Citizens' Tool for Monitoring Environmental Performance of Oil and Gas Companies

THE CITIZENS’ TOOL

FOR MONITORING THE ENVIRONMENTAL
PERFORMANCE OF OIL AND GAS COMPANIES
DEVELOPED BY CIVIL SOCIETY COALITION ON OIL AND GAS (CSCO)
IN COLLABORATION WITHCIVIL SOCIETY ALLIANCE ON OIL AND GAS IN SOUTH AND EASTERN AFRICA (COSEA)
WITH SUPPORT FROM WWF REGIONAL OFFICE FOR AFRICA – ENERGY HUB.

ACKNOWLEDGEMENTS:
We are very grateful to all those who contributed in various ways to the initiation and development of
this Citizens’ tool for monitoring environmental performance of oil and gas companies. The team is
grateful to the CSCO Steering Committee (2014); the oil and gas companies in Uganda who cooperated
in pre-testing the tool, the district local governments and local community representatives. The people
involved are too many to mention, but the following deserve special mention. We are grateful to the
following members of the study team; Twebaze Paul and Nathan Makuregye of Pro-Biodiversity
Conservationists in Uganda (PROBICOU); Geofrey Odama and Agnes Ochokoru of Rural Integrated
Community Empowerment – West Nile (RICE-WN); Ivan Amanigaruhanga and Robert Ddamulira of the
WWF Regional Office for Africa (WWF ROA) – Energy Hub among others.
We also wish to acknowledge and appreciate the support we have received in this process from CSOs
from Mozambique, Tanzania and Kenya.

DISCLAIMER:
The views presented in this document don’t reflect the official positions of the organizations or
individuals involved. The tool report is supplied in good faith and reflects the knowledge, expertise and
experience of the parties involved. The tool must not be published, quoted or disseminated to any other
party without appropriately referencing CSCO and Civil Society Alliance on Oil and Gas in South and
Eastern Africa (COSEA) as authors of the work. CSCO and COSEA accept no responsibility for any loss
occasioned by any person acting or refraining from action as a result of reliance on the report.
In conducting the analysis in the report the study team has endeavoured to use the best information
available at the date of publication, including information supplied by the various respondents. The
study team approach has been to develop analyses from first principles, on the basis of logic and
available knowledge and evidence from the field. Unless stated otherwise, the study team does not
warrant the accuracy of any results in the use of the tool.

Contents
ACKNOWLEDGEMENTS: ................................................................................................................................ 2
DISCLAIMER: ................................................................................................................................................. 2
1.0

INTRODUCTION TO THE TOOL .......................................................................................................... 4

1.1

COVERAGE AND FOCUS OF THE TOOL .......................................................................................... 5

1.2

OBJECTIVES ................................................................................................................................... 5

1.2.1

Overall objective: .................................................................................................................. 5

1.2.2

Specific objectives: ................................................................................................................ 5

2.0

METHODOLOGY OF TOOL DEVELOPMENT ....................................................................................... 5

2.1

EVIDENCE-BASED TOOL: ............................................................................................................... 6

2.2

HOW TO APPLY THE TOOL: ........................................................................................................... 6

3.0

MONITORING ELEMENTS AND REQUIREMENTS: ............................................................................. 7

Table1: Showing monitoring elements, specific requirements and observation checklists..................... 7
ATTACHMENT 1: ENVIRONMENTAL PERFORMANCE MONITORING TOOL – SCORE SHEET ................... 19

1.0 INTRODUCTION TO THE TOOL
Oil and gas resources are important for human development. However, the development,
transfer and utilization of these fossil-fuel resources presents significant challenges to the longterm conservation of the environment and natural resource especially in areas where oil and
gas production takes place in Africa.
The “Citizens’ tool for monitoring environmental performance of oil & gas companies (herein

referred to as MEPOC)” is an instrument which has been developed by WWF Regional Office for
Africa (ROA) Energy Hub and CSCO (in collaboration with COSEA) for establishing the extent to
which any given oil and gas company is effectively managing and conserving environmental
resources, biodiversity and maintaining vital ecosystem services through its direct and indirect
activities in a given area over the long-term.
The tool covers management actions, policies and guidelines or failure thereof, by companies;
their representatives and their contractors or sub-contractors with respect to implementing
international and national environmental safeguards during oil and gas development.
The tool is based on prevailing national, regional international best practices1 (specifically the
IFC Performance Standards and ISO-14001 Environmental Standards as well as associated
national legal, policy and other legislative frameworks and best practices.
It is in this regard that the research team seeks to establish;
1) To what extent to which an oil and gas company effectively implements the
requirements of the IFC performance standards for environmental management.
2) The extent to which an oil and gas company is ISO-140001 compliant in its practices.
3) The extent to which an oil and gas company complies with and exceeds the expectations
of a host country’s environmental laws, standards and regulatory requirements.
Environmental conservation (in the petroleum sector) involves practices aimed at resource
efficiency, waste minimization, protection of biodiversity (identification and
protection/enhancement of important/‘critical’ habitats and ecosystems/livelihoods), pollution
prevention, among others, as influenced by environmental legislation and ethics in day-to-day
conduct of oil and gas companies.

1

Best practices are defined as the exercise of professional skill, diligence, prudence and foresight that would
reasonably be expected from skilled and experienced professionals engaged in the same type of undertaking under
the same or similar circumstances globally and regionally (IFC, 2012)

1.1

COVERAGE AND FOCUS OF THE TOOL

The tool covers the elements of the ISO 14001 Standards 1 – 8, IFC Performance standards 1
and 6 and appropriate environmental laws and regulations of the country in which it is being
administered to measure the level of compliance of international oil companies (IOC). The main
themes that form the core focus of the tool are environmental management, biodiversity
conservation and maintenance of ecosystem services. The breakdown of the standard elements
and their respective requirements is presented in appendix 1.

1.2

OBJECTIVES

1.2.1

Overall objective:

The overall objective of the tool is to design a mechanism for facilitating an objective discussion
between civil society organizations and International Oil and Gas Companies on issues of
environmental concern as a means towards generating consensus for win-win solutions that
benefit people, the industry and the long-term conservation of the environment. The specific
objectives of applying this tool are further discussed below;
1.2.2 Specific objectives:
The tool enables citizens and oil and gas companies to;

i.
ii.

Periodically discuss and objectively assess how oil and gas development activities are
affecting the environment and natural resources.
Jointly develop and agree upon corrective measures and recommendations on how to
maintain environmental and ecosystem integrity in areas of oil and gas development.

2.0 METHODOLOGY OF TOOL DEVELOPMENT
The initiative is a civil society-led approach to monitoring environmental performance of oil and
gas companies operating in Africa and particularly in areas of high biodiversity conservation
value and which are important to local livelihoods. The idea was jointly developed through a in
a participatory process by COSEA with support from the WWF Regional Office for Africa Energy
Hub. The process involved initial discussions with competent CSO members particularly in

Uganda representing COSEA, for purposes of concretizing the idea, brainstorming on the best
implementation approach and sequencing of activities.

2.1

EVIDENCE-BASED TOOL:

This is an evidence-based tool that draws its conclusions based on the available information
encountered during its application. Literature on environmental requirements of international
standards and local laws should be reviewed to generate a list of ‘what to look out for’, also
known as monitoring indicators/elements.
Being an evidence-based approach, this is a critical step as Oil and Gas companies can only be
justifiably held accountable for what they are mandated to do.

2.2

HOW TO APPLY THE TOOL:

A score-sheet showing specific monitoring elements, requirements and sample questions for
each of the requirements is developed and applied on company staff at national offices, field
offices, local government leaders, select affected communities and civil society representing
such communities. The score-sheet also defines scoring criteria upon which deductions can be
made. Analysis of performance and assessment of company compliance to environmental
standards is based on responses/opinions and perspectives of all categories of stakeholders
engaged when applying the tool.
Other considerations to make when applying this tool include;
o Conducting adequate literature review to familiarize yourself with what the
company is doing, what is planned and identify any gaps or best practices
applied.
o Think of 3-5 questions per standard element to guide the collection of data from
companies.
o Where possible, company and stakeholder interviews should be with
departments/focus groups and not individuals so as to record positions that are
developed through consensus.
o This is an evidence-based approach, which requires the researcher to collect
evidence before a score is awarded and where evidence can’t be obtained such
criteria is better left un-awarded.

o The person administering this tool must have a good understanding of the
standards upon which the assessment is premised; particularly the IFC
performance standards2
o The tool is recommended to be applied by CSOs operating in a team of 3-5
experienced researchers with ability to balance and analyze responses to come
to acceptable conclusions.
o The team must seek and secure feedback first from the oil and gas companies
before cross-referencing such feedback with feedback from other stakeholders.
o Present findings of the tool objectively without making comparison of companies
being assessed.
o The detailed monitoring elements are only meant to assist the researchers in
framing their inquiry appropriately but are not meant to be followed judiciously
through the interview. Instead a summarized interview guide is attached in
Attachment 1.
Note: while the tool is aimed to be as objective as possible based on prevailing evidence; a
degree of subjectivity remains and this can only be eliminated through more cross-referencing
and group discussions rather than individual interviews.

3.0 MONITORING ELEMENTS AND REQUIREMENTS:
Table 1 below outlines the various monitoring elements and requirements identified as critical for
facilitating CSOs towards effective monitoring of the environmental performance of oil and gas
companies.

Table1: Showing monitoring elements, specific requirements and
observation checklists
MONITORING
ELEMENT

REQUIREMENT(S)

Environmental
Management
System (EMS)

Every oil and gas company must have a  Request to look at a copy – if the
dynamic and continuous system of Environmental Management system is
identifying, assessing and managing documented.
environmental and social risks that are  Cross check on company websites for
directly and indirectly associated with their Environmental Management
activities. This involves engagement

OBSERVATION CHECK LIST

2

http://www.ifc.org/wps/wcm/connect/c8f524004a73daeca09afdf998895a12/IFC_Performance_Standards.pdf?M
OD=AJPERES

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OBSERVATION CHECK LIST

between the company, its workers, local System/Plans information
communities directly affected and other
 Observe different components of the
stakeholders (IFC, Performance Standard 1:
system in practice;-for example the
Para 5. ISO 14001 Clause 1-4).
policy statement may be pinned in office.
The ESMS must incorporate the following  Take an initiative of ascertaining whether
elements: (i) policy; (ii) identification of risks other members of staff, stakeholders etc
and impacts; (iii) management programs; know about the Environmental
(iv) organizational capacity and competency; Management system and how often
(v) emergency preparedness and response; stakeholders may be involved
(vi) stakeholder engagement; and (vii)
monitoring and review. These sub-elements  Request for monitoring reports of the
should be the core focus of your assessment EMS
and are described in detail below;
1. Environmental
policy

Every oil and gas company should have an
overarching documented policy that clearly
specifies its environmental objectives and
principles to achieve sound environmental
performance in all its operations.
The company environmental policy should
also incorporate applicable national and
internationals laws and regulations in the
host country.
Where the oil and gas company subscribes
to internationally recognized standards (e.g.
ISO14001) these too should be described in
the environmental policy
Top management should define such an
environmental policy and ensure the policy;
a) Is appropriate to the nature, scale
and environmental impacts of its
activities, products and services
b) Includes a commitment to continue
improvement and prevention of
pollution,
c) Includes a commitment to comply

 Take a look at the Environmental policy
 Crosscheck whether these standards are
described in the policy.
 Cross check for its efficiency and
appropriateness with provisions of ISO
14001; 4.2

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with applicable legal requirements
and with other requirements to
which the organization subscribes,
which relate to its environmental
aspects
d) Provides the framework for setting
and reviewing environmental
objectives and targets.
e) Is documented, implemented and
maintained
f) Communicated to all persons
working for and on behalf of the
organizations
The environmental policy should be
available to the public (see IFC, Performance
Standard 1: Para 6, ISO 14001: 4.2)
2. Identification of
direct and indirect
environmental
risks and impacts
from oil and gas
operations

Direct and indirect (third party) impacts on
ecosystem services should be identified and
assessed; impacts associated with primary
supply chains should be identified as well.

The company is required to establish,
implement and maintain a procedure(s) to
identify the environmental aspects of its
activities, products and services within the
defined scope of the EMS that it can control
and determine those aspects that have or
can have significant impacts on the
environment (IFC, ISO 14001); potential
emergency impacts should also be
identified.

Risks and impact identification should be
based on recent environmental and social
baseline data at appropriate level of detail.
The process of identification of risks and
impacts should be adequate, accurate and

Request to look at copies of a recent
Environmental
Impact
Assessment
reports.
Ask about the procedures in place to
identify the environmental aspects of
company activities, products and services
within the defined scope of the EMS and
as an ongoing process.
Look out for:
 Evidence of pollution of air, water and
soils
 Change in quality of air, water and soils
 Waste management
 Restoration and decommissioning of
drilled sites
 Camouflage of industry infrastructure
 Changes in landscape and aesthetics
 Land degradation, loss of vegetation
 Animal movement and behavior and
disappearance of species
 Wetland degradation or disappearance

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objectively done by competent
professionals.

and shrinking or receding lake, river,
swamps and streams.
 Testimonies from community members
about impact (s)

The identification process will identify
relevant threats to biodiversity and
ecosystem services focusing on habitat loss,
degradation and fragmentation invasive
species, overexploitation, hydrological
changes, nutrient loading, and pollution,
emission of greenhouse gases; potential
trans-boundary effects e.g. air pollution and
pollution of international waterways.
Where the project involves specifically
identified physical elements, aspects, and
facilities that are likely to generate impacts,
environmental and social risks and impacts
will be identified in the context of the
project’s area of influence. This area of
influence encompasses, as appropriate:
The area likely to be affected by: (i) the
project and the client’s activities and
facilities that are directly owned, operated
or managed (including by contractors) and
that are a component of the project; (ii)
impacts from unplanned but predictable
developments caused by the project that
may occur later or at a different location; or
(iii) indirect project impacts on biodiversity
or on ecosystem services upon which
Affected Communities’ livelihoods are
dependent (IFC PS 1:Para 6-8).
Associated facilities, which are facilities that
are not funded as part of the project and
that would not have been constructed or
expanded if the project did not exist and
without which the project would not be
viable.
The company is required to establish,
implement and maintain a procedure(s) to
monitor and measure, on a regular basis,

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the key characteristics of its operations that
can have a significant environmental impact
(ISO 14001).
Cumulative impacts that result from the
incremental impact, on areas or resources
used or directly impacted by the project,
from other existing, planned or reasonably
defined developments at the time the risks
and impacts identification process is
conducted (ISO14001: 4.3.1)

3. Company capacity
and competence
to address
associated
environmental
risks and impacts

Cross-reference this requirement by
referring to relevant national and regional
laws, guidelines and standards (e.g.
Environmental Impact requirements).
The organization should have an established
and
fully
maintained
organizational
structure that defines clear roles,
responsibilities and authority to implement
its Environment Management System.

Kindly describe the organizational
structure responsible for implementing
your environmental management system?

Who has overall and subsidiary
responsibility for the effective
Key
environmental
management implementation of your environmental
responsibilities should be defined and management system?
communicated to relevant personnel and
How many people (permanent and
the rest of the organization.
temporary) are available to implement
Sufficient human and financial resources your environmental management system.
should be provided on an ongoing basis to
achieve
effective
environmental How much is your annual budget for the
implementation of the environmental
performance.
management system?
ISO14001 requires every certified company
to ensure the availability of resources
essential to establish, implement, maintain
and improve the EMS
See: IFC PS 1:6 Para 17-19 and ISO14001
4.4.1-4.4.2
Cross-reference this requirement by
referring to relevant national and regional

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laws, guidelines and standards.
4. Company
management of
environmental
risks and impacts

Every oil and gas company must establish
programmes and performance improvement
measures that effectively address the
identified environmental and social risks of
their operational activities.
These plans shall consist of documented
operational procedures, practices, plans and
related supporting documents (e.g. waste
management plan; oil spill contingence
plans etc).
Such environmental risk and impact
management plans should abide by the
mitigation hierarchy which will favor
avoidance of impacts over minimization and
where residual impacts remain,
compensation/offset where technically and
financially viable.
The mitigation measures chosen should take
into account the outcomes of the
engagement process with affected
communities.
The outcome of environmental risk and
impact management should be Action Plans
which should clearly define desired
outcomes and actions to address the issues
raised in the identification process.
The environmental impact action plan
should be complete with performance
indicators and targets that can be tracked
over defined time periods with estimates for
resources
and
clearly
assigned
responsibilities.
The management plan should also outline

Can I have access to copies of the
environmental risk/impact management
action plans?
How are the responsibilities of the
environmental action plans assigned
within the company?
What impacts have been identified that
can be directly attributable to third-party
(e.g. contractors) stakeholders?
How is the environmental management
action plan adaptable to unforeseen
environmental risks and impacts?

MONITORING
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REQUIREMENT(S)

OBSERVATION CHECK LIST

relevant actions and events controlled by
third-parties.
The Action Plan should be dynamic and be
responsive to changes in circumstances,
unforeseen events and results of monitoring
and review.
IFC: PS 1: Para 13-16
ISO14001. 4.4.6; 4.4.7
Cross-reference this requirement by
referring to relevant national and regional
laws, guidelines and standards.
5. Company
disclosure,
consultation and
participation
engagement of
stakeholders in
environmental
management

Oil and gas companies should have a clear
and ongoing process for stakeholder
engagement including stakeholder analysis,
planning, disclosure and dissemination of
information, consultation, participation,
grievance mechanism and ongoing reporting
to affected communities.
The company should demonstrate that the
aim of its stakeholder (particularly CSOs and
affected communities) engagement process
is to build strong, constructive and
responsive relationships that are essential
for management of environmental risk and
impacts.
Where the stakeholder engagement process
depends substantially on community
representatives, the company should make
every reasonable effort to verify that such
persons do in fact represent the views of the
affected communities.
Disclosure: The oil and gas companies
should disclose relevant information to
affected communities on i) purpose, nature,

Outline the process through which you
identify affected communities to your
operations?
Kindly describe your affected communities
and CSO engagement plans and activities?
Can you please provide a copy of your
stakeholder engagement plan?
How do you ensure that community
representatives in fact represent affected
communities?
Describe your grievance handling
mechanism?
How have you ensured that that your
grievance handling mechanism is well
understood by affected communities,
CSOs and other stakeholders?
Describe to your stakeholder consultation
process?
In what ways do you ensure that such a
process is continuous and is a basis for

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scale of the project ii) duration of proposed
activities iii) any risks to and potential
impacts on communities and relevant
mitigation measures iv) envisaged
stakeholder engagement process and v)
grievance mechanisms

ongoing impact identification and
mitigation?

Consultation: companies must undertake
effective and early consultation as a twoway process that i) begins early during
identification of impacts and risks and
continue as an ongoing basis for further risk
and impact identification ii) is based on prior
disclosure and dissemination of relevant,
transparent, objective, meaningful and
accessible information to affected
communities and CSOs that represent them
iii) is inclusive (women, youth, children,
elderly vulnerable and disadvantaged
groups) iv) be free of external manipulation,
interference, coercion or intimidation v)
enables meaningful participation vi) is
documented.

Can you kindly provide some
documentation of your most recent
stakeholder consultation/participation
activities?

Informed consultation and participation:
for projects with potentially adverse impacts
on affected communities companies must
undertake this kind of consultation. This
involves in-depth exchange of views and
information in an iterative process and
companies should incorporate the views of
affected communities on matters that affect
them directly e.g. sharing of benefits and
opportunities, mitigation of impacts and
sequencing of implementation.
Where government capacity is weak, the oil
and gas companies play an active and
supplementary role to ensure stakeholder
engagement planning, implementation and

How do you ensure that you capture the
views of women, youth, elderly, minorities
and other disadvantaged groups?

How do you ensure and community back
to communities on the extent to which
their views and ideas on impact
management have been incorporated into
your environmental management action
plans?
In what ways have you complimented
government efforts to ensure effective
stakeholder engagement planning,
implementation, review and monitoring?
Kindly describe your current grievance
management mechanism through which
you receive and resolve concerns on your
environmental performance?
Describe how you have ensured that your
grievance mechanism resolve
environmental and social concerns
promptly in an understandable and
transparent consultative process that is
culturally appropriate and readily
accessible?

MONITORING
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REQUIREMENT(S)

OBSERVATION CHECK LIST

monitoring are effective and adequate.
Grievance mechanisms: oil and gas
companies should establish and clearly
communicate an effective grievance
handling mechanism to receive, facilitate
resolution of concerns and grievances about
the clients environmental performance.
The grievance mechanism should resolve
concerns promptly in an understandable and
transparent consultative process that is
culturally appropriate and readily accessible.
The mechanism should not impede access to
judicial or administrative remedies and
should be effectively communicated to
affected communities.
See: IFC PS: 1 Para 25-36 and ISO14001

6. Monitoring,
review of
company EMS

Oil and gas companies should involve
representative of affected communities in
monitoring environmental impact
management activities.

How have you involved representatives of
affected communities in providing
external feedback to your environmental
management activities?

Company should maintain external experts
to verify its monitoring information.

Describe how you are verifying your
environmental monitoring and impact
management system through external
expert feedback processes?

The company should use dynamic
mechanisms such as internal inspections and
How are you applying internal inspections
audits to verify compliance and progress
and audits to verify compliances and
towards desired environmental outcomes.
progress towards desired environmental
outcomes?
Oil and gas companies must collaborate with
government to establish an effective
How are the results of environmental
impact monitoring processes
environmental risk and impact monitoring
communicated to top management?
system.
Companies should document results form
impact/risk monitoring activities and

What are some of the actions top
management takes in relation to these
environmental monitoring results?

MONITORING
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REQUIREMENT(S)

OBSERVATION CHECK LIST

identify and reflect necessary corrective and
preventative actions in the updated
management programmes and plans.

Other things to look out for;


Top management is required to review the
company’s EMS at planned intervals to
ensure its continuing suitability, adequacy
and effectiveness ISO 14001, 4.4.3), IFC
Standard 1, Para 22- 24







7. Compliance with
environmental
principles and
safeguards
prescribed by
your national
environmental
law.

CSOs applying this tool should check and
summarize here the requirements of the
relevant national environmental laws and
guidance with respect to environmental
management, restoration, forest
conservation laws, protection of wetlands,
species management plans, Environment
Impact Assessment (EIA) guidelines etc.




8. Pollution
management of
waste arising
from oil and gas
development
activity

CSOs applying this tool should check and
summarize here the requirements of the
relevant national, regional and international
laws, guidelines and standards on pollution
management of relevance to the oil and gas
sector. These should be summarized here as
guidance notes.







9. Protection of the
environment,
conservation of
biodiversity and
maintenance of
ecosystem
services

Companies should apply the impact
mitigation hierarchy which should seek to
avoid all impacts, where this fails should
minimize impacts where this fails should,
rehabilitate and restore biodiversity and
ecosystem services.
Companies must ensure there is no
conversion of natural habitats unless there







Evidence of meetings with a
variety of stakeholders
Meeting minutes about EMS
Reports of workshop on EMS
Community voices
Biodiversity study reports
Films and videos of monitoring
exercises

IEC materials
Evidence of meetings with a
variety of stakeholders
Meeting minutes about EMS
Reports of workshop on EMS
Community voices
Biodiversity study reports
Films and videos of monitoring
exercises

Waste bins
Waste management plans
Budgets for waste management
Existence of human resource
An independent contractor in
place

Describe how you are applying the
mitigation hierarchy?
Describe how you are safeguarding critical
habitats and species through a long-term
biodiversity conservation programme?
Describe how you are promoting and
enhancing the long-term conservation
aims and effective protected area
management for protected areas in or

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are no alternatives– there should be no-netloss3 of biodiversity and preferably a netgain to biodiversity

near your operation areas?

Protection of biodiversity and ecosystem
services for modified habitats, natural
habitats and critical habitats (e.g. Ramsar
sites) requires a long-term biodiversity
monitoring and evaluation programme.

What priority ecosystem services have
your identified will required special
attention for management during your
operations?
Describe measures you plan to undertake
to safeguard such ecosystem services?

How do you ensure that affected
In legally protected areas the oil and gas
communities are involved in identifying
companies must demonstrate that their
priority ecosystem services?
activities are legally permitted; consistent
Check also:
with government management plans for
such protected areas, consult protected area
 Biodiversity plans
managers, affected communities and other
 Budgets for biodiversity
stakeholders; and are undertaking
conservation
programmes to promote and enhance long Biodiversity study reports
term conservation aims and effective area
 Restored sites
management
 Systematic review reports
 Reports of stakeholder involvement
IFC: Performance Standard 6 (Para 9-23)
Ecosystem services: Where a project is likely
to adversely impact ecosystem services as
determined by the risks and impact
identification process, the Company will
conduct a systematic review to identify
priority ecosystem services
Priority ecosystem services include i) those
services which if affected will result in
adverse impacts on local communities; ii)
those services which company operations
depend upon.
For services (e.g. climate moderation) upon
which local communities depend; the
3

No net-loss is defined as the point at which project related impacts on biodiversity are balanced by measures
taken to avoid and minimise the project’s impacts, to undertake onsite restoration and finally offset significant
residual impacts if any on an appropriate geographic scale.

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REQUIREMENT(S)

companies must make effort to avoid
adverse impacts. Communities should also
be involved in determining priority
ecosystem services as part of the
stakeholder engagement process.
For services upon which operations depend;
companies should avoid and minimize
impacts as well as ensure resource efficiency
* CSOs applying this tool should enrich this
section by cross-reference with their
national wildlife protection laws and
regulations.

OBSERVATION CHECK LIST

ATTACHMENT 1: ENVIRONMENTAL PERFORMANCE MONITORING TOOL –
SCORE SHEET
Aim: This score-card aims to establish to what extent any given oil and gas company is committed and
taking actions that are aimed at protecting, conserving, maintaining biodiversity and vital ecosystems
and sustainably managing living natural resources during its oil and gas development activities within its
area of operation. Such actions are either directly by the company itself or through its contractors.
Score guide:
1
2
3
4
5

MONITORING
ELEMENT

Environmental
Management
System (EMS)

Very Poor
Poor
Good
Very good
Exemplary

OBSERVATION CHECK LIST

Request to look at a copy – if the
Environmental Management
system is documented.
Cross check on company
websites for Environmental
Management System/Plans
information
Observe different components of
the system in practice;-for
example the policy statement
may be pinned in office.
Take an initiative of ascertaining
whether other members of staff,
stakeholders etc know about the
Environmental Management
system and how often
stakeholders may be involved
Request for monitoring reports
of the EMS

1. Company

Request to take a look at the

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

environmental
policy

OBSERVATION CHECK LIST

company environmental policy
Does the policy integrate national
and International environmental
best practices and standards
Is the company committed to
continuous improvement and
prevention of pollution
Does the company communicate
the policy to all persons working
for and on behalf of the company
Does the company conduct policy
reviews on environmental
objectives and targets?

2. Identification of
direct and indirect
environmental
risks and impacts
from oil and gas
operations

Request to look at copies of a
recent Environmental Impact
Assessment reports.
Are
Environment
Impact
Assessments
available and
accessible to the public?
Does the company have
competent
staff
and
professionals to continuously
identify environmental risks and
impacts?
Ask about the procedures in
place
to
identify
the
environmental
aspects
of
company activities, products
and services within the defined
scope of the EMS and as an
ongoing process.
Look out for:

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

OBSERVATION CHECK LIST

 Evidence of pollution of air,
water and soils
 Change in quality of air, water
and soils
 Waste management
 Restoration and
decommissioning of drilled
sites
 Camouflage of industry
infrastructure
 Changes in landscape and
aesthetics
 Land degradation, loss of
vegetation
 Animal movement and
behavior and disappearance
of species
 Wetland degradation or
disappearance and shrinking
or receding lake, river,
swamps and streams.
 Testimonies from community
members about impact (s)

3. Environmental
risk and impact
management

Does the company have
procedure(s) to monitor and
measure, on a regular basis, the
key characteristics of its
operations that can have a
significant environmental
impacts?
Can I have access to copies of
the environmental risk/impact
management action plans?
How are the responsibilities of
the environmental action plans
assigned within the company?
What impacts have been
identified that can be directly

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

OBSERVATION CHECK LIST

attributable to third-party (e.g.
contractors) stakeholders?
How is the environmental
management action plan
adaptable to unforeseen
(emergency) environmental
risks and impacts?

4. Company capacity
and competence
to address
associated
environmental
risks and impacts

Kindly describe the
organizational structure
responsible for implementing
your environmental
management system?
Who has overall and subsidiary
responsibility for the effective
implementation of your
environmental management
system?
How many people (permanent
and temporary) are available to
implement your environmental
management system?
How much is your annual
budget for the implementation
of the environmental
management system?
Does the company have the
requisite infrastructure and
equipment for managing
environmental risks and
impacts?
What plans are in place to
ensure ongoing capacity
development of environmental

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

OBSERVATION CHECK LIST

management staff?
5. Company
disclosure,
consultation and
participation
engagement of
stakeholders in
environmental
management

Outline the process through
which you identify affected
communities to your
operations?
Kindly describe your affected
communities and CSO
engagement plans and
activities?
Can you please provide a copy
of your stakeholder engagement
plan?
How do you ensure that
community representatives in
fact represent affected
communities?
Describe your grievance
handling mechanism?
How have you ensured that that
your grievance handling
mechanism is well understood
by affected communities, CSOs
and other stakeholders?
Describe to your stakeholder
consultation process?
In what ways do you ensure that
such a process is continuous and
is a basis for ongoing impact
identification and mitigation?
How do you ensure that you
capture the views of women,
youth, elderly, minorities and

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

OBSERVATION CHECK LIST

other disadvantaged groups?
Can you kindly provide some
documentation of your most
recent stakeholder
consultation/participation
activities?
How do you ensure and
community back to communities
on the extent to which their
views and ideas on impact
management have been
incorporated into your
environmental management
action plans?
In what ways have you
complimented government
efforts to ensure effective
stakeholder engagement
planning, implementation,
review and monitoring?
Kindly describe your current
grievance management
mechanism through which you
receive and resolve concerns on
your environmental
performance?
Describe how you have ensured
that your grievance mechanism
resolve environmental and
social concerns promptly in an
understandable and transparent
consultative process that is
culturally appropriate and
readily accessible?

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

OBSERVATION CHECK LIST

6. Monitoring,
review of
company EMS

How have you involved
representatives of affected
communities in providing
external feedback to your
environmental management
activities?
Describe how you are verifying
your environmental monitoring
and impact management system
through external expert
feedback processes?
How are you applying internal
inspections and audits to verify
compliances and progress
towards desired environmental
outcomes?
How are the results of
environmental impact
monitoring processes
communicated to top
management?
What are some of the actions
top management takes in
relation to these environmental
monitoring results?
Other things to look out for;







Evidence of meetings
with a variety of
stakeholders
Meeting minutes about
EMS
Reports of workshop on
EMS
Community voices
Biodiversity study
reports
Films and videos of
monitoring exercises

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

OBSERVATION CHECK LIST

7. Compliance with
environmental
principles and
safeguards
prescribed by
your national
environmental
law.

CSOs applying this tool should
check and summarize here the
requirements of the relevant
national environmental laws
and guidance with respect to
environmental management,
restoration, forest conservation
laws, protection of wetlands,
species management plans,
Environment Impact
Assessment (EIA) guidelines etc.

Score
(1-5)

Evidence/justification for the score









Other things to consider:
 IEC materials
 Evidence of meetings
with a variety of
stakeholders
 Meeting minutes about
EMS
 Reports of workshop on
EMS
 Community voices
 Biodiversity study
reports
 Films and videos of
monitoring exercises

8. Pollution
management of
waste arising
from oil and gas
development
activity

CSOs applying this tool should
check and summarize here the
requirements of the relevant
national, regional and
international laws, guidelines
and standards on pollution
management of relevance to
the oil and gas sector. These
should be summarized here as
guidance notes.




Waste bins
Waste management
plans
Budgets for waste

MONITORING
ELEMENT

OBSERVATION CHECK LIST

management
Existence of human
resource
 An independent
contractor in place
Describe how you are applying
the mitigation hierarchy?


9. Protection of the
environment,
conservation of
biodiversity and
maintenance of
ecosystem
services

Describe how you are
safeguarding critical habitats
and species through a long-term
biodiversity conservation
programme?
Describe how you are promoting
and enhancing the long-term
conservation aims and effective
protected area management for
protected areas in or near your
operation areas?
What priority ecosystem
services have your identified will
required special attention for
management during your
operations?
Describe measures you plan to
undertake to safeguard such
ecosystem services?
How do you ensure that
affected communities are
involved in identifying priority
ecosystem services?
Check also:






Biodiversity plans
Budgets for biodiversity
conservation
Biodiversity study reports
Restored sites
Systematic review reports

Score
(1-5)

Evidence/justification for the score

MONITORING
ELEMENT

OBSERVATION CHECK LIST



Score
(1-5)

Evidence/justification for the score

Reports of stakeholder
involvement.

* CSOs applying this tool should
enrich this section by crossreference with their national
wildlife protection laws and
regulations.

REFERENCES:
1. IFC, 2012. Performance Standards on Environmental and Social Sustainability, IFC
Washington DC.
2. ISO 14001, 2004. Environmental Management systems – requirements with guidance
for use, Geneva, Switzerland.
3. UNEP, 1997. Environmental management in oil and gas exploration and production.
UNEP and the Oil Industry International Exploration and Production Forum. Nairobi,
Kenya.