As a responsible mining company, Eramet Grande Côte operates according to the highest international standards. We have translated these standards into commitments regarding Human Rights, ethics, health and safety, financial transparency, the environment, and regional economic development.

Our commitment, Act For Positive Mining, aimed at generating a positive impact for our stakeholders (10 concrete objectives), is based on the continuous improvement of our dialogue and practices. The participatory process established with our stakeholders also allows us, collectively, to minimize our negative impacts.

In this context, we have voluntarily agreed, with full transparency, to be scrutinized by our stakeholders through an IRMA audit (Initiative for Responsible Mining Assurance), the most demanding standard in the extractive industry.

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Social – Environment – Economy

Societal

Prior to the launch of its activities, the company conducted an environmental and social impact study that included an archaeological component across the entire project area.

This study enables the company to avoid causing negative impacts and to support the preservation of the cultural heritage of the regions traversed. The archaeological surveys revealed a total of 73 sites and 23 isolated finds. The collected material includes stone tools, pottery, slag, beads, tobacco pipes, glass bottle fragments, and imported ceramics, among others.

A chance discovery procedure has been implemented in case other sites or isolated finds are uncovered during the mine’s operation, so they can be preserved.

This plan and procedure are carried out and communicated with the heritage authorities of Senegal.

The Community Consultation and Information Plan presented in March 2021 summarizes the 22 community meetings organized in 11 sites located around Diogo during the update of Eramet Grande Côte’s strategic documents. It essentially reflects the perspective of the populations or their perception regarding the actions undertaken or to be considered by Grande Côte.

This document describes all the company’s activities, both mining and industrial, while also taking into account the environment and relationships with communities, particularly those impacted.

The overall objective of the public consultation and disclosure program of the Community Consultation and Information Plan is to achieve effective, inclusive, and equitable participation of the Project’s stakeholders, ensure the long-term viability of Grande Côte, and enhance potential positive impacts.

Communication between the company and the affected communities, as well as other Project stakeholders, is at the heart of this plan. This includes regular updates on the progress of Eramet Grande Côte’s activities, safety, employment opportunities, etc.

In parallel, the company is implementing a robust mechanism for recording and resolving complaints and grievances related to the Project.

As part of the mining concession granted by the Senegalese State to Eramet Grande Côte, socio-economic surveys were conducted in 2020 across 87 villages and hamlets that might be physically and/or economically displaced. The surveys were carried out with specific community groups: youth, women, leaders of community associations, local authorities, etc., to ensure everyone had the opportunity to express themselves. These qualitative discussion groups allowed for exchanges and sharing of detailed information about their activities and livelihoods. These consultations helped gather the community’s perception of the project involving the crossing of Lompoul by the mine, their expectations, and thus take them into account to minimize negative impacts.

This was followed by the delivery of a study conducted by an international firm on a resettlement and livelihood restoration plan for the operational phase of the Eramet Grande Côte mine from 2021 to 2028, divided into three stages: pre-Lompoul phase (2021-2022), Lompoul Sur Mer phase (2023), and post-Lompoul Sur Mer phase (2024 to 2028).

Potentially affected individuals and economic entities, including tourism activities in Lompoul, were identified within the framework of the Resettlement Commission chaired by the regional prefect and representatives of affected persons, to ensure compensation.

The resettlement and livelihood restoration plan for people affected by the Eramet Grande Côte project is based on studies conducted in 2007 and 2011 in the Thiès region.

A Resettlement Commission, chaired by the regional prefect and representatives of the affected people, was established prior to the project to manage resettlement and compensation. Communities were closely involved in the process of defining the resettlement modalities (site selection, configuration of the new village, its housing, and shared infrastructure, etc.). All resettlements were accompanied by the upgrading of housing and delivered infrastructure (running water, electricity, concrete structures, etc.). As a result, communities now have houses with at least three rooms, access to water, and solar lighting. Each locality also includes a school, a mosque, a water tower, and a waste management system for which communities are trained. In addition to financial compensation (based on the World Bank scale, five times higher than the national scale), replacement agricultural land was provided to residents. These lands are most often identified by the residents themselves before being financed by the company and even equipped (solar panels to replace fuel-powered pumps for drawing water from wells, saving 120,000 FCFA per week in fuel costs). A livestock route was developed around the villages. The company paid particular attention to restoring, at least to pre-resettlement levels, the livelihoods of the impacted people. Once the program is fully completed, the management of the resettlement villages is transferred to the public authority. Between 2017 and 2019, nearly 920 people from two villages were resettled.

As part of its corporate responsibility, Eramet Grande Côte has developed a Social Development Plan (2021) aligned with Senegal’s health policies. Among the ongoing programs: contributions to the construction of health posts or health huts (Foth, Diogo sur mer, …). It also organizes, in collaboration with the authorities, community awareness campaigns on malaria, … or hygiene (water, sanitation, …). At the end of February 2025, the company organized a major medical consultation day in Lompoul sur mer with the presence of 6 general practitioners or specialists. Approximately 250 people attended consultations on this occasion.

Environment

Aware of the potential impacts of mining and metallurgical activities on the natural environment, Eramet considers it its responsibility to implement all necessary measures to preserve the environment and the health of populations.

The Group places Corporate Responsibility at the heart of its development strategy, in line with the United Nations Sustainable Development Goals (SDGs).

Eramet’s environmental policy aims for three outcomes:

  • The implementation of efficient environmental management systems across all its subsidiaries,
  • The integration of environmental considerations as early as possible in the design and development of industrial and mining projects,
  • The supply of metals necessary for the energy transition and the development of activities that contribute to the growth of a model that is more resource-efficient and circular.

In 2014, Eramet Grande Côte engaged an international consultancy to conduct an environmental audit of its activities, particularly focusing on the “Installations Classified for Environmental Protection,” such as the resettlement plan, the rehabilitation plan, and the hazard study. At the same time, the Environmental and Social Management Plan for Grande Côte, dating back to 2005, was updated.

The various stakeholders involved in monitoring the implementation of the Environmental and Social Management Plan were consulted to provide their feedback during interviews and group discussions.

The final study conducted made it possible to propose actions to ensure regulatory compliance, including verification of the implementation of the measures outlined in the Environmental and Social Management Plan during the operational phase and at the time of the company’s closure.

Mitigation, monitoring, and environmental follow-up actions were integrated, complemented by capacity-building initiatives for stakeholders in the impacted regions.

Eramet Grande Côte has committed, through its environmental policy, to progressively rehabilitate the dunes exploited for their mineral sands. To this end, a rehabilitation plan was developed and approved by the Ministry of the Environment in 2015. It is regularly updated.

Eramet Grande Côte has initiated its roadmap for the handover of mine parcels for the 2022-2026 horizon. Progressive rehabilitation offers the opportunity for a gradual transfer of rehabilitated sites instead of waiting for the mine’s closure. To date, more than 2,300 hectares have been rehabilitated, knowing that it takes approximately 7 to 8 years to complete the rehabilitation cycle after dredging the mineral sands.

In 2025, it is planned to hand over to the authorities parcels totaling nearly 950 hectares, exploited and rehabilitated between 2015 and 2018, following the 85 hectares handed over in 2022. These parcels have already undergone biophysical characterization with very encouraging results.

Eramet Grande Côte is the first mine to have handed over rehabilitated mining parcels in Senegal.

Eramet Grande Côte has committed to mastering and optimizing its water consumption for its operations in order to preserve a quality water resource accessible to all, especially in the context of climate change.

This significant issue for our internal and external stakeholders has led Grande Côte to commit to minimizing the impact of its activities on water resources and aquatic environments by working on several aspects:

  • Continuous improvement of water monitoring for our activities (withdrawals, recycling, usage, discharges) to achieve a reduced water footprint,
  • Optimization of process water consumption and increased recycling,
  • Internal and external awareness, training, and communication.

An impact study is a preliminary analysis conducted prior to the implementation of mining or industrial projects that may have significant effects on the environment. Its purpose is to identify, assess, and propose measures to mitigate the negative impacts of a project. The ESIA ensures that the project complies with environmental laws and regulations.

To achieve this, consulting potentially affected neighboring communities (particularly rights holders) is essential to allow them to express their expectations and enable authorities to make informed decisions.

Approximately thirty meetings were organized with all project stakeholders: administrative authorities (Governors, Prefects, Sub-Prefects), heads of national, regional, and departmental technical services, local elected officials (mayors and municipal councilors), and populations from villages and hamlets in the project area. In total, 313 people were consulted in the two regions affected by the project.

The Eramet Grande Côte production capacity expansion project focuses on increasing the quantity of heavy mineral sands processed on the one hand and increasing the capacity to concentrate mineralized sands at the plant on the other. The project aims to enhance the natural resource of mineralized sands located along the mine’s path, without exceeding the boundaries of the initial concession granted by the Senegalese State.

It consists of two components: recovering mineralized sands located on either side of the mobile mine using more conventional means such as trucks and excavators. The project also plans to increase the number of spirals at the floating concentration plant to handle the larger tonnage of sands to be processed.

Two major objectives were targeted in the 2022 Environmental and Social Impact Study (ESIA): to assess the consequences of the project’s implementation on the biophysical and human environment and to propose measures to avoid, mitigate, or compensate for impacts deemed negative, in accordance with Senegal’s ESIA procedure governed by the Environmental Code and related texts.

The Environmental and Social Management Plan (ESMP), derived from the environmental assessment, defines measures to mitigate negative impacts as well as the modalities for their implementation, monitoring, and oversight. The ESMP also determines institutional arrangements to be considered during the project’s implementation, including those related to communication and capacity building.

Eramet Grande Côte aims to reduce its energy and climate footprint by -26% through the implementation of a photovoltaic solar power plant.

The Environmental and Social Impact Assessment (ESIA) was conducted in consultation with all stakeholders involved in the project at the national, regional, departmental, and local levels.

A total of 227 people were consulted, 22% of whom were women. The various meetings held as part of the public consultations revealed that the project enjoys very strong social acceptance. Nevertheless, concerns were raised by the stakeholders consulted, and recommendations were made (impact management measures, support measures, local employment, etc.), which have been taken into account in this report and in the resulting action plans.

Governance
Economy

Eramet Grande Côte est la première société minière du Sénégal à avoir obtenu la certification de son système de gestion environnementale ISO 14001, en 2020. Cette certification a été renouvelée avec succès en 2024. Les meilleures pratiques en la matière sont intégrées dans la gestion de l’environnement par les équipes de Grande Côte.

Chaque grande question environnementale, telle que l’eau ou la gestion des déchets, est également gérée conjointement avec l’ensemble des intervenants du Plan d’Action de Réinstallation.

Eramet Grande Côte a également obtenu la certification internationale ISO 50001 en 2021 pour la première fois grâce à la mise en œuvre une politique de gestion de l’énergie répondant aux meilleurs standards internationaux.

Safety is a fundamental value of the Eramet group. The goal is ZERO workplace accidents.

In factories and mining sites, our activities require constant vigilance to prevent any accidents and avoid endangering the health of employees or external contractors. We are convinced that every accident can be avoided.

Everyone is responsible for their own safety, as well as the safety of their colleagues and those around them.

While recognizing that the elimination of all health risks is impossible, the goal of the Group’s Health policy is to manage them to minimize their frequency and the severity of their consequences.

The Eramet group is committed to gaining detailed and in-depth knowledge of all health risks related to its activities, while contributing to the development of knowledge and its dissemination.

Safety is the primary responsibility of every manager in our company.

Over the years, Eramet Grande Côte has established a relationship of trust and mutual respect with its teams, subcontractors, and clients. These relationships have been built on the values of the Eramet Group and its commitment to human rights and ethics.

Our Code of Ethics and Compliance reflects our commitment to preserving and strengthening business integrity in all our activities, enabling us to better address long-term global challenges wherever the Group operates.

At Eramet Grande Côte, an anti-corruption policy and specific procedures (conflicts of interest, gifts, invitations, etc.) are clearly defined and implemented.

On a daily basis, these obligations apply to all Eramet Grande Côte employees, including subcontractors.

Over the years, Eramet Grande Côte has established a relationship of trust and mutual respect with its internal and external stakeholders. These relationships have been built by adhering precisely to the company’s values.

On a daily basis, these obligations apply to all employees of Eramet Grande Côte and structure their relationships with all their partners.

Anyone who believes that a value or principle promoted by Eramet’s Ethics and Compliance Charter has been violated, or that there are practices contrary to ethics, is encouraged to report it:

The Eramet Group considers that the company must be a vector of respect and promotion in terms of protecting Human Rights.

This is why the Group is committed to respecting and promoting the fundamental principles of Human Rights, as defined notably by the International Bill of Human Rights and the fundamental conventions of the International Labour Organization, following the recommendations of the guiding principles on business and Human Rights.

Eramet’s Human Rights Policy formalizes this commitment and reaffirms its fundamental role in the Group’s managerial and operational approach and in its relationships with stakeholders.

It complements the other policies of the Group and applies to all employees, business partners, and local communities.

Each of our stakeholders, particularly the local communities affected by a project, must be able to express their expectations and file complaints. To this end, a grievance mechanism has been established by Eramet Grande Côte. Complaints can be submitted either orally to our field agents, by telephone (76 552 51 05 or 76 552 51 35 or 76 552 51 35), or by mail (mailboxes are available in the main villages).

The grievance handling mechanism evaluates all grievances: an investigation is then launched, followed by a dialogue to assess the next steps. Each complaint is closed at the end of the review process, which is conducted with full transparency.

Concerns and complaints may arise from real or perceived impacts of the company’s activities.