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AKOBEN : Ghana’s new initiative for environmental performance rating and disclosure in the mining sector Sekyi, Ransford 2011-11

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Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011  AKOBEN: Ghana’s New Initiative for environmental performance rating and disclosure in the mining sector Ransford Sekyi Environmental Protection Agency, Government of Ghana, Accra, Ghana Abstract The AKOBEN program is an environmental performance rating and disclosure initiative of the Environmental Protection Agency (EPA), Government of Ghana.  Under the AKOBEN initiative, the environmental performance of mining and manufacturing operations is assessed using a five-color rating scheme.  The five colors are GOLD, BLUE, GREEN, ORANGE and RED, indicating environmental performance ranging from excellent to poor.  These ratings are annually disclosed to the general public and the media, and it aims to strengthen public awareness and participation.  AKOBEN ratings are evaluated by analyzing more than one hundred performance indicators that include quantitative data as well as qualitative and visual information. These ratings measure the environmental performance of companies based on their day-to-day operations once they have successfully cleared their Environmental Impact Assessments (EIA) and obtained their environmental permit to operate.  These ratings indicate how well companies have met the commitments they made in their EIAs at the planning stage. AKOBEN, therefore, complements the EIA process and serves as a monitoring and verification program to ensure that companies follow environmental regulations on a continual basis. Introduction Ghana formerly known as Gold Coast was a British Colony, which gained independence on 6th March 1957. The country is located in West Africa, Figure 1. The current population of the country is about 22 Million (Preliminary Result of 2010 National Census). One of the aims of the Ghana National Environment Policy is to put in place appropriate incentives and sanctions to ensure compliance and enforcement of regulations. It is guided by the following principles of the National Environment Policy that states:  Use of the most cost effective means to achieve environmental objectives,  Use of incentives in addition to regulatory measures, and  Public participation in environmental decision-making. The Ghana Environmental Protection Agency (EPA) in carrying out its mandate and in conformity with the principles of the National Environment Policy uses the known orthodox regulatory methods such as the “carrot and stick” approach, legal actions and continuous enforcement through monitoring which has proven to be very expensive and time consuming. The EPA over the last decade has explored a number of different regulatory approaches and in that light developed the AKOBEN program. The AKOBEN program is an Environmental Performance Rating and Disclosure System for the mining and manufacturing industries (Allotey, et al., 2011).  Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011   Figure 1: Location of Ghana in Relation to Neighboring Countries and African Continent  Historical Perspective Ghana since independence from the British in 1957 has gone through both economic and political transformation. Ghana is located in West Africa and has a population of about 22 million. In 2009 the overall GDP was US$12.91 billion, the growth rate was 4.7% and the per capita income was US$1500. On the political front, the country has gone through various phases from post-independence multi-party democracy through military coup d’états to the current stable multi-party democracy since 1992. Ghana practices liberal and free market systems and a majority of the population is engaged in farming. Majority of the farming is practiced on subsistence level and the country is the second producer and exporter of cocoa in the world. The country abounds with non-renewable natural resources. Notably among these resources include gold, diamonds, bauxite, manganese and recently the discovery and production of oil in commercial quantities. Ghana is the second largest gold producer in Africa and gold has been exploited in the country for over a century. There are a number of multinational companies operating in Ghana in both the mining and oil sectors including: • Newmont Gold Inc. (US based Company) • Golden Star Resources Inc. (US based Company) • AngloGold Ashanti Plc. (South Africa Based Company) • Goldfields Plc. (South Africa based Company) • Tullow Oil Inc (US based Company) Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 • Kosmos Energy Inc. (US based Company).   In 1974, two years after the first United Nations’ Conference on the Human Environment in Stockholm, Sweden, the Ghana Environmental Protection Council (EPC) was established as an initial step towards environmental governance mechanism. The EPC was primarily an advisory and research institution and had no enforcement powers to ensure environmental sanity and or preventing damage to the environment. Ghana like other developing countries exploited its natural resources and carried out other economic endeavours with little or no environmental considerations. However, the economy experienced a decline due to inappropriate economic policies, institutional rigidities, and the combined effects of poor weather, and internal and external shocks. To arrest the continuous decline in the economy, the Economic Recovery Program was launched in 1983.  The program resulted in positive growth but not without social and environmental cost. This led to a recognition that the sustainability of economic and social development depends on proper and responsible management of the natural resource base and the environment. In March 1988, the Government of Ghana initiated a major effort to put environmental issues on the priority agenda through the preparation of the National Environmental Action Plan. The Plan called for the urgent restructuring of the EPC with the necessary political backing as well as minimum level of enforcement powers to enable it carry out these additional responsibilities. This call led to the transformation of the Environmental Protection Council into the Environmental Protection Agency (EPA) in 1994 with regulatory powers and put in place an Environmental Impact Assessment (EIA) system that required that all new development activities go through the EIA process and secure environmental permits before start of operations whilst all existing undertakings were to prepare environmental management plans. The EPA considered environmental disclosure as a possible policy tool with the passage of the Environmental Assessment Regulations, LI1652 in 1999. The EPA, since the introduction of the EIA process, has used a number of orthodox environmental management tools to regulate the various undertakings.  The continuous uses of the traditional environmental management methods have proven too expensive and require tremendous resources.  The Meaning of AKOBEN The name of the environmental rating program—AKOBEN—has its roots in Ghana’s tradition of Adinkra symbols (  Figure 2 shows the Adinkra symbol for AKOBEN.  AKOBEN stands for vigilance and wariness—a set of behaviors that is pertinent for the issue of environmental conservation. Further, AKOBEN also signifies alertness and readiness to serve a good cause.  The AKOBEN program has strong Ghanaian roots and its rating methodology is tailored to reflect Ghana’s environmental values. It is for this reason that the AKOBEN program encompasses both physical and human environment in the rating methodology.  The first environmental rating and disclosure initiative was introduced in 1995 by Indonesia (Afsah, et al, 1997).  The Indonesian Program for Pollution Control Evaluation and Rating (PROPER) is not Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 comparable with AKOBEN and there are important distinctions between the two programs. Most important of all, the PROPER program does not yet have published rating criteria for the mining sector. Therefore, the AKOBEN program is the first in the world with a detailed environmental rating methodology for the mining sector. For this reason the AKOBEN program is an important contribution to the ongoing international effort in the field of environmental rating and public disclosure, specifically in the mining sector.            Figure 2: Adinkra symbol for AKOBEN  AKOBEN Program  Introduction  With the passage of the Environmental Assessment Regulations, LI1652 in 1999, the EPA considered environmental disclosure as a possible policy tool. This would make the EIA system comprehensive with a component to ensure that commitments made by developers are enforceable. However, it is important to state that, in developing countries strict enforcement of the rules could have serious social and economic costs. As a result, trade-offs ought to be accepted to achieve environmental objectives. These considerations, in addition to the provisions in the National Environment Policy, informed the type of disclosure-with-enforcement regime to adopt.  The history of EPA’s effort to launch an effective environmental disclosure is shown below in Figure 3.  AKOBEN represents the culmination of more than a decade long effort by EPA.  Under the AKOBEN Program (details of the program can be found at, the environmental performance of a mine site is assessed using a five-color rating scheme. The five colors are GOLD, GREEN, BLUE, ORANGE and RED, and it  Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 encompasses the full spectrum of environmental performance ranging from excellent to poor. These ratings are then disclosed to the public and the general media.  This section takes a step-wise approach to explain the rating methodology for mine sites in Ghana. First the conceptual framework of the rating system is presented, followed by the description of the basic rating rules of the AKOBEN program. Then the specific criteria are presented for each category of rating indicators. The remainder of the section clarifies the guidelines on the monitoring points, data sources, data analysis methodology, dispute resolution and rating disclosure. Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011  1999 2000-2006 2005-2007 2008-2010 The EPA Discloses the performance of Mining Company based on the basic criteria including posting of Reclamation Bond as per the LI 1652, June 1999    → The EPA Initiates and Implement Continuous Environmental Improvement Awards whilst Piloting the Performance Rating and Disclosure based on revised Criteria    → Ended the Piloting Program that was supported by the World Bank and was concluded that more work will be require before institutionalization of the program    → The Agency enhances and deepen the Disclosure Concept and create a brand name AKOBEN and gets support from International Experts on Environmental Performance and Rating. Project officially lunched and rating disclosed in November 2010 Figure 3: Pathway to the AKOBEN Program Implementation  AKOBEN Rating Methodology  Concept Traditionally, an analysis of environmental performance is limited to the assessment of whether or not a quantitative value of an environmental parameter has exceeded its numerical standards. At other times, regulators check if a mine site has followed the procedural requirements related to permits and reporting. These approaches are useful but they fail to adequately capture some of the new concepts of environmental performance that include corporate social responsibility, voluntary over-compliance and other non-regulatory environmental objectives. In short, a simple “In Compliance/Not in Compliance” type of assessment is too limited to provide a comprehensive picture of the complex environmental and ecological conditions one typically finds at mining sites.  Therefore, the AKOBEN rating methodology for the mining sector uses an approach that reflects the modern concepts of corporate environmental and social performance including ideas such as community relationships, public participation, conflict resolution and continual improvement.  AKOBEN’s methodology has several unique and innovative features that make it the first rating model of its kind for the mining sector. This rating methodology maps environmental performance of mining company into five color codes that are easy to communicate to the general public. This rating methodology uses quantitative, qualitative and visual information to comprehensively evaluate the environmental performance of each mine site.  AKOBEN’s approach to environmental performance measurement is designed to be practical, and it Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 also aims to minimize the use of controversial or vague indicators. Existing literature on environmental and social performance measurement is filled with innumerable ideas and concepts, AKOBEN’s rating system has narrowed it down to only those performance indicators that can be measured, verified and validated by a third party. Further, the focus of the rating system is on environmental outcomes that indicate various levels of environmental and health risks, the probability of restoration of environmental conditions in the long-term, and the quality of corporate commitment to social issues. Using these principles, the AKOBEN rating system maps the environmental performance of mine sites using a five-color rating scheme.  These colors are GOLD, GREEN, BLUE, ORANGE and RED, representing the best to the worst performance range. These color categories represent five specific levels of environmental performance, and the criteria for each color code are explained in brief  in Tables 1 whilst Table 2 provides the basic rating rules/explanation to the color coding.  In conceptual terms, however, BLUE, ORANGE and RED ratings pertain to regulatory compliance only, and accordingly these colors indicate the performance of a mine site relative to the mandatory national regulatory requirements related to environmental issues and the reclamation bond. In comparison, the GOLD and the GREEN ratings indicate the quality of social and community actions undertaken by mining companies to further enhance its environmental and social performance.  Table 1:   Explanation to AKOBEN Color Coding  Rating Level Performance General Description  RED Poor Failed to follow environmental law (LI 1652), shows pattern of chronic exceedances, and creates risks from toxics and hazardous wastes mismanagement and discharges ORANGE Unsatisfactory Exceedance of regulatory standards for non-toxics, weak environmental monitoring, and incomplete fulfillment of reclamation bond criteria BLUE  Good Adequate compliance with environmental standards and reclamation bond criteria GREEN Very Good BLUE + adopts voluntary initiatives and is responsive to public complaints GOLD Excellent Green + mine site follows its corporate social responsibility policies   Explanations to Framework for Social Criteria The AKOBEN Program incorporates two socially oriented criteria that relate to the catchment Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 communities within which the mining companies operate. These relate to Responsiveness to Community Complaints that relate to environment and Company’s own commitment to Corporate Social Responsibility Programs.  Environmental Complaints Environmental related complaints, as described solely for the AKOBEN Program, include the following complaints that: • are operation related and do hamper the welfare of the communities in the proximity of the project area, • affect water resources of the communities in the catchment area of the project, and • affect the ambient air quality due to dust and noise. Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011  Table 2. Basic Rating Rules/Explanation to the Color Coding Rating Level Rating Criteria Details Legal Requirements Legal Requirements-Permits and Reporting: 1. Company has valid environmental permit. 2. Company has submitted all monthly/quarterly returns by the end of the following month/quarter. 3. Company has submitted the Annual Environmental Report by the end of the first quarter 4. If applicable, the company applied for EMP renewal two months before expiry. RED Hazardous and Toxic Waste Management On-site Hazardous Chemicals and Waste Management: 5. If a Company is a hazardous waste generator, has it notified the EPA about it? 6. Are hazardous chemicals and wastes properly stored and handled at the site? Effluent Quality Compliance: 1. Is the company in compliance with the standard for effluent quality parameters for nine or more months over a twelve months period? Ambient Air Quality Compliance: 2. Is the company in compliance with the standards for ambient air quality at its monitoring stations for nine or more months over a twelve months period? Air Emissions Compliance: 3. Is the company in compliance with the standard for air emissions for nine or more months over a twelve months period? Compliance with Environmental Quality Standards Noise Pollution Compliance: 4. Is the company in compliance with the standard for noise pollution for nine or more months over a twelve months period? Effluent Quality Reporting: 5. Has the company monitored and reported the effluent quality data for at least nine months (75% reporting)? ORANGE/ BLUE Environmental Monitoring and Reporting Ambient Air Quality Reporting: Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 6. Has the company monitored and reported the air quality data for at least nine months (75% reporting)? Air Emissions Reporting: 7. Has the company monitored and reported the air emissions data for at least nine months (75% reporting)? Noise Pollution Reporting: 8. Has the company monitored and reported the noise pollution data for at least nine months (75% reporting)? Compliance Management System: 9. Does the company have proper systems and plans for managing effluent quality? 10. Does the company have proper systems and plans for managing air quality? 11. Does the company have a proper system and plan for managing noise pollution? Environmental Management Systems: 12. Does the company have environmental performance objectives and targets? 13. Are environmental management roles and responsibilities properly defined and communicated? 14. Are environmental staffs regularly trained? (try to get the number of staff who received environmental training regularly) 15. Are there procedures for communicating environmental issues to employees? 16. Does the company conduct third party environmental audit? Best Practices Environmental Management Water  and Energy Use: 17. Is the process water use monitored and reported to EPA? 18. Is the non-process water use monitored and reported to EPA? 19. Is the energy consumption monitored and reported to EPA? 20. Does the company record the energy generated on site? 21. Does the company use any energy from renewable sources (biomass, solar, other)? GREEN Complaints Management and Community Responsiveness to Environmental Complaints: 1. The company has Standard Operating Procedure (SOP) for handling verbal and written public complaints Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 Relations 2. The company has proper recording system to register and track public complaints. 3. The company regularly and accurately reports the complaints to EPA in its Annual Environmental Report 4. The company has addressed all complaints and that there is no unresolved environmental complaint GOLD Corporate Social Responsibility (CSR) Implementation of Corporate Social Responsibility Policy: 1. Does the company have a formal CSR Policy? 2. Is the CSR policy published or posted on a website for public access? 3. The CSR policy recommends community/regional/national development 4. The CSR policy supports consultation with community 5. The CSR policy supports local training and economic empowerment of communities 6. Does the company have the data on annual expenditure on community development activities, including charitable contributions? 7. Does the company advertise all relevant job opportunities locally?  Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 12   Non-environmental complaints are those that may be related to crop compensation, land ownership issues, and other resettlement related issues specifically for mining companies. Environmental complaints are an integral part of the concept of community monitoring of mining operations, and it complements EPA’s regulatory inspections in important ways (Dasgupta and Wheeler 1997). Since it is not feasible for EPA to continually monitor on-site environmental discharges and emissions, local communities are important sources of information for regulators. AKOBEN’s rating methodology therefore assigns considerable importance to environmental complaints received from the public, and views this channel for equalizing a situation of asymmetric information between companies and regulators. It is also important to state that environmental complaints are not always legitimate and AKOBEN’s rating methodology recognizes that fact and takes this into account.  Given the complexities of the relationship between companies and its neighboring communities, it is important to screen out frivolous complaints from the genuine ones. For this reason, the management of environmental complaints is a complex matter that needs to be handled with care. Otherwise it is possible that a normally manageable complaint can easily escalate into a costly confrontation between communities and companies. AKOBEN’s rating methodology aims to discourage such a situation from occurring, but at the same time it gives due credence to legitimate environmental complaints. A company needs a good overall complaints management policy and tracking system to effectively manage the environmental complaints it receives.  Accordingly, AKOBEN assesses the overall commitment and the policy of a company towards community complaints. It is not sufficient to just have a Standard Operating Procedure (SOP) for complaints management because the final outcome depends on how well the written policies are implemented. AKOBEN recognizes that companies that are responsive to public complaints may attract more complaints compared to those that are comparatively less responsive. Therefore, the focus of evaluation for AKOBEN would be on the level of responsiveness and successful closure of complaints rather than just the volume of complaints. The evaluation would also take into consideration the long- term trend of company behavior. And finally, specific incidents of unusual public complaints would be evaluated on a case specific basis by the AKOBEN team.  Evaluation of environmental complaints also includes the process of authentication by EPA inspectors. The verification process would include field visits, discussions with communities and companies, and if deemed necessary, samples would be collected for technical review and analysis. To enable the EPA inspectors to conduct a proper review of environmental complaints, companies are required to maintain a comprehensive record of all complaints and their responses. This information is checked during the AKOBEN audit of companies.  Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 13  Company’s Corporate Social Responsibility towards Catchment Communities1 The AKOBEN rating methodology encompasses the concept of social performance of companies also. However, unlike environmental performance that can be quantified through technical and scientific measurements, social performance cannot be measured and expressed in such numerical terms. It is a real challenge to evaluate the quality of social performance of companies because there are no quantitative regulatory standards for social performance. Nevertheless, social performance is the highest ranking rating criteria in the AKOBEN program as it ultimately determines whether or not a company would obtain a GOLD rating.  To evaluate the social responsibility actions of companies, AKOBEN rating methodology does not impose any mandatory performance standards on companies. Instead it has selected to assess performance of companies solely on the basis of how well each company implements its own corporate social responsibility policy. In other words, each company is held accountable only on the basis of the policies its corporate headquarters has mandated. Accordingly, the assessments of social performance of a company include three aspects. These are (1) intent of the company towards social issues, (2) expression of intent through a comprehensive social policy, and (3) the actions it undertakes in accordance with its CSR policy.  To conduct this evaluation the AKOBEN team of EPA would collect each company’s corporate social responsibility policy and review it to develop a checklist of resource commitments, community development projects and activities that its policy recommends and has implemented during the year under review. Each company’s checklist would be evaluated against the actual community development activities observed at the site of business operations. Based on this evaluation, the AKOBEN team would assess the qualifications for a GOLD rating. Since such an evaluation is expected to be very detailed and labour intensive, only those companies that have cleared the criteria for the GREEN rating would be subjected to the GOLD level review.  Data Collection and Quality Assurance The AKOBEN rating methodology is a data intensive system, and therefore complete and reliable data are critical requirements. Most of the data is compiled from the mandatory monitoring reports that each mining company is required to submit monthly to EPA, additional data is also collected by the Agency during regulatory inspections. Finally, the EPA AKOBEN team conducts field audits to collect information that are not reported in the regular monthly reports. The field audits evaluate performance in the following;   • Best practices in pit and waste rock management • Rehabilitation/Restoration of degraded lands • Ore Processing including chemical handling and tailings storage management  1  Communities within the area of influence of mining operation Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 14 • Waste management focusing essentially on hazardous waste • Environmental Quality Sampling as part of the verification process of the monthly returns • Verification of the provision of community development projects as part of Corporate Social Responsibility Program • Interaction with Catchment Community as part environmental complaint resolution mechanism.  There have been some data quality concerns because of sampling, laboratory or human data entry errors. Use of certified laboratories is preferred, because there have been variable laboratory capabilities for testing some of the metals or other such complex environmental parameters. The quantitative information on environmental parameters is analyzed by a computer model that uses various statistical tools to check the accuracy, completeness and trends in the data, and compute the probability of exceedance for compliance monitoring points at mine sites. All the qualitative information is converted into a “0 or 1” score and supported by proper documentation to justify the evaluation. It is essential to state that digital imagery forms a critical part of data gathering and the documentation process. AKOBEN’s ratings reports are designed to provide comprehensive analytical results and actionable information to mining companies so that both the EPA and the mines have a common understanding of performance gaps and where improvement efforts are required.  Environmental Quality Standards for Water and Air Quality For the purposes of the rating, AKOBEN program apply the following standards:  • EPA’s Sector Specific Effluent Quality Guidelines and air quality guidelines, where appropriate, and • Guidelines of International Institutions (e.g. World Health Organization, WHO, World Bank/International Finance Corporation, WB/IFC).  In addition, standards and or guidelines will apply to sampling locations that are specified in each company’s Environmental Management Plan (EMP). Each EMP is therefore required to specify all the monitoring points, its appropriate category (compliance, surveillance or reference point) and the applicable regulation and standards that are subsequently applied.  AKOBEN Rating Reports and Results Disclosure An important goal of the AKOBEN program is to create incentive for environmental improvement through information. One aspect of this informational incentive is the improved understanding of environmental performance that the AKOBEN program is creating for mining companies. As part of the AKOBEN program, each mining company receives a comprehensive ratings report from EPA. This report clearly shows where performance is strong and where there are gaps. The ratings report provides clear guidance on where a mining company needs to make improvements in the future.  Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 15 The AKOBEN program follows a two-step procedure for disclosing the results of the rating to the public and the media. As a first step, AKOBEN privately share the results of the ratings with mining companies. Where there are disputable issues, the mining company informs the AKOBEN team in writing. Upon receipt of the feedback, the AKOBEN team reviews the ratings and submits the reviewed rating results to the company. The final ratings are subsequently disclosed to the public.  Grievance Redressal Mechanism The AKOBEN program is aimed to be a collaborative effort between EPA and mining companies. While EPA is strictly applying the regulatory standards to evaluate the ratings of mining companies, it also recognizes their social and community development efforts. With such an approach, EPA aims to strengthen the environmental and social performance incentives for mining companies, and at the same time improve public awareness.  AKOBEN’s rating system is a complex process, which requires multi-dimensional data and information, and it is likely that sometimes there could be a difference of opinion with mining companies. Therefore, AKOBEN’s disclosure strategy follows a two-step procedure that would allow for any differences to be discussed and resolved. If required, EPA could conduct fresh data collection and field visits, and also provide documentary and analytical evidence to explain the basis of its evaluation.  Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 16 AKOBEN Launch and Rating Results for 2009 and 2010 The AKOBEN program was successfully launched in November 2010 and inaugurated by the Office of the Vice President of the Republic of Ghana and the Minister responsible for Environment, Science and Technology. Speaking at the function, Hon. Sherry Ayittey, Minister for the Environment, Science and Technology, said the AKOBEN initiative symbolizes government’s resolve to tackle the challenges of environmental degradation and natural resource management through transparency, disclosure, public awareness creation and community participation.  In the first round of ratings, eleven mining companies were rated. No company received a BLUE or better rating, showing that all the companies had at least one or more compliance violations. Tables 3 and 4 illustrate respectively the ratings for 2009, which, was released in November 2010, and that for 2010 which is to be released in October 2011. The majority of companies from the mining sector had serious environmental violations as measured by the RED rating based on the percentage score in 2009 ratings. However, the final ratings for the 2010 show slight improvement in the legal, toxic and hazardous waste management and complaint management criteria/regime. Table 5 provides comparative analysis for the 2009 and 2010 ratings whilst Table 6 provides a comparison between the percentage scores for 2009 and 2010.  Conclusions This paper provides information on Ghana’s development and implementation of the AKOBEN Program, that will ensure environmental compliance without excessive cost, ensure that commitments of companies are adhered to and also provide credible and dependable data, which could be shared and used during dispute resolution in terms of lodgment of environmental complaints against companies and raising of concerns by both local and international non-governmental organizations.  The paper also provides the information on how it took over a decade to fully develop the AKOBEN Program which is an environmental transparency initiative. Starting from just an idea in 1999, graduating into pilot tests and ultimately into a full-fledged regulatory program in 2011. Initial results and feedback from companies show that disclosure is an effective environmental enforcement tool. It works outside the formal court system through reputational incentives and community and media pressure to motivate firms to comply with environmental regulations. Additionally, the experience of Ghana shows that the color-code format for evaluating and rating environmental performance of companies is effective.  Acknowledgments The author would like to acknowledge two colleagues who are integral part of the Akoben team, namely Shakeb Afsah with Performeks LLC, Bethesda, Maryland, USA and  Haron Harrison-Afful, EPA, Ghana. Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 17 Table 3. Overall Mining ratings for 2009 Released in November 2010  Company 1 Legal Issues 2 Hazardous Waste Management 3A Toxics Releases 3B Non- Toxic Releases 4 Monitoring and Reporting 5 Environmental Best Practices 6 Community Complaints 7 Corporate Social Responsibility Final Rating A Blue Blue Blue Blue Orange Orange Green Gold Orange B Red Red Red Orange Orange Orange Not Adequate Gold Red C Blue Red Red Orange Orange Orange Green Gold Red D Blue Blue N/A Orange Orange Blue Green Gold Orange E Red Red N/A Blue Orange Orange Not Adequate Not Adequate Red F Blue Blue N/A Blue Orange Blue Not Adequate Gold Orange G Blue Blue Red Blue Orange Orange Not Adequate Not Adequate Red H Blue Blue Red Blue Orange Blue Not Adequate Gold Red I Red Red Red Orange Orange Blue Not Adequate Gold Red J Blue Red Blue Orange Orange Blue Not Adequate Gold Red K Red Red N/A Orange Orange No Data No Date No Data Red   Table 4. Overall Mining ratings for 2010, to be released in September 2011  Company 1 Legal Issues 2 Hazardous Waste Management 3A Toxics Releases 3B Non- Toxic Releases 4 Monitoring and Reporting 5 Environmental Best Practices 6 Community Complaints 7 Corporate Social Responsibility Final Rating A Blue Blue Blue Blue Blue Blue Green Gold Blue B Blue Blue Red Orange Orange Blue Green Gold Red C Blue Blue Red Orange Orange Orange Not Adequate Gold Red D Blue Blue Blue Blue Orange Nlue Green Gold Orange Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 18 E Red N/A N/A No Data No Data Blue Fail Fail Red F Blue Blue Blue Orange Blue Blue Not Adequate Gold Orange G Blue Blue Red Blue Orange Blue Green Gold Red H Red Blue Red Blue Orange Orange Green Gold Red I Blue Blue Blue Blue Orange Blue Not Adequate Gold Orange J Blue Blue Blue Blue Blue Blue Not Adequate Gold Blue K Red N/A N/A No Data No Data Orange Fail Fail Red  Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 19 Table 5. Comparative Rating Results for 2009 and 2010   Table 6. Analysis of rating percentiles for 2009 and 2010  Akoben 2009 Akoben 2010 Color Number Percentage Number Percentage Red 8 73 6 55 Orange 3 27 3 27 Blue 0 0 2 18  References  Afsah, S., Laplante, B. and Wheeler, D., 1997 “Regulation in the Information Age: Indonesia’s Program for Environmental Management”, World Bank  Allotey, J., Sekyi, R., Faabeluon, L., Erquaye-Tetteh, E.N., Affull, H.H., Sarfo-Afriyie, Y., Forocco, S. and Afsah, S. (2011) Integration of Environmental Discloure into Regulatory Management: The Case of AKOBEN Environmental Rating Programme, Proccedings of 9th International Conference for Environmental Compliance and Enforcement, Track E: Non-Traditional Approaches, Interantional Network for Environmental Compliance and Enforcement, 12 pp. ( (accessed August 17, 2011)  Company Akoben 2009 Akoben 2010 A Orange Blue B Red Red C Red Red D Orange Orange E Red Red F Orange Orange G Red Red H Red Red I Red Orange J Red Blue K Red Red Proceedings Tailings and Mine Waste 2011 Vancouver, BC, November 6 to 9, 2011 20 Dasgupta, S, and Wheeler, D., 1997, “Citizen Complaints as Environmental Indicators: Evidence from China”, Policy Research Working Paper # 1704, World Bank


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