• Huaneng’s Sustainability reports were compiled in accordance with the Sustainability Reporting Guidelines from Global Reporting Initiative and ISO 26000: Guidance on Social Responsibility (Source: 2011-2013 Sustainability Report).
• In 2007, Huaneng endorsed the Global Compact. (Source: 2013 Sustainability Report).

• Huaneng’s Regulations on Environmental Protection Article 4 states that Huaneng shall ensure its full compliance with environmental laws and regulations, but it is not clear whether the regulations apply to overseas projects.

• Huaneng is one of two project developers. The other project developer is the Royal Group in Cambodia.
• Huaneng has not adopted Chinese standards and practices in hydropower development as a minimum (Source: Same Company, One River, Two Dams Report, February 2015).

• Huaneng has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• Huaneng Regulations on Environmental Protection Article 19: the company shall establish a management system and a monitoring network for environmental protection. However, it is not clear whether the Regulations apply to overseas projects.

• A basic EMP was included in the EIA, which outlined potential environmental impacts, proposed mitigation measures, identified responsible institutions and cost estimates. However, based on field research, not all measures outlined in the EMP have been implemented at the project site. The EMP was disclosed with the EIA report prepared in 2009 and since then no updated EIA or EMP has been publicly released (Source: Environmental Impact Assessment Report for Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia. 2009).

• Huaneng has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; and Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• Huaneng’s Regulations on Environmental Protection Article 10: Construction projects shall strictly comply with China’s Environmental Protection Regulations on the Administration of Construction Project as well as the EIA Law and regulations. Article 11: During the feasibility study phase, an MEP-certified EIA agency shall be commissioned to compile EIA documents. Sedimentation and erosion issues shall be submitted for approval in accordance with the Regulations. Construction projects shall not be commenced if the EIA documents have not been reviewed or approved by the environmental authorities. However, it is not clear whether the Regulations apply to overseas projects.

• Impacts on forest, vegetation, aquatic species (but limited to only fish species), sedimentation, water quality, and water quantity are addressed in the EIA. The EIA only briefly addresses cultural heritage, property and biodiversity. Cumulative indirect and interactive impacts are not addressed. Generally, limited surveys were conducted with much of the species survey relying a previous study completed in 2000 but were not updated for the purposes of ascertaining the baseline situation (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• NGOs including NGO Forum on Cambodia and the Rivers Coalition of Cambodia had the opportunity to comment and respond on the EIA report. However it is not clear that these comments were incorporated or reviewed by the new project developers (Source: Comments on Chapter VIII Environment Management Plan of the Lower Sesan 2 Draft EIA by Key Consultants Cambodia - 22 July, 2008, NGO Forum on Cambodia’s Lower Sesan 2 Hydro Project EIA Review).

• No information collected.

• The EIA made no consideration of upstream and downstream impacts in the Mekong River Basin or 3S (Sekong, Srepok, Sesan) watershed.

• Huaneng has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; and Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• No information collected on the company’s policies or commitments about biodiversity.

• The project area is located within the Lower Mekong Dry Forest Eco-region, and is also part of several Important Bird Areas as identified by Birdlife International (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• A 2012 study published in the Proceedings of the National Academy of Sciences found that the Lower Sesan 2 Dam would cause a 9.3% drop in fish biomass in the Mekong Basin, while threatening to push to extinction more than 50 fish species (Source: Guy Z., et al. 2012. Trading-off Fish Biodiversity, Food Security, and Hydropower in the Mekong River Basin, Proceeding of the National Academy of Sciences of the United States of America: vol. 109 no. 15 5609-5614).
• Cambodia’s Ministry of Agriculture, Forestry and Fisheries has reportedly halted the forest clearing activities in response to concerns about illegal logging in the reservoir area. Media reports in 2012, 2013 and 2014 note illegal logging has been associated with the commencement of project construction – particularly in, but also beyond, the inundation area.(Source: https://www.cambodiadaily.com/archives/sesan-ii-reservoir-a-laundry-for-illegal-timber-60575/).
• Proposed mitigation measures in the EMP include: The project design shall minimize the flooded level in order to reduce damage to forest and agricultural land, the number of resettlement households, and land and forest concessions. The alignment of the detour road with the national road and a new resettlement site shall be selected in places that do not adversly impact natural and social resources in the area. Fish passage structures or other approaches shall be provided to allow fish and other aquatic fauna to migrate upstream and downstream of the dam. A fish research center is one option to balance fisheries up- and downstream in both rivers. Reforestation in open space near the project area or in demonstrated area by Forestry Administration shall be undertaken during project construction and operation stages to compensate for the area of forest lost due to the project. The company shall also make a contribution to strengthen the forest and wildlife habitat conservation program in the area including cooperating with and contributing budget to the Forestry Administration and other conservation agencies to protect the forest and wildlife in and around the project area (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• No information was publicly disclosed on how the above measures have been implemented.
• No information was collected during our field work in October 2014 on biodiversity management during construction (Source: Site visit, October 2014).

• Huaneng has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; and Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• Huaneng’s Regulations on Environmental Protection Article 4 states that all pollutant discharges should be up to standard. Environmental laws and regulations violations and environmental pollution accidents should be avoided. Article 12 states that a qualified agency shall be commissioned to carry out environmental protection design, which should follow established procedures and meet the requirements concerning EIA approval, pollutant discharge standards, total pollution control, ecosystem protection, etc. Article 18 states that during construction, all pollutant discharges should meet national and local standards and requirements for total pollution control. In the cases where national or local standards and requirements are not met, control measures or modifications shall be taken. Waste and hazardous chemicals shall be properly managed and disposed to prevent potential environmental pollution. However, it is not clear whether the regulations apply to overseas projects.

• The EMP recommends basic management techniques for water, air, noise and public health impacts mitigation (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• However, no implementation or monitoring information has been released during the construction period on if the EMP is being managed, or on the changes in noise, water quality, air quality and public health due to project construction.

• No information collected.

• There has been no acknowledgement of impact or harm caused during construction on cultural heritage and sacred sites. The cultural heritage assessment concluded that there were no important sites, which is not in keeping with the views of local communities (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008; Site visit, October 2014).
• No evidence provided that ethnicity or indigenous culture and livelihoods are being factored into resettlement plans.

• Huaneng has endorsed the Global Compact, which includes the environment principles: Principle 7-Businesses should support a precautionary approach to environmental challenges; and Principle 8-Businesses should undertake initiatives to promote greater environmental responsibility.
• Huaneng’s Regulations on Environmental Protection Article 14: Water and soil conservation shall be supervised by a qualified agency in compliance with requirements by national authorities. After construction is completed, remediation and restoration of the ecological environment affected by construction shall be done in a timely manner to treat water loss and soil erosion. However, it is not clear whether the Regulations apply to overseas projects.

• Basic measures on this issue are listed in the EIA Report (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• No erosion and sediment control plan has been publically disclosed.
• Hydrolancang has commissioned a redesign study for a safer and more environmentally-friendly dam with easier sediment flushing and flood discharging (Source: http://www.phnompenhpost.com/national/sesan-dam-gets-new-design), however it is not clear how these designs will improve erosion and sediment management issues.
• No evidence of a cumulative impact assessment conducted in relation to sediment or erosion.

• No information collected.

• No Environmental Flows Assessment was undertaken. However, Hydrolancang has reportedly adopted design modifications for the project to reduce environmental impacts, though it is not known whether this includes environmental flows (Source: http://www.phnompenhpost.com/national/sesan-dam-gets-new-design). The EIA also recommends “the company should provide as close to pre-dam flows as possible to ensure keeping the ecosystem of the stream alive and so not to have a high negative impact on the aquatic fauna and flora downstream and upstream of the project site.” The adoption of the above measures has not been confirmed by project developers (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).

• No information collected.

• The EIA Report included some socio-economic analysis, but this has not been updated since 2008 (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• No measures have been announced for downstream communities and no mitigation measures for downstream communities were contained in the 2008 EIA (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• It is not clear whether local communities have been offered local employment opportunities. No confirmed reports on the establishment of a community development fund or other opportunities to support transition post resettlement (Source: Site visit, October 2014).
• No standard for post-resettlement livelihoods has been established by the dam developers despite commitments by the Cambodian Prime Minister that affected people will have better livelihoods (Source: Letter from Prime Minister Samdech Hun Sen, Letter No31: Clarification to the request by HE Son Chhay, Phnom Penh Parliamentarian, for delay in the implementation of the Hydropower Project of Lower Sesan II of the Vietnamese Company EVN in joint venture with the Royal Group Company, 28 July, 2011).

• No information collected.

• The Social Impact Assessment did not include gender or age disaggregation. No specific mitigation strategies for at risk populations (e.g. women, children, elderly) (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• Resettlement directly impacts several thousand people, and the resettlement assessments are not up to date. The Social Impact Assessment and resettlement plans were prepared several years before the start of construction and not updated at the time construction commenced (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008).
• NGO Forum on Cambodia has made several attempts to contact the company to obtain a copy of the Lower Sesan 2 EIA and it has never been provided (Source: Site visit, October 2014).

• No information collected.

• Under the previous dam developers, up to three consultation meetings were held during the EIA process (February and May 2008), and some selected NGOs were given an opportunity to provide feedback on the EIA at the Ministry of Environment (5 May 2009, November 2012 and February 2013). It has also been reported that the Stung Treng Provincial Governor met with villagers to outline resettlement options (Source: Comments on Chapter VIII Environment Management Plan of the Lower Sesan 2 Draft EIA by Key Consultants Cambodia, 22 July, 2008, NGO Forum on Cambodia’s Lower Sesan 2 Hydro Project EIA Review; Site visit, October 2014)
• Communities did not have the opportunity to participate in project design and development. Most of the information on the dam has been given by NGOs (Source: Site visit, October 2014).

• No information collected.

• Concerns, complaints and grievances are widespread across the communities in the project area and surroundings. Affected communities have organized numerous protests against the project and refused to resettle (Source: Site visit, October 2014).
• There is no formal mechanism to lodge grievances and concerns. Letters sent on behalf of local communities by regional, national and international NGOs have also remained unanswered by the project developers (Source: Site visit, October 2014).

• No information collected.

• No wider benefit sharing. However, Hydrolancang is reportedly considering establishing a social investment fund for the project, which could provide on-going support for communities, though this is not confirmed.

• Huaneng endorsed the Global Compact, whose human rights principles are: Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and Principle 2: Businesses should make sure that they are not complicit in human rights abuses. In its 2013 Sustainability Report, Huaneng reported its implementation as abiding by laws and regulations at home and abroad, supporting international conventions on human rights approved by the central government, safeguarding and respecting human rights, and guaranteeing employees’ legal rights and interest (Source: 2013 Sustainability Report).
• The labor principles in the Global Compact include: Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: Businesses should uphold the elimination of all forms of forced and compulsory labor; Principle 5: Businesses should uphold the effective abolition of child labor; and Principle 6: Businesses should uphold the elimination of discrimination in respect of employment and occupation. In its 2013 Sustainability Report, Huaneng reported its implementation as abiding by the national laws and regulations on labor issues, forbidding the use of child labor, opposing any forms of forced labor, adhering to equal and just labor policies and democratic management, making public the affairs of enterprises, and respecting the rights of labor (Source: 2013 Sustainability Report).

• In November and December 2014, local community members reported threats made by the Cambodian government to accept the asset survey process otherwise they would not be resettled or receive any compensation (Source: 3SPN Notes from Consultation with Communities, 2014).
• A complaint dated 13 January 2015 was also lodged in a submission to the UN Special Rapporteur on the Situation of Human Rights in Cambodia, prepared by local and international NGOs, covering the human rights impacts of the project.

• Huaneng Evaluation Standards on Hydroelectric Plant Safety, which concerns labor safety and the working environment, provides evaluation standards on safety for different types of work and machinery, on labor protection articles, and on the working environment including production area, safety signs, air quality, alarms, transportation safety, fire and explosion protection and other occupational hazards.

• No information collected.

• No information collected.

• No information collected.

• Huaneng endorsed the Global Compact. The anti-corruption principle in the Global Compact is that businesses should work against corruption in all its forms, including extortion and bribery.
• In 2012, Huaneng developed Manual on Prevention and Control of Corruption Risks (Source: 2012 Sustainability Report).

• No information collected.

• No information collected.

• The EIA contains a list of relevant ministries and laws for the Lower Sesan 2 Project but no analysis of the project developers’ specific obligations.
• During the fieldwork for this case study, local villagers in Phluk village had individual and community property impacted by road construction for the dam site and did not receive any compensation (Source: Site visit, October 2014).

• No information collected.

• Transboundary issues were neither addressed in the EMP nor the EIA (Source: Environmental Impact Assessment Report for Feasibility Study of Lower Sesan 2 Hydropower Project, Stung Treng Province, Cambodia, October 2008). In June 2013 and June 2014, the development partners to the Mekong River Commission (MRC) expressed concern over the project’s regional impacts and called for voluntary submission of the project to “Prior Consultation” under the Procedures for Notification, Prior Consultation and Agreement (PNPCA) of the 1995 Mekong Agreement. No response has been made to this call Joint Development Partner Statement: MRC Informal Donor Meeting, Phnom Penh, Cambodia, 28 June 2013; Joint Development Partner Statement Twentieth Meeting of the MRC Council Joint Meeting with the Eighteenth Development Partner Consultative Group, Bangkok, Thailand, 26 June 2014).

• In 2013, Huaneng revised and improved the Regulation of Safe Operation in Power Industry and issued the Management Methods for Training Staff of Power Generation Enterprises on Production Safety (Source: 2013 Sustainability Report).
• Huaneng Regulations on Safety in Production
• Huaneng Management Method for the Safety of Outsourcing Projects
• Huaneng Evaluation Standards on Hydroelectric Plant Safety covers the following four aspects: safety management in production, labor safety and the working environment, reservoir pivot constructions and external risks control, and production equipment and systems.
• Huaneng General Response Plans for Major Emergencies, which covers 18 types of major emergencies, has defined responsible organizations and their duties, established an emergency response system, and specified the needs for emergency support.
• Emergency Response Plan for Environmental Accidents and Huaneng Emergency Response Plan for Major Environmental Accidents have defined environmental accidents, analyzed the risks, defined responsible organizations and their duties, established prevention and warning mechanisms and raised post-emergency and information disclosure requirements.
• Huaneng Regulations on Environmental Protection Article 23: A feasible emergency response plan for environmental accidents shall be made. In the event that environmental accidents or other environmental emergencies have caused or might lead to pollution, contamination or health hazards, emergency measures shall be taken without any delay, organizations and residents that might be affected shall be informed in time, and reports shall be submitted immediately to local environmental authorities and the company for further investigation.

• No information collected.

• Huaneng Regulations on Environmental Protection Article 23: A feasible emergency response plan for environmental accidents shall be made. In the event that environmental accidents or other environmental emergencies have caused or might lead to pollution, contamination or health hazards, emergency measures shall be taken without any delay, organizations and residents that might be affected shall be informed in time, and reports shall be submitted immediately to local environmental authorities and the company for further investigation.
• No information collected on the policies concerning how the company informs communities in advance or discloses project risks.

• No information collected.