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BGC

Disaster Relief and Donation Plan


Project All
Originating Company Basrah Gas Company (BGC)
Document Title Disaster Relief & Donation Plan
Document Number Consult Doc Control (DCC)
Document Revision R01
Document Status Second draft
Originator / Author Ahmed Al-Sawaei/Gilbert Merhej
Security Classification Restricted
ECCN ??
Issue Date June 2017
Revision History is shown next
page

Revision History
Date
Status
Rev # of Originator Checker Approver
Description
Issue

IFR – Issued Ahmed Al-Sawaei/ Diego


R01 Gilbert Merhej
for Review Gilbert Merhej Perez

The copyright of this document is vested in BGC. All rights reserved. Neither the whole nor any part of this document may be
reproduced, stored in any retrieval system or transmitted in any form or by any means (electronic, mechanical, reprographic, recording
or otherwise) without the prior written consent of the copyright owner. The contents of this controlled document shall not be altered
without formal approval of the document Custodian.
Disaster Relief & Donation Plan
Revision: R01
BGC, South Iraq

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Disaster Relief & Donation Plan
Revision: R01
BGC, South Iraq

Revision History

Date Issue Notes Author Reviewers Approval

05/06/2017 1

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Disaster Relief & Donation Plan
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BGC, South Iraq

TABLE OF CONTENTS

1.0 Introduction:
1.1 Company Profile
1.2 Social Performance at BGC
1.3 Purpose of the Document

2.0. Potential Disasters and Emergency Response System in Iraq

3.0. Assumption on BGC’s Potential Role in Disaster Relief

4.0. Assessment and Decision Making


4.1. Criteria
4.2. General Principles
4.3. Responsible Parties
4.4. Assessing need for specific disaster templates

5.0. Implementation of Disaster Relief Donation


5.1. Activation of the Disaster Relief Plan
5.2. Money and In-Kind Donations (transfer of money or goods to a third party)
5.3. Staff Fundraising and Matching Funds
5.4. Staff Volunteering

6.0. Reporting and Communication


7.0. After Action Review

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Disaster Relief & Donation Plan
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1.0. Introduction:

1.1. Company Profile

The Basrah Gas Company (BGC) was established in May 2013 as a joint venture between the
South Gas Company (SGC) owning 51%, Royal Dutch Shell (RDS) owning 44%, and Mitsubishi
Corporation (MC) owning (5%).
The purpose of venture is to develop the gas infrastructure in the Basrah province to gather
and commercialize associated gas produced and flared by the Licensing Round 1 fields in the
Basrah region. Under the terms of the Agreement BGC will purchase and off-take gas not
utilized under LR1 contracts by the upstream operators, and commercialize it into valuable
products (dry gas, LPG and condensates). The Company will be selling dry gas to South Gas
Company (Ministry of Oil affiliate) to meet domestic demand for power generation, while
directly exporting excess LPG and other products that are surplus to domestic needs.

1.2. Social Performance at BGC


Social Performance (SP) refers to how BGC manages the social impacts of its activities on the
communities and societies where it operates. The Company has adopted the Shell Group HSSE
and SP Control Framework, and relevant National and International governing standards. BGC
proactively identifies and manages social impacts by building stakeholder relationships,
addressing key issues, and ensuring the wellbeing of BGC’s neighbours and ultimately BGC
business and license to operate. There has been increased expectation on the role of the private
sector especially oil and gas companies working in post-war Iraq to contribute to emergency
response and relief efforts especially by key stakeholders and partners in the area.

The challenges for BGC are:


• To respond in a timely, proportional and balanced manner so that it is regarded as
appropriate to aid recipients, staff and other stakeholders.
• Not responding appropriate could have a highly negative impact on reputation.

1.3. Purpose of the Document


The Disaster Relief Donation Plan is intended to manage disaster relief donations consistently
and swiftly. It provides a brief description of potential disasters that may occur in Iraq (regions
mentioned or at National level), in line with the national emergency response system who
provides guidelines on how disaster relief donations should be managed.

2.0. Potential Disasters and Emergency Response System in Iraq


Typical sources of disaster in Iraq include the following;

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Disaster Relief & Donation Plan
Revision: R01
BGC, South Iraq

• Heavy rains and resultant flooding, which may impact residential and agricultural areas and
cause displacement of civilians.
• River flooding at rainy seasons or increase in river water level and increased pressure on
local dams.
• Explosive remnants of war such as ordnance or land mines.
• Impacts of conflict (armed conflict, terrorism) triggering an influx of internally displaced
Iraqis causing pressure on food and local supply systems.
• Heath service provision in extremely poor areas, or those caused by deficiencies in the
country’s medical supply chain (nutritional services, vaccinations)

The impacts of these disasters will continue to be likely due to the country’s poor infrastructure
and lack of country disaster preparedness and emergency plans.

3.0. Assumption on BGC’s Potential Role in Disaster Relief


The following assumptions are deemed in place for the country to manage potential disasters:
• There are several Iraqi institutions coordinating disaster relief as the Red Crescent, WHO,
local disaster response committees, and national coordination with international aid
agencies. However, there is no solid and functional national emergency response system in
place.
• Taken into consideration the local scale of BGC project/s in the country, it is unlikely that
BGC will have a leading or major role in disaster relief activities in case of a national level
disaster.
• At the same time, the role of BGC at regional level in disaster relief activities might be
significant; especially within Basrah and the areas adjacent to our operations. As initial
response is typically required immediately, in some situations the resources owned by the
neighboring BGC assets might significantly increase the resources available and serving the
needs of the affected area.
• Even in the cases when the resources of BGC projects are close to the event, response
should be expected through governmental bodies. As such, BGC should not lead the disaster
response.
• BGC is likely to be considered by the government as a resource provider (legally obliged to
provide the requested resources) rather than an independent player.
• Special attention should be paid to differentiation between the legal obligations of BGC
projects located in the affected areas (such as emergency response, provision of transport,
etc) and voluntary disaster relief activities.
• In Iraq, the disaster relief donations can be collected by people and organizations and due
to the lack of coordination, should gathered and channelled through BGC itself.
• Attention and proactive communication -and when appropriate- are necessary to
communicate what BGC is doing for disaster relief.

There could be 3 types of BGC contributions for the disaster relief:

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a) Mandatory provision of resources or services in accordance with the Iraqi law

Hence such contributions to the emergency response are the legal requirements they are
outside of scope of the Country Disaster Relief Donation Plan.
b) Urgent requests for resources or services from authorities and other responsible parties
such as Crisis Management Centres and / or local authorities might ask Assets for in-kind
assistance (e.g. firefighting, vehicles, places in camps, blankets, tents, etc.) in emergency
situations. Although the Iraqi legislation don’t see such assistance as an obligation

c) Voluntary donations: Voluntary donations are the focus of the Disaster Relief Donation Plan.

4.0. Assessment and Decision Making

4.1. Criteria
Decisions whether to (and what) donate (i.e. a type of Social Investment involving a simple transfer
of money or goods to a third party) should be based on the following criteria:
• Loss of life, injuries and damage to infrastructure;
• Ability of local or national government to cope with the disaster;
• Requests from country or aid organizations for assistance to sources outside the disaster
area;
• Type and extent of BGC operations in the area in which the disaster has occurred (measured
by investment and number of staff employed);
• Impact of the disaster on local stakeholders, and on BGC operations, staff and contractors;
• BGC’s business aspirations in the impacted area;
• Requests from BGC staff for the Company to provide assistance;
• Benchmarks against previous disaster relief donations; and
• Amounts donated by other companies (i.e. competitors).

4.2. General Principles


The principles for the disaster relief donations are in line with those for Social Investment:
• All donations should be reviewed against the Company’s Business Principles to which they
must conform.
• All donations must be lawful and conducted in a way that will withstand vigorous scrutiny,
to avoid all suggestions of improper business practice or unfair advantage.
• Donations shall not create dependency.
• Organisations selected to deliver the donation shall be subject to ABC compliance and
appropriate Due Diligence.

4.3. Responsible Parties


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In case of voluntary donations, the decisions are made by the Managing Director (or Deputy MD),
and the Corporate Affairs Director (together with SP and ER Managers).
Ensuring all relevant approval procedures are complied with.
In case of urgent requests for resources or services from authorities and other responsible parties.
the decisions are made by L1 level Directors under condition that they do not exceed their levels of
authority and seek final authorisation from the Corporate Affairs Director and the Managing
Director.
4.4. Assessing need for specific disaster “templates”
Although decisions are made on ad hoc basis using the criteria, it would be reasonable to assess the
need for specific Disaster Relief Donation templates to cover specific disasters either at the country
or at the regional level.
The following conditions might indicate that disaster relief donation templates covering specific
disasters are desirable:
• One or some disasters are ‘common’ (have tendency to be repeated) to and lead to
significant negative impact including massive material damage and / or fatalities in the
territory where BGC operates.
• BGC’s resources are regularly involved in addressing disasters of a certain nature (e.g.
flooding) either at the request of the local authorities and / or communities or on voluntary
basis.
• BGC’s experience and expertise might be of special help in addressing the consequences of
the specific disasters in the area. E.g. the disaster relief activities are in line with the SI
themes of BGC.

Preparation of specific plans will help


• Increase efficiency of the disaster response.
• Streamline communication strategies and messages.
• Increase efficiency of SI programs making them more focused.

Specific plans should describe different disaster scenarios identify possible mechanisms,
organizations / partners (e.g. government and aid agencies “local NGOs”) with field expertise,
processes and communication internal / external strategies, etc.
Special attention should be paid that the activities outlined in such plans do not create dependency
and do not result in the perception that BGC is responsible for addressing the disaster in the area.

5.0. Implementation of Disaster Relief Donation


5.1 Activation of the Disaster Relief Plan

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1. Managing Director should initiate and handle donations -in consultation with the Corporate
Affairs Director- and other support.
2. There is no separate (Social Investment) budget for Disaster Relief.

5.2. Money and In-Kind Donations (transfer of money or goods to a third party)
• The relevant teams working on the emergency response are directly involved or SP and ER
Managers with relevant teams ‘on the ground’ should identify needs (e.g. with the help of
requests from communities; country, international leadership, aid organizations, etc.)
• It is advisable that the donation does not exceed USD 100,000 although the amount in real-
life situations might vary (e.g. depending on extent of loss of life, injuries and damage to
infrastructure; impact of the disaster on local stakeholders; etc.). The final decision rests
with the Managing Director.
• In case of transfer of money: as there are no special disaster relief donations budget and in
cases when external stakeholders (e.g. local communities) are involved in the social
investment decision-making process, it is necessary to ensure that external stakeholders
are duly consulted about the decisions concerning the disaster relief donation.

Whenever applicable, The SP and ER Managers together with focal points responsible for
engaging with relevant stakeholders should ensure these consultations have taken place.
• Disaster relief donations should be channelled through formal aid organisations, where they
exist, or through government, as appropriate – failing this, BGC may consider making
donations directly themselves. In doing so, the Company should make best efforts to verify
that selected aid organisations can swiftly and effectively distribute disaster relief
donations made by BGC. It should also inform the aid organization that the donations are to
be used to supplement relief efforts for the disaster in question.
• Depending on the situation working through one or several aid organizations might be a
preferred option (e.g. depending on the impact of the disaster, on what resources,
competences or skills are necessary, etc.) unless BGC may consider making donations
directly themselves.
• If developed, specific disaster relief donation templates should investigate organizations
that could assist in certain situations.
• It is essential that any decision on support should be made in a timely manner. Wherever
possible, the MD, Corporate Affairs Director and SP/ER Managers should meet within 12
hours of announcement.
• The SP and ER Managers together with relevant teams should monitor the peer companies’
present and past activities on disaster relief in the region (if any): what they do, how much
they donate and how quickly their processes are to propose amendments to the BGC’s
actions if necessary.
• The ER Manager writes and implements a plan for communicating the Company’s response
to the disaster, what donations are made and how these donations are spent.

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Disaster Relief & Donation Plan
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Note 1: Special Procedures


Regardless of the monetary amount or in-kind value of the contribution, the special
procedures outlined in the ABC Manual must be followed if:
• The proposed Charitable Contribution has been solicited by a Government Official; or
• A Government Official is a director, manager or trustee of the recipient organization AND it
is reasonably expected that BGC may have business that could be influenced by that
Government Official or the Government Official’s agency;
• Any other situation where a reasonable person may conclude that BGC could receive an
improper advantage because of the proposed Charitable Contribution.
• In addition to the procedures set forth above, the proposed recipient of any Charitable
Contribution shall complete the certificate attached in Appendix C and any Red Flags raised
by the certificate must be resolved before funds are released. The completed certificate
should be then retained together with the documentation listed above in a central
repository for ten years.

5.3. Staff Fundraising and Matching Funds (establishing a means for staff and contractors to
make donations (financial and/or in-kind) through BGC and matching these funds)
• Staff fundraising is usually initiated and organized by local staff, with support from External
Relations or Social Investment focal point.
• The Managing Director decides on matching staff and contractor donations.
• Wherever necessary (e.g. if asked by staff or contractors) the MD decides on establishing a
channel for staff and contractors to make donations (financial and/or in-kind) to help
employees raise funds.
• The MD appoints an Action Team (e.g. relevant Communications practitioner, HR
practitioner) who meet with staff members to discuss required support.
• The ER Manager writes and implements a plan for communicating to staff and contractors
on how to make donations through BGC.

This communication might include (but not necessarily limited to):


• Web messages posted on country site to be posted by country ER focal point; web messages
should be updated regularly.
• Messages on Company Websites to be posted by ER;
• Short Q&A’s should be available to answer questions about donations or operations.
• Information and advice on how to donate should be readily available for staff and
contractors; focal points should be given Q&A’s to answer all relevant questions. Staff and
contractors should check with Media Office on what information and how much of it could
be shared with the external audience.
• Disaster relief donations should be channelled through formal aid organizations, where
they exist, or through government, as appropriate. In doing so, the Company should make
best efforts to verify that selected aid organizations can swiftly and effectively distribute

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Disaster Relief & Donation Plan
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disaster relief donations made by BGC. It should also inform the aid organization that the
donations are to be used to supplement relief efforts for the disaster in question (see point
above about ABC manual).
• It is essential that any decision on support should be made quickly.
• Wherever appropriate the staff and contractor representatives should be early consulted on
what organizations the donations will be channelled through to avoid misunderstanding.
• Relevant for matching funds: as there is no special disaster relief donations budget and in
cases when external stakeholders (e.g. local communities) are involved in the decision
making about social investments it is necessary to ensure that external stakeholders are
duly consulted about the decision on the disaster relief donation. This includes potential
donations or match-making by the South Gas Company Employee Donation Committee.
• The ER and SP Managers together with focal points are responsible for engaging with
relevant stakeholders should ensure these consultations have taken place (if applicable).
• It is advisable that the amount of money for matching funds does not exceed USD 100,000
although the final decision rests with the MD.

5.4. Staff Volunteering


• Relevant teams who are directly linked to the actual emergency response (e.g. cases where
BGC is directly involved in the Emergency Response) or the SP and ER Managers with
relevant teams ‘on the ground’ should identify needs.
• The MD decides on approval of staff volunteering sponsored by BGC.
• Before approval, health and safety risks for the volunteers should be carefully assessed by
competent practitioners from HSE and other relevant teams.
• Before approval the potential impact of the staff absence on asset activities should be
assessed by relevant competent practitioners. Although in some situations the absence is
possible in other situations risks may be unacceptable (e.g. increasing risks of disruption of
the potentially dangerous technological processes).
• The MD appoints actions parties responsible for ensuring normal and safe living and
working conditions for the volunteers in accordance with all applicable standards.
• ER Manager writes and implements a plan for communicating to staff and contractors
volunteering options and conditions.

This communication might include (but not necessarily limited to):


• Web messages posted on country site to be posted by ER focal point; web messages should
be updated regularly.
• Messages on Company website to be posted by ER;
• Short Q&A’s should be available to answer questions.
• Information and advice on how to become a volunteer should be readily available for staff
and contractors; focal points should be given Q&A’s to answer all relevant questions.

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6.0. Reporting and Communication


• All donations should be conducted in a way that will withstand vigorous scrutiny; records
should be duly kept.
• Uncertainty and suspicion in misuse of money or lack of efficiency are common for Disaster
Relief Donations all over the world. It is advisable that all expense reports or key
information from them is made publicly available to ensure transparency and avoid all
suggestions of improper business practice or unfair advantage.
• The special reporting procedures outlined in the ABC Manual should be duly obliged
wherever applicable.
• Special measures in communication (e.g. special web page on web) might be considered if
necessary.

7.0. After Action Review


The Corporate Affairs Director , on behalf of the Managing Director will initiate a Post Action
Review within a week of the conclusion of disaster response procedures, in order to measure actual
spend and assess effectiveness of impacts relevant to both immediate and long-term rehabilitation.
One of the main objectives is the delivery of documented key learnings and recommendations for
improvements of this plan.

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