and contributing to local society’s development (Source: Sustainable Development Policy 2014).

• Sinohydro International committed to complying with the rule of law, respecting local culture, religion and customs, providing the locals with skills training and equal employment and business opportunities, and contributing to local society’s development (Source: Sustainable Development Policy 2014).
• The company is also committed to treating all employees equally, requires their employees to comply with all applicable laws and regulations, forbids discrimination, and is committed to providing employees with training opportunities for career growth (Source: Statement of Ethical Principles 2014).

• In 2012, there was a strike by some Ecuadorian workers due to compensation and safety complaints. A detailed investigation was carried out. The Ministry of Labor confirmed that Sinohydro International didn’t violate laws of payment, health and safety, while Sinohydro International still made efforts to further improve the safety equipment provision standards, established the labor union and signed a group contract with the workers (Source: http://renewables.seenews.com/news/ecuador-says-hydropower-project-not-halted-by-strike-318226; Company meeting, April 21, 2015).
• Sinohydro International has received complaints and requests from employees, mainly about salary and benefits. On average 10-20 complaints are received each month, most of which are in verbal form from the staff (Source: Site visit, October 2014).
• Workers at Sinohydro International established their own union to negotiate salary and benefits with Sinohydro International (Source: Site visit, October 2014).
• All the interviewed personnel (both Chinese and Ecuadorians) rate the living environment, salary and working environment above four out of five (Source: Site visit, October 2014).

• Sinohydro International committed to the health and safety of any persons who may be affected by their operations; to prevent injury, ill health, damage and loss arising from their operations, and to comply with all regulatory or other legal requirements pertaining to safety, health and the environment (Source: Statement of Ethical Principles).
• They have also committed to taking all appropriate measures to provide a safe and healthy workplace, and complying with local legislation, international standards and the company’s requirements to protect the environment (Source: Occupational Health Safety and Environmental Policy).
• Sinohydro International is committed to establishing, implementing and developing the Health, Safety and Environmental Management System in compliance with relevant standards and regulatory requirements (Source: Occupational Health Safety and Environmental Policy).
• They are also committed to constantly reviewing and monitoring the effectiveness of the HSE Management System for continuous improvement; to providing leadership, required resources, effective training and communications to ensure the implementation of the HSE management System; to identifying and assessing risks, health and safety hazards and implementation actions; and to promoting safe behavior inside the group (Source: Occupational Health Safety and Environmental Policy).

• In 2012, there was a car accident where one Chinese worker and one Ecuadorian worker died, and four workers were seriously injured (three Ecuadorian and one Chinese) (Source: Site visit, October 2014).
• There was another accident, which resulted in the death of a Chinese worker. The death occurred while the worker was doing maintenance work for the Tunnel Boring Machine used to excavate the 24.8 km channel (Source: Site visit, October 2014).
• A seperate workplace incident on December 13, 2014 resulted in the deaths of 13 people. The local procuratorate is still investigating the incident and will provide a final official investigation report. The structural and geological engineers invited by the local procuratorate have confirmed that the incident was caused by force majeure (Source: http://www.hydroworld.com/articles/2014/12/at-least-13-killed-by-collapse-at-ecuador-s-coca-codo-sinclair-hydropower-plant.html).
• Sinohydro International provides appropriate equipment for workers, monitors air quality, light conditions, noise conditions and temperature conditions at the construction sites and provide health checks to the workers. Some workers told us there is room for improvement in industrial safety measures (Source: Site visit, October 2014).

• Sinohydro International seeks to make a lasting positive impact in the host countries, including recruiting and training local workers whenever possible and promoting their professional development (Source: Statement of Ethical Principles).
• Sinohydro International commits to compliance with the rule of law, respect for local culture, religion and customs, providing the locals with skills training and equal employment and business opportunities, and contributing to local society’s development (Source: Sustainable Development Policy).

• There are about 7,000 workers (1,463 Chinese, 4,989 Ecuadorian, and a small number of Mexicans, Germans and others). Some jobs require skills and specializations that Ecuadorians do not have (Source: Site visit, October 2014).
• Training was provided to local hires. Professional Chinese workers were assigned to teach and train the Ecuadorian workers until they could completely meet the requirements for the positions (Source: Site visit, October 2014).
• Sinohydro International also supports a town near the project site (Canton Chaco) through an agreement with the mayor to use their personnel and machinery/equipment (such as trucks and other heavy equipment for roads, etc.) (Source: Site visit, October 2014).

• Sinohydro International prohibits, under all circumstances, the use of bribery and similar practices in any form and at all levels of their business. It prohibits offering, giving or accepting a bribe or kickback in any form, direct or indirect, from or to any person or party, including customers, representatives, contractors, suppliers, and government officials (Source: Statement of Ethical Principles).
• Sinohydro International also seeks to ensure that improper payments are not channeled through intermediaries including joint venture partners, consultants, agents or other representatives, suppliers, and subcontractors (Source: Statement of Ethical Principles).
• Relevant policies and procedures in place include: the Anti-Bribery Policy and Guide, The Representative Due Diligence Guide, The Gifts and Hospitalities Policy, and the Procurement Policy (Source: Compliance Program Announcement).
• The Audit and Monitoring Department is in charge of corruption and bribery prevention management (Source: Sinohydro International HSE Department Interview, March 27, 2014).
• The company has developed a regular training program for employees on topics relevant to compliance with anti-corruption laws (Source: Sinohydro International HSE Department Interview, March 27, 2014).

• Corruption risk analysis and assessment is regularly conducted and the results have been that the risk is controllable (Source: Site visit, October 2014).
• Anti-corruption training is conducted for those in leadership roles and managers (Source: Site visit, October 2014).
• Sinohydro International follows its China issued policies and uses collective decision-making process to prevent corruption. There are internal norms and procedures that need to be complied with (Source: Site visit, October 2014).

• Sinohydro International is committed to complying with the requirements stated in local laws and in the guidelines issued by the Chinese government and international organizations (Source: Sinohydro International HSE Department Interview, March 27, 2014).
• They have also established a Compliance Program (Source: Compliance Program Announcement).

• EMP includes an analysis of relevant laws and regulations (Source: Site visit, October 2014).
• The contracting department of Sinohydro International is responsible for risk analysis and related legal compliance work (Source: Site visit, October 2014).
• The company was fined in 2012 by the Ministry of Labor because the project did not meet the legal requirement of hiring 4% of the work force with disabilities (Source: Site visit, October 2014).

• Sinohydro International also established a safety risk identification, assessment and management program and an emergency preparation and response program (Source: Q/SHL. 101-2010 QSHE Management System).

• There is a fire emergency response plan, a flood emergency response plan, and a volcano emergency response plan in place (Source: Site visit, October 2014).
• The company’s internal safety assessment results were good in both 2012 and 2013 (Source: Site visit, October 2014).
• The report on the recent fatal accident (December 13, 2014) should shed some light into bad engineering practices and/or insufficient risk prevention.
• SHSA provides training on the emergency response mechanism about three times a year. A few thousand staff have attended the trainings (Source: Site visit, October 2014).

• Sinohydro International is committed to defining an open and effective dialogue and communication mechanism to facilitate information exchange with customers, employees, subcontractors, communities and authorities on matters of common interests relating to health and safety at the workplace, the environment, and concerns of the economy and society (Source: Sustainable Development Policy).
• They have developed specific procedures about how to inform the communities with different risks from construction activities in the relevant HSE procedures(Source: Company meeting, April 21, 2015).

• No information collected.