• The 2013 CSR Report noted that Three Gorges has a certified management system, an environmental management system and an occupational health and safety management system certification, but it is not clear which body has awarded these certifications. It also reported that four subsidiaries including China International Water and Electric Corporation have been certified under ISO 14001 (Source: 2013 CSR Report).
• According to the 2013 CSR Report, Three Gorges has commited to following the Guide on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce (Source: 2013 CSR Report).

• No information collected.

• No information collected.

• According to the 2013 CSR Report, Three Gorges has made a commitment to follow the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce (Section 4.6.1). Environmental Management of these guidelines includes the following requirements: “establish, implement, and improve environmental management systems, develop environmental management schemes for all contracting projects, and invite specialized institutions to conduct environmental management system certification and registration” (Sources: 2013 CSR Report; Guidelines on Social Responsibility for Chinese International Contractors).

• A separate EMP report was developed by a local consulting firm Chemsain. The EMP includes action plans for ecological impacts management, traffic safety, health and safety, soil erosion and soil stability, waste generation and management, hydrology and drainage, water quality management, noise pollution, air pollution, socio-economic consideration, decommissioning and abandonment, and emergency response (Source: Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• Environmental departments at Bintulu and Kuching both have copies of the EMP and carry out regular site monitoring (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• A Chinese researcher from Thailand who has been in contact with Three Gorges was able to obtain a copy of the EMP upon request (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• International Rivers was also able to locate an electronic copy of the Project EMP publicly available online.

• The 2013 CSR Report noted that Three Gorges carried out an EIA and an SIA for all new projects in 2013.
• According to the 2013 CSR Report, Three Gorges committed to follow the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce (Section 4.6.1). Environmental Management requires companies to “conduct environmental impact assessments prior to the construction of projects, evaluate risks and impacts of project activities on the environment with respect to risk management and sustainable development, and take preventive measures to control such risks and impacts on the environment.”

• Not relevant to EPC Project Assessment.

• No information collected.

• Not relevant to EPC Project Assessment.

• Three Gorges developed a matrix to identify the strategic importance of different corporate social responsibilities. Within this matrix, ‘Biodiversity’ is rated as highly important strategically (Source: 2013 CSR Report).
• Three Gorges has committed to following the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce. The relevant section – 4.6.4 Ecological Protection – requires the company to “protect rare and precious fauna and flora species and their natural habitat, and reduce a project’s impact on biological diversity.” The same relevant section also states that “during the implementation of a project, attention must be paid to the protection of ecological systems (wetlands, wild animal passage, protection zones and farmland) and restore in a timely manner damages that have already occurred.” As well as this, the guidelines also state that Thee Gorges Corporation should “encourage and organize employees of the enterprise and local inhabitants to conduct charity activities aiming at protecting and restoring ecological systems.”

• The ecological impacts from the site preparation and construction mentioned in the EIA and EMP include the following: the impact on the migration of aquatic species through the diversion of water flows, the physiological and psychological stress to wildlife from noise, more intense hunting activities due to an influx of workers to the area, habitat loss and fragmentation, death of terrestrial animals by reservoir clearing and inundation, change of fish distribution and other aquatic resources by impoundment, and loss of vegetation and biodiversity because of impoundment. Sixteen bird species and 13 mammal species are protected under the Sarawak Wildlife Protection Ordinance 1998. No IUCN Red List Species were reported in the EIA. However, the descriptions of the impacts are vague and brief in both documents (Sources: Environmental Impact Assessment for Proposed Murum Hydroelectric project, Belaga District, Kapit Division, Sarawak; Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• The EMP includes an “Ecological Impacts Management Plan”. The Action Plan includes 15 clauses relevant to phased biomass removal, controlled removal of vegetative cover, adoption of natural base flow, wildlife rescue support and management, establishment of fish hatcheries, prohibition of hunting and poaching, native flora conservation and rehabilitation (Source: Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• According to Three Gorges, they have generally followed the EMP, but we were not able to collect evidence to verify this or gain further information on the implementation of this action plan (Source: Company interview by a Chinese researcher from Thailand, January 2015).

• The 2013 CSR Report notes that Three Gorges has developed a Solid Waste Management Regulation (Source: 2013 CSR Report), and as such is committed to the following guidelines: completely avoid environmental incidents, 100% implementation of simultaneous design, construction and operation of environmental protection measures with the main project, 100% compliance with pollution discharge standards, and treat 95% of sedimentation and erosion issues, in the period of the Twelfth Five Year Plan (2010-2015)(Source: 2013 CSR Report).
• Three Gorges wastewater treatment management strategy in overseas projects is to adopt a package treatment system or relevant simple treatment measure to treat the domestic wastewater, and to treat the construction wastewater according to the local legal requirement and contract requirement to meet the discharge standards. The solid waste management strategy is to set up a solid waste treatment facility or contract local professionals to treat and classify the solid waste at the same time (Source: 2013 CSR Report).

• The EMP includes action plans to address waste generation and management, water quality management, noise pollution management, air pollution management, the concerns of health and safety in the transfer operations, construction, quarry and tunnel operations, and a separate action plan to address traffic safety issues (Source: Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• According to Three Gorges, they have generally followed the EMP, but we were not able to collect evidence to verify this or gain further information on the implementation of this action plan (Source: Company interview by a Chinese researcher from Thailand, January 2015).

• Three Gorges has committed to following the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce. The relevant section, 4.7.4 Culture and Education, notes that companies should “respect and protect the cultural traditions and heritage of the community, and provide support for community cultural activities and projects when necessary.”

• The EMP proposed to relocate burial grounds in each of the affected settlement areas if necessary, based on local cultures and tradition, and after consultation with the communities concerned and give every effort to preserve all aesthetic, cultural and historical sites (Source: Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• According to Three Gorges, the local indigenous communities have a megalithic culture and Three Gorges carried out geological surverys and modified the dam design to avoid impacts on the left side of the dam. Three Gorges also helped to build a supporting frame for the megalithic site and provided support to the local people during pilgrimage (Source: Company interview by a Chinese researcher from Thailand, January 2015; Three Gorge’s comments on the draft, May 25th, 2015).

• Three Gorges committed to completely avoid environmental incidents, 100% implementation of simultaneous design, construction and operation of environmental protection measures with the main project, 100% compliance with pollution discharge standards, and treatment for 95% of sedimentation and erosion issues, in the period of Twelfth Five Year Plan (2010-2015) (Source: 2013 CSR Report).
• Three Gorges sedimentation and erosion management strategy in overseas projects is to adopt various prevention and treatment measures such as pre-dredge drainage canals, hill protection, and vegetation and land leveling (Source: 2013 CSR Report).

• The EMP includes an action plan to address soil erosion and slope stability (Source: Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• According to Three Gorges, they have generally followed the EMP, but we were not able to collect evidence on this or further information on the implementation (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• Three Gorges claimed to have established nursery sites to help with revegetation. They also invited local people to teach how to plant and improve the survival rate. Three Gorges has developed decommissioning and restoration plans and timetables, and submitted to the Department of Environment (Sarawak) for approval (Source: Company interview by a Chinese researcher from Thailand, January 2015).

• No information collected.

• Three Gorges proposed a new design of discharge outlets to allow an environmental flow of 8m3/s from the dam, in order to minimize the downstream impacts. The proposal was accepted by the developer Sarawak Energy Berhad (Source: Three Gorges's comments on the draft, May 25th, 2015).

• Three Gorges locates resettlement at a “medium” level in terms of strategic importance in regards to their own matrix for identifying the strategic importance of different corporate social responsibilities (Source: 2013 CSR Report).

• Not relevant to EPC Project Assessment.

• Three Gorges carried out an EIA and an SIA for all new projects in 2013 (Source: 2013 CSR Report).
• Three Gorges has committed to following the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce. The relevant section, 4.7.1 Community Involvement and Communication, commits companies to “visit the communities where a project is located and evaluate the potential impacts of project activities on the community, learn the needs of the community, and identify development priorities.”

• Not relevant to EPC Project Assessment.

• In the 2013 CSR Report, Three Gorges outlined that one of their community engagement strategies is to establish engagement mechanisms for community representatives to participate in project construction and development (Source: 2013 CSR Report).
• Three Gorges has committed to following the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce. The relevant section, 4.7.1 Community Involvement and Communication, requires companies to “actively communicate project related information and learn and respond to the opinions and suggestions of stakeholders” and “develop community engagement plans and participate in community and public service and management activities.”

• Villagers from impacted villages of Tegulang and Metalun reported that Three Gorges representatives have not visited the villages or attended consultation meetings in relation to any dam building issues. One of the areas where a local government official suggested that Three Gorges could do better is if they met with the local people in order to communicate and integrate with the local society in a more meaningful way as outlined by their Social Responsibility guidelines (Source: Field trip, January 2015).

• No information collected.

• There is no existing local dispute or complaints mechanism put in place by either government or companies (contractor or developer) that affected villagers are aware of (Source: Field trip, January 2015).
• Three Gorges said they have received few compensation complaints from the local communities. As instructed by the developer SEB, they report complaint cases to SEB for action whenever they receive complaints from the communtities (Source: Three Gorges’s comments on the draft, May 25th, 2015).

• In the 2013 CSR Report, Three Gorges identified that community development was rated as ‘‘Low’’ in terms of strategic importance. The ranking was based on a matrix developed by the company to identify the strategic importance of different corporate social responsibilities (Source: 2013 CSR Report).
• Three Gorges outlined that their management strategies of helping local development include the following: continuously help to improve local infrastructure, promote local employment, respect local culture; actively participate in local emergency support; and give charity gifts (Source: 2013 CSR Report).
• Three Gorges has committed to following the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce. The relevant section includes requirements that companies “utilize project skills and support the development of public infrastructure in the community, including transportation, telecommunication, drinking water, and sanitation” (SC9), as well as “help advance public services, management, and health care systems of the community to improve living conditions” (SC10) and “take into consideration community practicalities, explore local resources to help the community develop featured industries” (SC11).

• International Rivers was not able to collect any evidence about a long term benefit sharing scheme planned or promised. However, according to Three Gorges, they have sought to help local people in many ways. For example, they have built a house for a local resettled family that lost their old house and assets in a fire (in the area now inundated by the dam) and sent food as gifts to local people. Now Three Gorges is considering building a hospital for the local people (Source: Company interview by a Chinese researcher from Thailand, January 2015).

• In the 2013 CSR Report, Three Gorges identified that human rights were rated as ‘‘Low’’ in terms of strategic importance. The ranking is based on a matrix developed by the company to identify the strategic importance of different corporate social responsibilities (Source: 2013 CSR Report).
• In the 2013 CSR Report, Three Gorges said one of their equal employment management strategies is to respect the rights to equal pay and non-discrimination, as well as to comply with labor laws (it’s not clear whether the labor law also refers to labor law in the host country) (Source: 2013 CSR Report).

• Reported by Three Gorges,there were four cases filed by the local workers because they were unhappy with the termination of their contracts. The company terminated their contracts because the workers failed to comply with company policies and ignored warning letters. The workers admitted their mistakes after being questioned by the Labor Department and agreed to settle the cases outside of court. Three Gorges provided additional compensations to them (Source: Three Gorges’ comments on the draft, May 25, 2015).
• Chinese workers interviewed reported that their complaints to Three Gorges are mostly solved after negotiation. Indonesian workers interviewed in the field reported that they can only complain to the private recruitment agent because of language problems, however the agent representatives have not been able to help solve their problems (Source: Field trip, January 2015).
• According to Three Gorges, the company buys CIDB green cards and insurance for every worker, including the workers from labor service providers (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• The Malaysian workers earn Malaysian Ringgit (MR) 8/hr for up to 12 hours per day (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• Chinese workers feel that the living conditions, salary, and working conditions are acceptable. However Indonesian workers reported when they arrived at the work site, their passports were seized and they were required to sign a different contract than what they thought they had agreed to. They were not in possession of any CIDB Green Card to enable access to basic accident and death insurance. They rated living conditions and salary as bad (Source: Field trip, January 2015).

• In the 2013 CSR Report, Three Gorges identified that occupational health was rated as ‘‘Low’’ in terms of strategic importance. The ranking was based on a matrix developed by the company to identify the strategic importance of different corporate social responsibilities (Source: 2013 CSR Report).

• In 2009 and 2010, there were a few safety incidents due to blasting, construction collapse, and electric shock, some of which resulted in deaths. The local government has given warnings to Three Gorges. After this, Three Gorges made more efforts to implement the safety management measures. Since April 23, 2011, there has been no more fatality accident. In the end of 2014, SEB gave Three Gorges an award called the 10 Million Manhour safety prize (Source: Company interview by a Chinese researcher from Thailand, January 2015; Three Gorges’ comments on the draft, May 25, 2015).
• According to Three Gorges, the company has established a safety management system to comply with the requirements of Three Gorges Group, as well as the Chinese government and Malaysian government (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• Chinese workers reported that everyone has been provided with protective equipment and is required to wear this before going to work. The company also bought accident insurance. But Indonesian workers said that they have to buy the helmets and rubber shoes themselves, and have no accident insurance. As well as this the medical services on site are not free to them (Source: Field trip, January 2015). According to Three Gorges, every worker onsite is provided with personal protection equipment and covered by Group Personal Accident Insurance and medical and Surgical Insurance provided by the company (Source: Three Gorges’ Comments on the draft, May 25, 2015).

• In the 2013 CSR Report, Three Gorges said one of their management strategies in the resettlement of affected people is to promote local employment by creating job opportunities and providing technical training. Three Gorges outlined that their management strategies of helping local development are as follows; continuously help to improve local infrastructure, promote local employment, respect local culture, and actively participate in local emergency support and give charity gifts (Source: 2013 CSR Report).
• Three Gorges has committed to following the Guidelines on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce. The relevant section, 4.7.2 Employment and Training, requires companies to “offer maximum job opportunities to the community, taking into consideration the practical situation of the project’, also to “organize, participate in, and/or develop occupational skills training programs to improve the capacities of community inhabitants on the basis of the needs of the community” and “increase job opportunities for vulnerable groups within the community by collaborating with local institutions or organizations and developing special training programs”.

• Three Gorges hired over 300 local workers (Source: Company interview by a Chinese researcher from Thailand, January 2015). According to Three Gorges, they worked closely with the goverment on how to enhance local hiring, as well as provided job opportunities to the Penan Communities, however, local hiring has been very difficult due to the nature and environment of the work (Source: Three Gorges’ comments on the draft, May 25, 2015).
• There are also workers from Indonesia, Bengal, Pakistan and Philippines (Source: Field trip, January 2015).
• The Director of the Belaga District office (local government official), suggested the workload is too hard for local people. Malay Chinese only worked for half year and the Penan (impacted indigenous people) worked only one month or less (Source: Field trip, January 2015).
• According to Three Gorges, the company provides each worker with safety training and CIDB induction traning (Three Gorges’ comments on the draft, May 25, 2015). However Indonesian workers reported that they only received some safety training, and they had not been registered with the CIDB and were not provided with CIDB safety training (Sources: Site visit, January 2015).
• Local workers have been working as drivers and secretaries (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• Three Gorgess is responsible for training the SEB engineers to operate the hydropower plant (Source: Company interview by a Chinese researcher from Thailand, January 2015).

• Three Gorges has developed and adopted compliance policies and procedures on bribery risk management. The policies require to carry out appropriate due diligence including effective controls of cash accounts, and financial and operational processes moniorting, etc. The company also provides anti-corruption tranings to all the employees (Source: Three Gorges’ comments on the draft, May 25, 2015).

• Three Gorges has developed and adopted bribery control policies and procedures. No internal and external reports have been found on the improper involvement in the local political processes (Three Gorges’ comments on the draft, May 25, 2015).
• Three Gorges provides anti-corruption training to all employees at different levels (Three Gorges’ comments on the draft, May 25, 2015).

• In the 2013 CSR Report, Three Gorges identified that legal compliance was rated as ‘Medium-Low’ in terms of strategic importance. The ranking was based on a matrix developed by the company to identify the strategic importance of different corporate social responsibilities (Source: 2013 CSR Report).
• In the 2013 CSR Report, Three Gorges committed to strictly comply with local laws and international regulations in overseas business. The commitment is unclear on what the international regulations are.
• Three Gorges has also committed to following the Guide on Social Responsibility for Chinese International Contractors, prepared by China International Contractors Association under the direction of the Ministry of Commerce (Source: 2013 CSR Report).

• The EMP prepared by Three Gorges includes an analysis of legislative requirements (Source: Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• According to Three Gorges, different local government departments all explained the local laws clearly to Three Gorges. The relevant local government departments include CIDB, police department, department of labor, department of safety and health, and the Sarawak provincial government (Source: Company interview by a Chinese researcher from Thailand, January 2015). Three Gorges has engaged a loal legal firm to act on behalf of the company if any legal uncompliance occurs during the construction period (Source: Three Gorges’ comments on the draft, May 25, 2015).
• Reported by Three Gorges, there were four cases filed by the local workers because they were unhappy with the termination of their contracts. The company terminated their contracts because the workers failed to comply with company policies and ignored warning letters. The workers admitted their mistakes after being questioned by the Labor Department and agreed to settle the cases outside of court. Three Gorges provided them with additional compensations (Source: Three Gorges’ comments on the draft, May 25, 2015).

• No information collected.

• Not relevant to EPC Project Assessment.

• In the 2013 CSR Report, Three Gorges developed a matrix to identify the strategic importance of different corporate social responsibilities, in which, safety is rated as of ‘‘High’’ strategic importance for the company.
• The 2013 CSR Report demonstrated that Three Gorges has established a safety responsibility system and an emergency response system, and developed an emergency response plan (Source: 2013 CSR Report).
• The 2012 CSR Report showed that Three Gorges has developed 221 emergency response plans (Source: 2012 CSR Report).

• The EMP includes a short section of Emergency Response Plan, and an Environmental Contingency Plan (Source: Environmental Management Plan, Proposed Murum Hydroelectric Project, Belaga District, Kapit Division, Sarawak, Final Report, Date: March 2009. Ref: CK/EV110-131/08).
• There is a 20-person safety management committee that includes people from different partners in the joint venture (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• According to Three Gorges, they have developed emergency reponse plans for fire fighting and flood control, etc., and carries out an emergency response drill every two to three months (Source: Company interview by a Chinese researcher from Thailand, January 2015; Three Gorges’ comments on the draft, May 25, 2015).
• Pre-work meetings are required every day before every team starts work, so that the workers fully understand the work and associated safety risks (Source: Company interview by a Chinese researcher from Thailand, January 2015).
• Indonesian workers interviewed reported that they were not provided with CIDB safety training (Source: Field trip, January 2015).

• No information collected.

• Three Gorges set up alarm system and management system to monitor and inform all the relevant stakeholders about the impounding information (Source: Three Gorges’ comments on the draft, May 25, 2015).