What Norway's Ethics Council told VedantaPublished by MAC on 2017-03-10
Source: NPF Council on Ethics (2017-03-10)
Multiple accusations to which the UK company has not replied
The following letter was sent by Norway's Council on Ethics to Vedanta Resources plc in May 2016, justifying its refusal to re-include the company in the government's Pension Fund portfolio. It concludes:
"[T]here continues to be an unacceptable risk that your company will cause or contribute to severe environmental damage and serious or systematic human rights violations".
The company has not replied to any of the allegations made.
See also: Norwegian Government Pension Fund updates banned companies list (10/03/2017)
From the Council on Ethics, Government Pension Fund Global
To: Tom Albanese, CEO
Vedanta Resources plc
16 Berkeley Stree
Oslo, 27 May 2016
Concerning the Council on Ethics' reassessment of Vedanta Resources
Dear Mr. Albanese,
We make reference to previous communication with your company including Vedanta's letters to the Council dated 11 February 2015 and 11 February 2016.
The Council has carefully reviewed the information Vedanta has provided. The Council has considered your views regarding our 2007 recommendation, but has also looked into developments at Vedanta's subsidiaries from 2007 until the present. The Council has assessed Sterlite Copper, Bharat Aluminium Company, Lanjigarh Alumina and Konkola Copper Mines.
Following its assessment, the Council has decided not to recommend the re-inclusion of Vedanta in the Government Pension Fund Global’s investment universe. In the Council’s view there continues to be an unacceptable risk that your company will cause or contribute to severe environmental damage and serious or systematic human rights violations.
Please find attached the Council’s assessment.
Johan H. Andresen
Chair of the Council on Ethics
CC: Radhika Arora, Investor Relations and Rahul Matta, Sustainable
Development and Communications
Enclosures: The Council on Ethics' assessment of Vedanta Resources plc.,
27 May 2016
The Council on Ethics’ assessment of Vedanta Resources plc. 27 May 2016 Vedanta Resources plc (Vedanta) and its listed subsidiaries Sterlite Industries Ltd (Sterlite) and Madras Aluminium Company Ltd (Malco) were excluded from the Norwegian Government Pension Fund Global in 2007, following a recommendation from the Council on Ethics. The Council examined four of Vedanta’s subsidiaries in India: Sterlite Industries, Madras Aluminium Company, Bharat Aluminium Company and Vedanta Alumina, and found that the companies were responsible for or contributed to severe environmental damage or systematic human rights violations.
Since 2007, Vedanta has restructured. Sterlite Industries, Sesa Goa, Vedanta Aluminium (VAL) and Malco (which was delisted in 2009) were merged into a new company, Sesa Sterlite Ltd. In 2013, the Council recommended the exclusion of Sesa Sterlite, as the merger did not change the companies’ operations, and the recommendation of 2007 continued to apply. Sesa Sterlite has now been renamed Vedanta Ltd.
In this reassessment of Vedanta, the Council has focused on four of Vedanta’s subsidiaries - Sterlite Copper, Bharat Aluminium Company, Lanjigarh Alumina, all operating in India, and Konkola Copper Mines, which is located in Zambia. The review is based on information that Vedanta has made available to the Council, as well as the Council's own research. The Council has based its assessment on developments from 2007 until the present.
Sterlite Copper -Tuticorin
In its recommendation of 2007, the Council focused on Vedanta's approach to production expansions, the disposal of hazardous waste, the contamination of ground water, green belt issues, repeated breaches of government regulations and requirements, as well as the likely environmental and health impacts on people living in the area.
Vedanta has provided extensive information on the operations at Tuticorin, regarding both investments in pollution abatement and waste disposal, and claims to have “obtained all valid consents, clearances & approvals from statutory bodies [ ] since inception and till date and is operating under consented capacities”.1 In this regard, the Council notes that in 2010 the Madras High Court ordered the closure of Sterlite Copper on environmental grounds, including excessive pollution, poor waste disposal, inadequate green belt development and violations of the Pollution Control Board's directives under the Consent to Operate. The Supreme Court stayed the decision, but ordered a third-party inspection of pollution at the plant and an assessment of whether operations were in compliance with environmental requirements.
Following this investigation, the Supreme Court directed the Tamil Nadu Pollution Control Board (TNPCB) in 2011 to impose mitigation measures on Sterlite Copper. As stated in your letter, the TNPCB issued 30 directives (improvement measures) to Sterlite Copper and prescribed a timeline for their implementation. Vedanta has informed the Council that Sterlite Copper is now in compliance with all the directives. Nevertheless, the Council notes that the Supreme Court's final decision in 2013 not to close the operation was accompanied by a significant penalty imposed on Sterlite Copper for extensive environmental degradation between 997 and 2012, and for not being in compliance with government requirements. The judges stated:
“Considering the magnitude, capacity and prosperity of the appellant company, we are of the view that it should be held liable for a compensation of Rs 100 crore for having polluted the environment in the vicinity of its plant and for having operated the plant without a renewal of the consents by the Tamil Nadu Pollution Control Board for a fairly long period and according to us, any less amount, would not have the desired deterrent effect on the company.”2
Your statement that all consents have been in place from the start-up of operations conflicts with the court's judgement.
The Council notes that Vedanta has taken steps to improve the environmental performance of Sterlite Copper by investing in a number of pollution abatement and waste disposal facilities, particularly following the Supreme Court's ruling in 2011. The Council finds that the company's investments are likely to have reduced some of the pollution from the operations. However, there are still issues of concern, outlined as follows:
- In 2008, Sterlite Copper commissioned an epidemiological study covering all villages within a 5 km radius of the plant. In your letter to the Council, you state that: “The study has not found any ill effects due to operations of the plant.” However, the report also describes more incidences of respiratory disorders and skin ailments in the population living around the factory site compared with a similar population living further away.
This seems not to have been investigated further, which may undermine the credibility of the report.
- In the latest inspection report, carried out by National Environmental Engineering Research Institute (NEERI) in 2011, it is stated that: “The total land under possession of M/s SIIL [Sterlite Copper] from SIPCOT as per the industry management is 102.5 ha as against 172.17 ha.”3 In the excerpts of the report that you have provided to the Council, this page is missing. The environmental clearance for the expansion of production capacity at Sterlite Copper appears to have been based on a plant area of 172.17 ha. Considering that only 60 percent of this area is available, it is not clear to the Council whether there has actually been sufficient room to implement the required pollution control measures.
- The Council notes that in the same NEERI report it is pointed out that at some locations the green belt is fragmented, that the single-line plantations stretching for a total of 2.5 km were not considered to constitute a green belt, and that the green belt only covered 12.1 per cent of the area, compared with the required 25 per cent. Also these pages of the report are missing in the information you have provided. Although Vedanta states that it has now complied with the requirement, it is not clear to the Council whether there is sufficient room for plantation development, considering that there is significantly less land available at the site.
- A claim against Sterlite has been filed in the Madras High Court, alleging that Sterlite Copper has been dumping slag in low-lying areas and water bodies on local people’s land. This practice seems to be ongoing.
- Google Earth Images from 2016 show that large volumes of gypsum are stored in the gypsum pond, contrary to Vedanta’s claims that the pond is empty.
Local sources contacted by the Council have confirmed that disposal facilities are full.
Bharat Aluminium Company (Balco)
The Council based its assessment of the Balco’s Bodai Daldali bauxite mining operations on the forced relocation of tribal people in Kawardha between 2005 and 2007, and the inadequate or lack of compensation offered to those affected by the mining operation.
Resettlement and compensation
Vedanta disagrees with the Council's assessment with regard to the number of families and individuals affected, the amount of compensation paid and the fact that the relocation was forced. Vedanta states that Balco’s land compensation rate was Rs 1 lakh per acre ( USD 1,650 per acre) while the existing market rate was Rs 30,000 – Rs 50,000 per acre (USD 490–830 per acre). Vedanta also writes that it practices “voluntary shifting of displaced family at place of their choice, therefore the resettlement villages have been made at place of their choice only, and accordingly the house land and agricultural land of villagers have been taken in possession by Balco only with consent of the displaced family”.
In the Council’s view, this does not seem to be the full picture. After a visit to the mine in 2009, the Expert Appraisal Committee (EAC) of India’s Ministry of Environment and Forests (MoEF) confirmed that Vedanta/Balco was obliged to ensure proper relocation and resettlement of 261 affected families in four villages at Bodai-Daldali.
The EAC stated that by April 2009 only 72 families had been moved to four relocation sites; 189 families had yet to be resettled, and the rehabilitation of the 261 families had still to be completed. In the EAC’s view, progress in the resettlement of the families to be displaced was far from satisfactory. Many families did not have verifiable land titles, as a consequence of which Vedanta/Balco refused to compensate them for their loss. The EAC commented that it was “sheer coincidence that the issue has become relevant and known to the EAC while considering the proposal for expansion”.4 The Council is aware that in April 2010 the EAC permitted the expansion for a period of five years. There is no information as to why the EAC exempted the huge expansion project from any public hearing.5
According to Vedanta’s GRI Disclosure Document FY 2014-15, none of the company’s active mines are operating in or adjacent to indigenous people’s territory. However, to the Council’s knowledge, the Baigha is one of India's notified Scheduled Tribes and has the right under Indian law to give Free, Prior and Informed Consent (FPIC) to a project as large as the Bodai Daldali mine.6 The lack of public hearing means that the Baigha as a community may not have been given an opportunity to express its concerns about the project prior to a period of a huge expansion, which seems to be in conflict with Vedanta’s own policies on consultation and community development.
The chimney collapse at Korba
The chimney collapse at Balco's Korba site in Chhattisgarh on 24 September 2009 has been widely reported. The chimney was under construction and had reached a height of 240 metres when it collapsed on top of more than 100 workers, who had sought shelter from a thunderstorm. The judicial Commission of Inquiry into the causes of the disaster stated in its report of 2012: “Compliance with all the statutory requirements for the construction of the chimney was the responsibility of BALCO and the responsibility of determining the safety measures was also that of BALCO, because BALCO was the owner of the Project.” 7
Vedanta has previously communicated to the Council that the Chimney collapse was found to be a meteorological phenomenon not related to design flaw of chimney design.8 This is not consistent with the Commission’s findings. Vedanta has also informed the Council that it obtained an injunction from the Chhattisgarh High Court prohibiting the publication of the Commission’s report, on the grounds that Balco had not been afforded a sufficient right of reply to its allegations.
In the Council’s view, it is peculiar that what appears to be the only action Vedanta has taken in response to the accident is to hinder the publication of the inquiry report. To the Council’s knowledge, Vedanta has not addressed the report’s findings. The Council has not seen any information showing that the company has reviewed its health and safety procedures to prevent future accidents.
Vedanta has provided the Council with information relating exclusively to positive developments. It is striking that in the 2010 audit of Vedanta's operations and policies, conducted by the British consultancy Scott Wilson (later URS), there is only a brief mention of the collapse, where at least 40 workers died. The URS review of “Vedanta's Sustainability Policies and Practices for the Lanjigarh Refinery of 17 November 2010” recorded that, in 2009, the company had received an award from the British Safety Council (BSC).9 The Council finds it pertinent to add that in August 2010, the BSC withdrew two awards previously made to Vedanta, due to the substantial number of fatalities and casualties at Korba the previous year.10
Poor working conditions at Balco's mines
The Council is aware that the extraction of bauxite ore at Balco’s Bodai Daldali mine is to a large degree carried out manually by contract workers engaged for one day at a time. Reportedly, these workers splinter rocks with sledgehammers, gather the pieces bare-handed in kitchen bowls, which they carry on their heads to waiting lorries. No protective gear seems to be provided.11 The working conditions at the mine have recently been documented in video footage and articles by journalists who visited the mine in February 2016. These labour practices hardly correspond to Vedanta’s own human rights policy, which states that the company will strive to “ensure the health, safety and well-being of all workers”, and “minimise risks associated with occupational hazards and prevent injury and ill health to contractor employees working on Vedanta sites”.
In addition, other requirements imposed by the government on the company – such as dust control, the provision of safe drinking water, medical care facilities for workers and the reclamation and replanting of mined-out areas – seem not to be complied with.12
The recommendation addressed the environmental impacts associated with the planned mining operations in the Niyamgiri Hills and the refinery at Lanjigarh, as well as violation of the human rights of tribal people in the area.
In January 2014, the Indian government denied permission for Vedanta to prospect and mine the Nyamgiri Hills on the grounds that, inter alia, the Dongria and Kutia Khond communities had unanimously voted against it at their gram sabhas (village meetings).13 In the Council’s 2007 recommendation, the impact that the mining operations would have on the tribal communities was considered a serious human rights violation.
In its letter to the Council, Vedanta states that it has entered into a MoU with the Government of Odisha, “which assures supply of 150 mill tonnes of bauxite for our processing facility, we are working with the State Government and pursuing alternate options for our long term bauxite security”. In February 2016, it was reported that the Government of Odisha had “petitioned the Supreme Court for holding a fresh Gram Sabha in the Niyamgiri area, an earlier attempt to get the nod of the village body was unsuccessful”. Odisha’s steel and mines minister said: “We have urged the Apex Court to allow the State-owned Odisha Mining Corporation to undertake mining at Niyamgiri hills.”14 The Council considers that should it source bauxite from the Niyamgiri Hills, Vedanta could still be complicit in human rights violations perpetrated by its business partner.
Media reports state that the Orissa state government has now directed its mining corporation, OMC, to start mining bauxite at Karlapat, which is also in the Kalahandi district, reportedly to provide bauxite to Vedanta’s refinery.15 The Council notes that tribal organisations have strongly opposed the Karlaplat project because it would be detrimental to the environment and tribal livelihoods, and as such appears to be similar to Niyamgiri. To the Council’s knowledge, Vedanta seems so far not to have engaged with local communities in this case.
The Lanjigarh refinery expansion
In 2007, Vedanta submitted an application to the Ministry of Environment and Forests (MoEF) for the expansion of the Lanjigarh refinery from 1 to 5 million tonnes per annum of Alumina, and for an increase in power generation from 75 to 300 MW.16 The Council notes that accusations of illegal activity, violations of environmental regulations and human rights abuses are still being voiced against the company.
Vedanta has provided a timeline of major events concerning the setting up the Alumina refinery at Lanjigahr. In this, Vedanta makes reference to the committee that was set up in 2009 to review the mining plan, but not to the conclusions of its report, one of which is cited below:17
“The Vedanta Company has consistently violated the Forest Conservation Act, the Forest Rights Act, the Environment Protection Act and the Orissa Forest Act in active collusion with the State officials. Perhaps the most blatant example of it is their act of illegally enclosing and occupying at least 26.123 ha of Village Forest Lands within its refinery depriving tribal, dalits and other rural poor of their rights. In view of the above this Committee is of the firm view that allowing mining in the proposed mining lease area by depriving two Primitive Tribal Groups of their rights over the proposed mining site in order to benefit a private company would shake the faith of tribal people in the laws of the land which may have serious consequences for the security and well being of the entire country.”18
Likewise, in the timeline provided, there is no mention that the MoEF decided not to permit mining in 2011. Vedanta challenged this decision in court, but the Orissa High Court backed the MoEF's ruling against the refinery and required Vedanta to start a new the process for environmental clearance. The court recorded that: “By the company’s admission it was evident that nearly half the work on the refinery had been completed even before it got the requisite clearance, which is in violation of the law.”19
In July 2014, Vedanta again applied for environmental clearance for the expansion of the refinery. The expansion will require an increase in the supply of bauxite from 3 to 15 million tonnes per year.
Vedanta misrepresents the outcome of a mandatory public hearing on the expansion of the refinery which took place on 30 July 2014. Vedanta claims that the “majority of the people have supported the expansion project in the interest of local area as well as community”. To the Council’s knowledge, the meeting was disrupted by Dongariya Kondh villagers who questioned the purpose of holding the meeting in the absence of locals, and there was a strong opposition to the refinery expansion voiced by Kondh people at the hearing, which had to be abandoned midway through.20
The Council is aware that Amnesty International has published three reports on Vedanta’s operations at Lanjigahr, in 2010, 2011 and 2012, alleging that Vedanta is responsible for numerous violations of environmental laws and regulations, as well as human rights abuses against indigenous inhabitants.21
Amnesty carried out four field visits from 2010-2012 to gather information on Vedanta's environmental and human rights practices. Vedanta responded in 2011 by issuing the report: “The Lanjigarh development story: Vedanta’s perspective”, but seems not to have replied publicly to Amnesty's 2012 report.
In Vedanta's account, there is no mention of the investigation carried out by India’s National Human Rights Commission (NHRC) into human rights violations associated with Vedanta's operations in Lanjigahr. The NHRC report was issued in 2010 and shows that the NHRC was concerned about the forced displacement of families and lack of proper compensation. In all, 276 families have lost 100 per cent of their farmland to the company, but only 9 have been treated as displaced families (and thus entitled to rehabilitation under Vedanta's scheme). The remaining families have been given a cash grant but no alternative means of livelihood. The commission recommended that the government monitor the rehabilitation of the families affected by the project. Contrary to what Vedanta claims, the NHRC states that people affected by the project have been protesting against the acquisition of their land at village meetings (gram sabhas). “The company has chosen to suppress dissent through inducement of local police. Protestors have been booked in false cases including dacoities. The police have forced them to sign agreements with the company, undertaking to vacate their land and houses at the company’s terms, under duress.”
Excessive pollution from the refinery is also reported. The report recommends a number of actions to the government, including an expert group to monitor the impact of pollution on the health of local communities.22 To the Council's knowledge, the government has not responded to the report. In its meeting on 18 February 2016, the Commission directed the Chief Secretary of the government of Orissa “to look into the allegations made in the complaints and to send a report within four weeks including status of the rehabilitation and resettlement of the victims/displaced persons at the plant”.23
In the Council's view, it appears that the situation at the refinery with regard to human rights violations and environmental hazards does not seem to have improved significantly since 2007.
In light of the proposed expansion of the refinery, which will require Vedanta to acquire additional areas for red mud disposal, ash disposal, green belt and buildings, there is a serious
risk that these violations will continue.
Konkola Copper Mines (KCM)
The Council did not assess KCM in 2007, but finds it pertinent to include KCM now.
Since 2006, a number of serious discharges have been identified at the Nchanga mining complex. They are alleged to be ongoing, occur frequently and result in contaminated water with very low pH levels and quantities of toxic substances (including Cu, Fe, Co, Mn and sulphates). These spills are alleged to be caused by systematic failings in equipment, maintenance, monitoring and operations at the Nchanga copper mine.
In 2011, the High Court upheld a claim brought by 2000 residents from Chingola against KCM for polluting the town’s piped water supply. Pointing to a number of serious failures in KCM’s operations, the court found KCM guilty of water pollution. The court further declared that KCM had shown “gross recklessness” and that KCM “must bear moral, criminal and civil liability” in respect of the pollution it had caused.24 The verdict was upheld in the Supreme Court in 2015, although compensation to villagers was reduced. The Council is aware that the law firm Leigh Day has taken legal action on behalf of 1,826 Zambian villagers against UK-based Vedanta Resources plc and KCM. The claimants are seeking compensation for the loss of and damage to their land and for health problems resulting from the pollution. They are also seeking remediation of the land and the provision of clean water.25 The Council notes that Vedanta has challenged the villagers’ right to pursue their claims in Britain, saying that the case against them should be heard in Zambia.26
In 2014, the Auditor General of Zambia investigated the “management of environmental degradation caused by mining activities in Zambia”, including the Nchanga and Nkana operations at KCM’s Konkola mine. The report is based on the KCM’s own monitoring reports from 2009-2011, which show levels of Cu, Fe and TSS consistently in excess of requirements throughout the year for some of the monitoring points. For some substances, e.g. copper, levels were 100-200 times higher than the limits set by the authorities. The highest discharges were from the pollution control dam, which appeared to be overflowing.
All the discharges monitored flowed into local streams. The auditor also found that silt from a number of overburden dumps at the Nchanga mine had the potential to pollute local streams and ultimately the Kafue River. The Council has requested updated monitoring reports from Vedanta, but these have not been provided.
Vedanta states that it has implemented a number of mitigation measures. Most of these, however, seem either to have been installed before 2011 or they are not adequate to reduce pollution levels.
The Council's assessment
Vedanta has provided the Council with information on its sustainability policies, its reporting practices and the external reviews of its policies and practices carried out by third parties. It has also submitted comments to the Council’s recommendation of 2007. In addition, the Council has requested further information from Vedanta, including on the mining operations at KCM.
The Council notes that controversies surrounding the company’s operations do not seem to have diminished since 2007. Allegations of human rights violations and environmental damage continue to be voiced by local communities affected by its operations. The results of investigations that various authorities have conducted to clarify these issues, give cause for
Human rights violations associated with relocation of local communities appear to be ongoing at Lanjigarh, as the NHRC, among others, has observed. It is disturbing that local police forces still appear to be acting in the company’s interest in silencing protests. Harassment and intimidation of local communities by police forces acting on behalf of Vedanta was investigated by the Central Empowered Committee in 2005, and included in the Council’s 2007 recommendation. It seems that Vedanta has done little to prevent such human rights violations.
Likewise, forced displacement and inadequate compensation still appears to be an issue at Lanjigarh and possibly also at Balco’s operations. One cause of the conflict seems to be related to Vedanta’s practice of distinguishing between families with and without land titles. Affected families without land titles appear to receive less compensation, although they may be equally affected by the company’s operations. Although this may not be unlawful, it causes serious harm to vulnerable groups who have no alternative sources of income, and is not consistent with Vedanta’s assurance that it makes every effort to minimise and mitigate the impact of unavoidable resettlement.
Breaches of workers’ entitlement to safe working conditions appear to be ongoing at Balco’s mine. Apart from the serious safety shortcomings which the commission of inquiry found after the fatal collapse of a chimney that was under construction, there still seems to be significant potential for the company to improve working conditions at its operation.
Certain pollution aspects at Sterlite have probably improved as a result of specific government directives. Nevertheless, a number of issues are yet to be resolved. Furthermore, the Council finds it substantiated that the pollution at KCM is ongoing, with long-term impacts that are detrimental to local people’s health and livelihoods. The Council has not researched environmental impacts associated with other subsidiaries, but notes that the NHRC recommended an investigation of the pollution from the refinery at Lanjigarh.
The violations of laws and procedures by Vedanta’s subsidiaries were important elements in the Council’s 2007 recommendation. In preparing this assessment, the Council has also found numerous reports of Vedanta’s failure to comply with government requirements. This applies to all four subsidiaries investigated.
In recent years, Vedanta has developed “a sustainability framework which covers all aspects of sustainability – Occupational Health and Safety, New Projects, Human Rights, Land Resettlement, Energy & Carbon, Training & Leadership Development, Community Engagement, etc”. Vedanta has upgraded management systems to implement the framework, policies and reporting procedures, and has initiated third-party reviews (External Sustainability Assurance) of its policies and their implementation at its subsidiaries. To a large extent, the audits find that the subsidiaries have implemented Vedanta’s framework and policies in a satisfactory way.
This conclusion does not correspond to the Council’s findings and assessment. The Council finds that the company is selective when informing about its activities. It is difficult to understand that neither the pollution at the Konkola Mines, the social conflicts and NHCR’s investigation into human rights violations and the opposition to the expansion of the refinery at Lanjigarh, nor the chimney collapse are mentioned in the audits. This weakens the credibility of the audits and the sustainability framework. In the Council’s view there is a significant gap between Vedanta’s policies and its actions on the ground.
The Council concludes that the basis for excluding Vedanta from investment by the Norwegian Government Pension Fund Global is still present, as there continues to be an unacceptable risk of the company causing or contributing to severe environmental damage and serious or systematic human rights violations.
3 NEERI 2011: Inspection of M/s Sterlite (India) Ltd., Thoothukudi – Assessment of Environmental Pollution Status. Hon'ble Supreme Court of India, p.106. (Hereafter referred to as NEERI 2011).
4 In early 2007, Vedanta/Balco applied to the Indian Ministry of Environment and Forests (MoEF) for permission to expand its Bodai-Daldali operations no less than five-fold.
7 The Bakshi Judicial Inquiry Report Into The Korba Chimney Disaster Of 23 September 2009, http://www.minesandcommunities.org/files/2014/Bakshi%20Report%20on%20Korba%20disaster.pdf
8 Telephone call with representatives from Vedanta 14 October 2014.
9 Scott Wilson 2010: Vedanta Resources PLC and Lanjigarh Refinery. Independent Review of Sustainability Policies and Practices, Summary report, 17 November 2010, p. 18,
12 http://www.minesandcommunities.org/article.php?a=13331 and Balco report on compliance submitted to the Ministry of Environment and Forests in November 2012.
16 Vedanta’s Annual report of 2015 states 4 Mt., http://www.vedantaresources.com/media/177388/22883_vedanta_ar2015_final.pdf
17 Saxena, et.al.: Report of the four-member committee for investigation into the proposal submitted by the Orissa mining company for bauxite mining in Niyamgiri. 16 August 2010, p. 9, http://envfor.nic.in/sites/default/files/Saxena_Vedanta-1.pdf
18 See footnote 17
19 TerraGreen, 30 January 2012, cited in the EIRIS 2012 “Update Two years on: Review of progress by Vedanta Resources on EIRIS’ ESG recommendations”, commissioned by Aviva Investors, p. 6, http://www.eiris.org/publications/
20 Caravan Magazine, 10 August 2014, reprinted at: http://www.minesandcommunities.org/article.php?a=12739 This video can be
viewed at: https://www.youtube.com/watch?v=MsSGBnNmM-U
21 Amnesty International, 2010: Don't mine us out of existence, https://www.amnesty.nl/sites/default/files/public/rap_india_dont_mine_us_out_of_existence.pdf Amnesty International, 2011: Generalisations, omissions, assumptions: the failings of Vedanta’s Environmental Impact Assessments for its bauxite mine and alumina refinery in India’s state of Orissa, https://www.amnesty.nl/sites/default/files/public/asa200362011en.pdf Amnesty International, 2012: Briefing: Vedanta’s perspective uncovered. Policies cannot mask practices in Orissa, https://www.amnesty.org.uk/sites/default/files/vedanta2.pdf
22 Letter from NHRC Eastern Region's Special Rapporteur to NHRC, 14 May 2011 pp 35-40.
23 NHRC Case Details of File Number: 601/18/6/2010. Status 2/18/2016.
24 In the High Court of Justice Queen's Bench Division Technology and Construction Court Between: Dominic Liswaniso Lungowe & others (Claimants) and (1) Vedanta Resources PLC (2) Konkola Copper Mines PLC (Defendants). Particulars of Claim. Claim No. HT – 2015 – 0000292. Dated 14.08.2015.
25 See footnote 24.