Several independent reviews have been conducted by third parties in order to ensure that the projects are carried out in compliance with the best social and environmental practices and with the requirements of the duty of care. Alongside the ongoing dialogue with the local communities, these reviews also allow the action taken to be assessed for effectiveness and potential improvements to be identified.
- Environmental and Social Impact Assessments (ESIA)
- Reports commissioned by TotalEnergies and status of recommendations
- Reports by NGOs
- Other reports
- TotalEnergies' public responses to allegations made against the Tilenga and EACOP projects
Environmental and social impact assessments (ESIA)
To conduct these projects, TotalEnergies and its partners carried out detailed assessments (ESIA, Environmental and Social Impact Assessment) of the potential social impacts (particularly access to land and water) and environmental impacts of Tilenga and EACOP. They led to the implementation of the measures needed to prevent or minimize these impacts.
Tilenga ESIA
EACOP ESIA
Uganda
Reports commissioned by TotalEnergies and status of recommendations
Tilenga – Human Rights Impact Assessment Report
Date: June 2022
Author & reference organization: Eco& Partner Consult Limited with assistance by LKL International Consulting Inc.
For this report prepared on behalf of TotalEnergies EP Uganda, the consultants carried out extensive field work during the period April to November 2021.
Scope of the study: The purpose of the Human Rights Impact Assessment is to understand the risks and impacts of the Project on human rights and to develop a proactive and comprehensive Human Rights Action Plan framework for ongoing Human Rights Due Diligence to manage the Project’s salient human rights issues as it moves through the construction and operational phases. This Assessment builds upon prior human rights studies that the Project has undertaken, notably through the Environmental and Social Impact Assessment (ESIA) and other related studies.
Non-public sources used by the consultant remain outside the public domain.
Third Party Report on Human Rights Defenders
Date: July 2021
Author & reference organization: Michel Forst, Consultant (Article Premier)
Michel Forst is an independent consultant, specialized in Human Rights. He was previously Special Rapporteur on the situation of Human Rights Defenders for the Office of the United Nations High Commissioner for Human Rights (OHCHR).
For this report, the author travelled to Uganda in April 2021.
Scope of the study. In recent years TotalEnergies EP Uganda (TEPU) has faced allegations of links to intimidation of Human Rights Defenders which it has systematically investigated. TEPU has not found any evidence which suggests that such allegations are substantiated but wishes to establish a more formal framework for the management and investigation of alerts and allegations of this nature connected to its activities. TEPU is aware there is an expectation by civil society that the company will exercise its leverage when made aware of allegations related to Human Rights Defenders in proximity to its activities and wishes to consider how best to exercise such leverage.
In this context, TEPU commissioned Michel Forst to provide an independent report summarizing observations collected in the field, including recommendations regarding TEPU public statements on Uganda’s Human Rights Defenders, recommendations on management of grievances related to Human Rights Defenders, and applicable internal procedures.
Non-public sources used by the consultant remain outside the public domain.
Third Party Review of RAP1 Performance and Compliance
Date: June 2019
Author & reference organization: F. Giovanetti Consultant
Frederic Giovannetti is an independent consultant, specialized in resettlement planning and implementation, as well as social and environmental impact assessments. He has worked with several major international organizations in the Oil & Gas mining sectors, with a strong focus on the Russian-speaking world and Africa.
For this performance and compliance report, the author travelled to Uganda in the first half of May 2019.
Scope of the study: As part of the implementation of the Tilenga project, TotalEnergies EP Uganda (TEPU) and its partners submitted in 2017 a Resettlement Action Plan (RAP) to specify the conditions for relocating the affected households concerned by the project. In 2018, the Ugandan authorities did approve the plan, divided in 5 zones. Since then, TEPU has been working on the implementation of Zone 1 of the RAP (RAP 1) which covers land acquisition of priority areas of the industrial area for the Tilenga Project located in the vicinity of Kasenyi Village, Ngwedo Sub Country, Buliisa District, Uganda.
In this context, TEPU commissioned F. Giovanetti to provide an independent review of the implementation of RAP1 to provide concise and relevant information about whether compensation, resettlement and development initiatives were on track, or whether corrective actions would be required.
Non-public sources used by the consultant remain outside the public domain.
Tilenga Project – Resettlement Action Plan 1 (RAP1) – Review of the current livelihood restoration plan
Date: May 2020
Author & reference organization: Ted Pollet (Cousins Environmental Consultants)
Ted Pollet is an International Social Development Specialist working closely with Cousins Environmental Consultants Ltd. (CECL), located in Wales. This organization provides a range of environmental and social risk management services to the extractive, infrastructure and manufacturing industries worldwide by ensuring that the exposure to environmental and social risks are understood and managed both at the corporate level and at all stages of project development, implementation and closure. CECL works with a global network of specialists and associates, and particularly in Africa: Uganda, Kenya, Ghana and Sierra Leone.
Scope of the study: Since 2018, TotalEnergies EP Uganda has been working with its partners in the planning and implementation of RAP1 (Resettlement Action Plan 1), and has commissioned an independent expert, F. Giovanetti, to assess whether compensation, resettlement and livelihood restoration measures were being adequately implemented or whether corrective actions were required. While F. Giovannetti found that the general implementation of the project (including the socio-economic survey, land acquisition, compensation process, and grievance management system) was generally in line with international performance standards and good practices, he also provided several recommendations, for example on livelihood restoration strategy.
Within this framework, and in accordance with this recommendation, in February 2020 TotalEnergies EP Uganda commissioned Cousins Environmental Consultants (CECL):
- To review the current livelihood restoration plan as described in the Resettlement Action Plan 1 (RAP 1) and the third-party performance and compliance review undertaken by F. Giovannetti (18 June 2019).
- To recommend any relevant changes, based on the review of relevant reports and the field visit, to ensure that all aspects of the livelihood restoration program are fit for purpose and meet the needs of affected households and the requirements of Ugandan and international performance standards.
- To design a follow-up plan in order to support the execution of the livelihood restoration plan and any proposed corrective actions.
Non-public sources used by the consultant remain outside the public domain.
Review of Tilenga IFC compliance in Project Implementation Planning
Date: September 2019
Author & reference organization: Gill Cousins, Amy Sexton, Susan Wood (Cousins Environmental Consultants)
Gill Cousins owns Cousins Environmental Consultants Ltd. (CECL), a Welsh company providing a range of environmental and social risk management services to the extractive, infrastructure and manufacturing industries worldwide. It ensures that exposure to environmental and social risks is understood and managed both at the corporate level and at all stages of project development, implementation and closure. CECL works with a global network of specialists and associates such as Amy Sexton and Susan Wood, and particularly in Africa: Uganda, Kenya, Ghana and Sierra Leone.
For this review, the CECL team analyzed documentation, held phone meetings with Tilenga team members, and completed an in-country visit in March 2019.
Scope of the study: TotalEnergies EP Uganda has placed particular emphasis on environmental and societal issues. The approach within the Tilenga project framework is based on International Finance Corporation Standards (IFC). After the ESIA’s submission to regulators for approvals, the Tilenga project teams needed to look ahead to the implementation and ensure that all environmental and social processes were in place to meet international standards.
Within this framework, TotalEnergies EP Uganda has engaged Cousins Environmental Consultants Limited (CECL) to evaluate the position of the Tilenga Project with respect to development of plans, programs and related activities and resourcing that, moving forward, enable the Project to be IFC-compliant. This independent review provides specific information on whether the project is compliant with Environmental, Health and Safety Guidelines (EHS), and IFC’s eight performance standards (PSs):
- PS1: Environmental and Social Impact, PS2: Labour and working conditions, PS3: Resource efficiency and pollution prevention, PS5: Land acquisition and involuntary resettlement, PS6: Biodiversity conservation and sustainable management of natural resources, PS7: Indigenous people, PS8: Cultural Heritage.
Non-public sources used by the consultant remain outside the public domain.
TotalEnergies EP Uganda – Investigation Vigilance
Date: December 2019
Author & reference organization: Emmanuel Pitron, Alexandra Haziza, Arthur Leprince (ADIT)
Emmanuel Pitron, Alexandra Haziza and Arthur Leprince are consultants working for ADIT, a European leader in strategic intelligence founded in 1993 in Paris. Its main mission is to reduce the level of risk in international projects and the uncertainty inherent in any business growth strategy. ADIT develops its activity around 5 areas of expertise: strategic intelligence, business ethics and compliance, business security, business diplomacy and territorial intelligence, and operational deployment.
Scope of the study: On 23 October 2019, two NGOs (Les Amis de la Terre and Survie) initiated summary proceedings against Total S.A. (which has since become TotalEnergies SE) on grounds relating to the compliance of the Vigilance Plan, the vigilance measures established by the Company in the management and implementation of the Resettlement Plan for Exposed Persons (Tilenga), and the practical implementation of the commitments made by TotalEnergies EP Uganda and its partners in the agreement with the Ugandan government setting the framework for land acquisition and resettlement of people affected by the Tilenga and EACOP (Land Acquisition & Resettlement Framework) projects.
As part of this process, TotalEnergies commissioned ADIT to assess the relevance of the measures implemented by the Tilenga and EACOP projects by its subsidiary TotalEnergies EP Uganda, in the light of the Company's Compliance Plan, applicable standards and in accordance with the principles set out in the Land Acquisition and Resettlement Framework (LARF), as well as the best practices identified. The mission was also to monitor the proper implementation of these measures and, if necessary, to identify any persistent risks.
Non-public sources used by the consultant remain outside the public domain.
Reports by NGOs
In September 2020, the International Federation for Human Rights (FIDH) with its local partner FHRI, and Oxfam International with its partners Global Rights Alert (GRA), Civic Response on Environment and Development (CRED) and Northern Coalition for Extractives and Environment (NCEE), published two Human Rights Impact Assessments related to the communities affected by the oil projects around Lake Albert, including the Tilenga project, on the one hand, and the EACOP project, on the other hand.
TotalEnergies, TotalEnergies EP Uganda and EACOP teams appreciated the constructive discussions to which these reports have given rise and the value of their complementary approach to that of the Company, notwithstanding not sharing all the findings.
The Company welcomes most of the recommendations pushed forward by FIDH and Oxfam in these reports and will progressively enhance its action plan to fit them in.
The following documents summarize the analysis of these recommendations by TotalEnergies teams and the action plans planned or conceivable at this stage by the Company.
- Read TotalEnergies’s analysis and status of the recommendations from FIDH
- Read TotalEnergies’s analysis and status of the recommendations from Oxfam
- See the FIDH report, online on the NGO's website
- See the Oxfam International report, online on the NGO's website
Other reports
Since 2013, IBLAC (Independent Biodiversity and Livelihoods Advisory Committee) supports all stakeholders (TotalEnergies Exploration Production Uganda BV, Chinese National Offshore Oil Company Uganda Limited and East African Crude Oil Pipeline) in the Tilenga-EACOP project.
IBLAC is mandated to advise stakeholders on how best to conserve and preserve biodiversity and related livelihood aspects of local communities in their areas of operation and in the area of influence before, during and after projects.
The Committee is composed of international experts from a range of worldwide organizations. These experts participate in meetings, site visits, and discussions on management of the biodiversity and livelihoods.
In 2022, IBLAC published its annual report presenting the observations and recommendations made by the experts following their annual visit to Uganda and Tanzania. The visit focused on the activities of the teams responsible for biodiversity, social and land issues at the Tilenga, Kingfisher and EACOP projects in Uganda, and the EACOP project in Tanzania.
The Company welcomes most of the recommendations pushed in these reports and will progressively enhance its action plan to fit them in.
TotalEnergies' public responses to allegations made against the Tilenga and EACOP projects
For transparency and completeness issues, TotalEnergies publishes its responses to the allegations made against the Tilenga and EACOP projects.
