Vedanta Resources plc Second Progress Report on the implementation of the Scott Wilson recommendations

Final Version

Vedanta Resources plc

3rd February 2012

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Executive Summary Vedanta Resources is committed to implementing all of the Scott Wilson recommendations within a wider program of fully integrating a new Sustainability framework and policies consistent with a multinational metal and mining enterprise operating 53 sites on four continents. This is the second progress report against the recommendations made by Scott Wilson in their report dated 17th November 2011. It will be publically available at http://www.vedantaresources.com/sustainability/scottwilson.html

At the Corporate / Group level, having modified the governance structure in the last period we have continued the development with the introduction of a new ExCo Subcommittee on Sustainability with a view to driving improved performance. The committee is chaired by Mr. MS Mehta the Group CEO and its members are subsidiary company CEOs /COOs and the company’s Chief Sustainability Officer. The Vedanta Board Sustainability Committee met twice during the latter half of 2011 and discussed sustainability performance, the sustainability framework, driving safety, capacity building, IT and target setting. The committee approved the sustainability framework and individual policies relating to social, human rights, biodiversity, water management, HIV/Aids, supplier and contractor management, energy & carbon management (including climate change) and stakeholder engagement with updates to our HSE policy. The ExCo Subcommittee met twice and focussed on safety issues within the plants reviewing specific audits of equipment permit to work systems that had been led by the corporate sustainability team.

During the last six months the Corporate Sustainability team has completed and rolled out 8 new policies and 34 Technical Standards as part of the Vedanta Sustainability Framework. It should be noted that all subsidiary companies have management systems in place and 29 out of 33 major sites are certified to ISO14001 and OHSAS 18001. Each site has carried out a GAP analysis and actions plans are in place to close any gaps found. The remaining technical standards will be rolled out as part of this programme during February and March and a suite of Guidance Documents is begin created to offer more details support in certain areas. To support this process a training programme has been developed and all CEOs have attended the summary session, while 17 operations and project managers plus 44 sustainability specialists are in process of completing the three day course. Of the eleven corporate recommendations we consider seven to be closed, three to be making excellent progress and one (the final sign off audit) to be completed in the future as per the original schedule.

During the period significant progress has been made at the group company level. Our new Project Development process is supported by the implementation of Technical standards on the Production of ESIAs to International Standards, Stakeholder Engagement, Water, Biodiversity, Cultural Heritage, Grievance Mechanisms and Land and Resettlement. These standards include specific sections on Vulnerable Social Groups. We have engaged competent environment and social consultants to support our work in this area. Further, we are reviewing all the land we own in order to assess risk to biodiversity. Of the seven company level recommendations we consider three to be completed and the remaining four to be well advanced.

At plant in Lanjigarh, we have continued to operate at or close to capacity without incident during the six month period. The plant has an excellent safety record and during the period was certified to ISO 50001 adding to the certifications of the environmental and safety systems to ISO 14000 and OHSAS 18001. During the period the HSES GAP analyses were completed as was the government approval of the site emergency preparedness and response plan which meets the Vedanta technical standard which reflects the UNEP requirements. Of the eleven recommendations we consider eight to be closed, two to be progressing very well and one (regarding the proposed expansion) to be on hold pending government approval.

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Table of Contents

Executive Summary _________________________________________________________ 1

Table of Contents ___________________________________________________________ 2

Background ________________________________________________________________ 4

Section 1 Corporate Level Progress __________________________________________ 6

Recommendation 2.5.7 Sustainability Committee _________________________________ 6

Appendix 1 – Meeting Minutes – Sustainability Committee ___________________________________ 6

Appendix 2 – Meeting Minutes – ExCo Sustainability Subcommittee ____________________________ 6

Recommendation 2.5.8 Chief Sustainability Officer ________________________________ 6

Appendix 3 – Job Description - Chief Sustainability Officer ____________________________________ 7

Recommendation 2.5.4 Value Statement ________________________________________ 7

Recommendation 2.5.2 Code of Conduct ________________________________________ 7

Recommendation 2.5.6 Policies ________________________________________________ 7

Appendix 4 – Policies _________________________________________________________________ 10

Appendix 5 – Vedanta Sustainability Framework Mapping Analysis versus IFC & ICMM ____________ 10

Appendix 6 – Sesa Goa and Balco Sustainability Policies _____________________________________ 10

Appendix 7 – Summary of Company GAP Assessments ______________________________________ 10

Appendix 8 – Vedanta Sustainability Framework Rollout Programme __________________________ 10

Appendix 9 – Vedanta Sustainability Framework T1 Training Programme (T1 Summary) ___________ 10

Recommendation 2.5.3 Stakeholder Engagement ________________________________ 10

Appendix 10 – Stakeholder Engagement Technical Standard _________________________________ 11

Recommendation 2.5.13 Reporting ____________________________________________ 11

Recommendation 2.5.8 Sustainability Committee Oversight _______________________ 11

Ref - Appendix 2 – Minutes of ExCo Sustainability Subcommittee _____________________________ 12

Recommendation 2.5.9 Professional Competency Review _________________________ 12

Appendix 11 – Sustainability Framework Training Rollout Programme (T1 Summary) _____________ 12

Appendix 12 – T1, T2 & T3 Training and Attendees _________________________________________ 12

Recommendation 2.5.16 Human Rights Policy ___________________________________ 13

Appendix 13 – Vedanta Resources plc Human Rights Policy __________________________________ 13

Appendix 14 – Guard Training Course Material ____________________________________________ 13

Recommendation 2.5.24 External Audit ________________________________________ 13

Internal Audit Programme _______________________________________________________________ 13

Appendix 15 – Draft Self Assessment Questionnaire ________________________________________ 13

Appendix 16 – Audit Programme 2012-13 ________________________________________________ 13

Final External Audit ____________________________________________________________________ 13

Section 2 Company Level Progress _________________________________________ 14

Recommendation 2.5.15 International Standard Best Practice ______________________ 14

Appendix 17 – New Project Risk Assessment ______________________________________________ 14

Recommendation 2.5.11 Land Management ____________________________________ 15

Appendix 18 – Biodiversity Risk Assessment ______________________________________________ 15

Recommendation 2.5.23 Register of Social and Labour Incidents ____________________ 15

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Appendix 19 – Social and Labour Incident Register _________________________________________ 15

Recommendation 2.5.12 Environmental Communication __________________________ 15

Appendix 20 – Stakeholder Engagement Plan – VAL-Lanjigarh ________________________________ 16

Recommendation 2.5.17 New project planning and development ___________________ 16

Appendix 21 – New Project Planning Process and Site Closure Management Standard ____________ 16

Appendix 22 – Vedanta Social Policy ____________________________________________________ 16

Ref - Appendix 10 – Stakeholder Engagement Technical Standard _____________________________ 16

Ref - Appendix 17 – New Project Database including Risk Assessment _________________________ 16

Recommendation 2.5.20 Vulnerable Social Groups _______________________________ 16

Appendix 23 – Vedanta Human Rights Policy ______________________________________________ 17

Appendix 24 – Conducting ESIAs to International Standards Technical Standard _________________ 17

Recommendation 2.5.22 Cultural Heritage ______________________________________ 17

Appendix 25 – Vedanta Cultural Heritage Technical Standard ________________________________ 17

Section 3 Lanjigarh Progress ______________________________________________ 18

Recommendation 3.3.20 Environmental and Social Management ___________________ 18

Appendix 26 – VAL–Lanjigarh HSE Policy _________________________________________________ 19

Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan _____________________________ 19

Recommendation 4.5.8 Grievance Mechanism __________________________________ 19

Appendix 28 – Vedanta Grievance Technical Standard ______________________________________ 20

Appendix 29 – Grievance Summary Data Analysis and Actions Taken __________________________ 20

Recommendation 3.3.3 Housekeeping _________________________________________ 20

Recommendation 3.4.3 Proposed expansion ____________________________________ 20

Recommendation 3.3.79 Disaster management plan ______________________________ 20

Appendix 30 – Lanjigarh Emergency Preparedness Management Plan _________________________ 21

Appendix 31 – Lanjigarh Emergency Preparedness Plan – Safety Handbook _____________________ 21

Appendix 32 – Lanjigarh Emergency Preparedness Plan – Drill Plan ____________________________ 21

Recommendation 3.3.32 Retrenchment Planning ________________________________ 21

Recommendation 3.3.48 Contractor accommodation _____________________________ 21

Appendix 33 – Vedanta Supplier and Contractor Management Technical Standard _______________ 22

Appendix 34 – VAL–Lanjigarh Contractor Accommodation Standard Operating Practice ___________ 22

Recommendation 4.5.5 Dust reduction plus health monitoring _____________________ 22

Recommendation 4.6.8 Additional livelihood programmes_________________________ 22

Recommendation 4.6.12 Integrated Community Development _____________________ 23

Appendix 35 – Integrated Livelihood Development Plan _____________________________________ 25

Recommendation 3.3.63 Contractor and Community Health and Safety ______________ 26

Ref - Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan _________________________ 26

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Background Vedanta Resources is a London Stock Exchange company with major assets in mining and processing

of copper, zinc, and aluminium and iron ore and oil and gas. Operations are located primarily in India

with mines and processing plants in South Africa, Zambia, Namibia, Liberia, Australia, Ireland and Sri

Lanka.

Vedanta Resources is committed to implementing all of the Scott Wilson recommendations within a

wider program of fully integrating a new sustainability framework of policies and standards

consistent with international standards such as the IFC, ICMM and OECD and consistent with

operating a multinational metals, mining and energy enterprise with 53 sites on four continents.

In 2010, the Vedanta board set the sustainability goal to be recognized internally and externally as

the global benchmark company in sustainability performance.

Of our 33 major metal and mining sites, 29 are approved to ISO14001 and OHSAS 18001 and Sesa

Goa, Hindustan Zinc Sterlite and Cairn India are companies quoted on major stock exchanges. Group

companies operate under their own Board of Directors.

This is the second progress report and details the actions we have taken since the Scott Wilson

Report was published on 17th November 2011. It contains supporting documentation where

relevant and possible.

At the corporate level we have developed an appropriate model for our business that has strong

subsidiaries and many operations in developing countries.

This model develops the Responsible Stewardship of all our the assets we manage including their

effect on the health and safety of our people and the environment but it goes further and

encourages us to develop Strong Relationships with all our stakeholders, be they shareholders or

lenders, employees, neighbours, members of our industry, the governments where we operate or

third parties with valid interests in our business. The goal of this second pillar is to create platforms

for creating sustainable development opportunities and hence support the third pillar in which we

The Vedanta

Sustainable

Development

Business Model

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aim to find ways to Add and Share Value with each of our stakeholder groups and thus meet the

Board’s sustainability objective.

Following the restructuring of a Sustainability Department in late 2010 and changes to our

governance structure in early 2011, we have embarked on a programme to make sure we manage

responsibly across all our businesses. We are fulfilling the recommendations of the Scott Wilson

report by the creation and group-wide implementation of a sustainability framework of eight

Vedanta policies and thirty five standards aligned to our sustainability model that will lead to a

consistency of process and to superior performance.

We intend to continue to develop our external reporting and to this end, we have taken the

opportunity to align our sustainability reporting calendar with the financial reporting timetable. We

published our Sustainable Development Report 2010-11 in June 2011.

http://www.vedantaresources.com/sustainability/griindex.html. This report was externally assured

by Det Norske Veritas (DNV) and received a B+ level against the GRI reporting framework.

Following our first six monthly progress report, Scott Wilson visited our sites at VAL - Lanjigarh and

Hindustan Zinc. They reported that of the eleven corporate level recommendations two were closed,

and two we substantially complete, three were progressing, three needed more attention and one

was not due being the final sign off audit. At the company level, of the eight recommendations, all

were progressing but extra attention was needed. This reflects the fact that we had focussed our

efforts on creating the complete framework before rolling it out. At Lanjigarh, one recommendation

was closed out and the rest will require further work as per the original timetable. During the last six

months, we have completed the sustainability framework and have rolled it out to all subsidiaries

who have reviewed the requirements against their own management systems. Where gaps have

been identified actions plans are now in place. We believe that seven corporate recommendations

are now closed and three are progressing on target (the final audit is still not due).

At the company level, we have made good progress on all seven recommendations and three are

closed as they have been covered by the sustainability framework and will be implemented on new

projects. We are in a good position to close the remaining four items in June. Most depend on the

completion of the implementation process of the Sustainability Framework and as previously

discussed this is progressing well.

At Lanjigarh, we have continued to make significant strides. A new position of Sustainability Officer

has been created and the team have made good progress such that we believe that eight of the

eleven recommendations are now closed and the rest in a good position for closure in June.

To strengthen the corporate systems we have recruited a head of assurance. Reporting to the Chief

Sustainably Officer, this position is responsible for developing the corporate sustainability assurance

programme that will begin implementation in March 2012. This is described in more detail later in

the report.

The following three sections describe in details our progress at the Corporate, Company and

Lanjigarh levels.

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Section 1 Corporate Level Progress During the period between June and December 2011, significant progress has been made. We have

continued to enhance sustainability governance with the formation of the new ExCo Subcommittee

of CEOs/COOs which meets monthly and supports the ExCo and board appointed Sustainability

Committee. The Sustainability Framework is substantially complete with all new policies approved

by the Sustainability Committee which has fully oversight of all sustainability matters. These policies

and their supporting technical and management standards have been progressively rolled out to the

companies. To support this process a training programme has been developed and all CEOs and

senior management have attended the summary session, while 31 operations and project managers

as well as 67 sustainability specialists will complete the full three day course.

Recommendation 2.5.7 Sustainability Committee 2.5.7 The title of the HSE Committee should be changed to the Sustainable Development Committee and its terms of reference expanded to reflect the breadth of its role covering all aspects of the environmental and social sustainability of the Group. Target: May 2011

Following a recommendation by the HSE committee, the Board of Directors evolved the HSE

Committee into the Sustainability Committee at their meeting on 17th March 2011. The

Sustainability Committee met twice between July and December. We now consider this committee

an integral part of the management of the company along with the other board appointed

committees. The committee has full ownership to oversee the process of implementation of the

Scott Wilson recommendations and approved the interim submission of information in September

2011.

During the period, we have formed an ExCo Sustainability Subcommittee, led by the Vedanta CEO

with subsidiary CEO/COOs as members. This committee meets monthly to champion the

implementation of the Sustainability Framework in particular improvements in our safety

performance.

We consider this recommendation closed.

Appendix 1 – Meeting Minutes – Sustainability Committee

Appendix 2 – Meeting Minutes – ExCo Sustainability Subcommittee

Recommendation 2.5.8 Chief Sustainability Officer 2.5.8 Appoint an appropriately qualified Chief Sustainability Officer with international experience to direct and coordinate the HSE, CSR and related functions. The CSO will act through single points of

contact in each subsidiary company. Target November 2011

A Chief Sustainability Officer was appointed on 8th November 2010. The Chief Sustainability Officer’s

position reports directly to the Vedanta Resources Chief Executive Officer.

The Chief Sustainability Officer’s team includes specialists, who head; sustainability assurance,

health and safety, environment and community investment. The Chief Sustainability Officer’s job

description is attached and his organisation chart and his operational contacts are shown below.

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We consider this recommendation closed.

Appendix 3 – Job Description - Chief Sustainability Officer

Recommendation 2.5.4 Value Statement 2.5.4 Revise the wording of the Value Statement on Sustainability to state: “We aim to contribute to the social and economic welfare of the communities where we work and to protect and conserve the environment.” Target: January 2011

Closed by Scott Wilson (Review of Progress Report - June 2011)

Recommendation 2.5.2 Code of Conduct 2.5.2 The preamble to the Code, “How We Do Business”, should include reference to local communities as a key element affecting Vedanta’s reputation along with customers, shareholders, competitors and suppliers. Target: January 2011

Closed by Scott Wilson (Review of Progress Report - June 2011)

Recommendation 2.5.6 Policies 2.5.6 Develop a series of policies to realise the aims stated for each of the four sustainability areas (environmental stewardship, nurturing people, health and safety and empowering communities). The policy statements should be succinct, should reflect best international practice and reflect a commitment to continuous improvement. Annual targets for progress and reporting should be considered wherever possible. Noise should be included as a policy issue. Target: To be implemented in time for the 2011 Annual Report and Sustainability Report to be published in June 2012.

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Under the umbrella of the Company’s, Vision, Values, Code of Conduct and Sustainability Model, the

Sustainability framework of policies, management and technical standards has been substantially

completed. Our policies are publically available at

http://www.vedantaresources.com/sustainability/our_strategy.html

This framework has been mapped against IFC and ICMM performance standards and guidelines and

our external assurance provider states the following:

“As part of the development and implementation of the Vedanta Sustainability Framework, ERM has

mapped the elements of the Framework to meet IFC and ICMM requirements. The IFC and ICMM

requirements are generally met by the Vedanta Framework elements as set out in the mapping

document attached. It is noted that some of the more technical elements of IFC Performance

Standard requirements are currently being addressed through the development of additional

Standards and/or Guidance Documents. It is anticipated that the remaining technical elements will

have been addressed during the first half of 2012”.

The management teams at our group companies, led by their CEO have reviewed the 8 policies and

34 (of 35) standards that have been rolled out to date (Our Sustainability Data Management

Technical Standard remains to be rolled out in March after a decision is taken on the choice and

implementation of a new Sustainability IT system ). A summary of the GAP analyses performed by

each group is attached and time bound action plans are in place to close the gaps identified. To help

with the closure of any gaps and to include some of the fine details within the IFC guidance notes

and EHS Guidelines, a series of Guidance Notes is being created to support the subsidiary

companies. These will be completed and be in full operation by June. As examples of the alignment

taking place within the group the Sustainability Policies of Sesa Goa and Balco can be found in

Appendix 6.

In order to enhance capacity across the group a training programme has been developed. The

summary programme has been attended by all CEOs and full three day programme by Operations

and Project Managers as well as Susintailbity specialists. Two courses have taken place, one in India

and one in Zambia and the third is planned again for India in February. The Sustainability specialists

had a further two days of train the trainer sessions to allow them to take the course back to their

companies for all to benefit. The roll out programme is attached in Appendix 9

Within the Corporate Sustainability team, the head of assurance has been instrumental in preparing

the Sustainability audit programme. This will consist of a Self Assessment Questionnaire to be

completed by all group companies and approved by their respective CEO annually in April, and then

again at the end of each following financial year. Following this first step, a programme of site visits

will take place to verify the group company’s records and confirm their assessment of compliance

with the Vedanta Sustainability Framework. A description of the framework and our Sustainability

Policies can be found on our website at

http://www.vedantaresources.com/sustainability/our_policies.html.

To better manage the systems associated with our sustainability performance we have completed

the selection process for a world class IT system that will be implemented at all group companies

during the rest of 2012. As the implementation progresses we will reduce our reliance on manual

systems and we expect it to be a major benefit to the company.

We expect the system to be fully implemented and all gaps closed by June 2012 at which time we

believe that this recommendation will be closed.

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The policies in the framework are titled as follows:

The global processes and management standards are titled as follows:

Group Policies

Responsible Stewardship Strong Relations Adding Value

HSE Policy

Biodiversity Policy

Water Management Policy

Energy and Carbon Management Policy

Social Policy

Supplier and Contractor Management Policy

Human Rights Policy

HIV/Aids Policy

Global Management Processes & Management Standards

GLOBAL MANAGEMENT PROCESSES

New Projects, Planning Processes & Site Closure

Stakeholder Materiality and Risk Management

Incident Reporting and Investigation

Management of Change

Documentation & Records Management

Corrective & Preventive Action Management

Auditing and Assurance

Acquisitions, Divestment and Joint Venture Due Diligence

MANAGEMENT STANDARDS

Compliance and Other Requirements

Leadership, Responsibilities and Resources

Objectives, Targets and Performance Improvement

Competency, Training and Awareness

Management Review and Continual Improvement

Audit and Assurance

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The technical standards, designed to support the policies are titled as follows:

Appendix 4 – Policies

Appendix 5 – Vedanta Sustainability Framework Mapping Analysis versus IFC & ICMM

Appendix 6 – Sesa Goa and Balco Sustainability Policies

Appendix 7 – Summary of Company GAP Assessments

Appendix 8 – Vedanta Sustainability Framework Rollout Programme

Appendix 9 – Vedanta Sustainability Framework T1 Training Programme (T1 Summary)

Recommendation 2.5.3 Stakeholder Engagement

2.5.3 Adopt internal procedures to ensure that all requests for information from stakeholders (including investors, NGOs, international organisations and the press) are dealt with a timely manner. We see this as an important part of a wider programme to inform and communicate with all stakeholders. To assist with transparency Vedanta should maintain a register of enquiries and responses and provide a summary in their Annual Sustainability Report/website. Target: April 2011

A key part of the new sustainability framework is the social policy and the supporting technical

standards. These standards require all operations to identify stakeholders and determine

engagement plans together with a method to record and reply to stakeholder enquiries and

grievances.

Technical Standards

Responsible Stewardship Strong Relations Adding Value

Health Management

Safety Management

Environmental Management

Conducting ESHIA to International Standards (includes EMPs)

Waste Management

Biodiversity Management (includes EMPs)

Water Management

Energy and Carbon Management

Land and Resettlement Management

Security Management

Emergency and Crisis Management

Transport and Logistics Management

Sustainability Data Management

Cultural Heritage

Supplier and Contractor Management

Employee Consultation & Participation

Stakeholder Engagement

Social Investment Management

Grievance Mechanisms

HIV/Aids Management

Site Closure

.

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At the Corporate level, we are developing our Stakeholder Engagement Plan and have set up an

email address sustainability@vedanta.co.in for enquiries which are registered. This address was

publicised in our latest sustainable development report and is available on our website at

http://www.vedantaresources.com/sustainability/griindex.html

Additionally, enquiries or correspondence to our Investor Relations group are also registered and

receive a reply.

An analysis of enquires received shows that of 163 emails received between January 2011 and

January 2012. Of this total, 30 are requesting information about Sustainability topics while 57 are

companies sending unsolicited marketing information, 32 are requests for speakers and 15 requests

for employment. Replies have been sent to all requests for information and employment while for

others appropriate action was taken or they did not require action. This process is now part of our

Sustainability Management system.

We consider this recommendation closed.

Appendix 10 – Stakeholder Engagement Technical Standard

Recommendation 2.5.13 Reporting 2.5.13 Report, where possible, on Group environmental and social performance as a whole and seek to benchmark performance against industry best practice and seek assurance from appropriate bodies with industry and sustainability expertise. Target June 2012

In their July progress report, Scott Wilson commented on the need for external benchmarking and this is in process. This recommendation will be completed by June 2012.

Recommendation 2.5.8 Sustainability Committee Oversight 2.5.8 The corporate Sustainability Development Committee should continue to ensure that subsidiary companies take a consistent approach to promoting sustainable development in accord with international best practice by monitoring performance, lesson learning and dissemination of best

practice. Target November 2011 The board appointed sustainability committee has full oversight of all issues regarding sustainability.

The committee approved the submission of documentation to Scott Wilson in September now

formally contained in this document.

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The committee has met four times so far in this financial year and has been instrumental in the

formation of the ExCo subcommittee as its executive arm. These meetings now from an important

part of the Vedanta Board’s oversight of sustainability issues and will form a permanent part of the

company’s governance structure.

During its meetings the Sustainability Committee approved our submissions to Scott Wilson

including this report and discussed the following subjects: Vedanta and subsidiary sustainability

performance, the sustainability framework and its roll out to subsidiaries, driving safety, capacity

building, IT and subsidiary target setting.

During its meetings, the ExCo subcommittee focussed on safety and reviewed the results of a

number of specific plant and equipment audits across the group. It also instigated an audit of near

misses. Both these actions have led to direct reduction of risk to our employees and contractors as

improvements have been implemented.

Sustainability oversight is fully within the Sustainability Committee remit and is an ongoing part of

the management of the company; as such we consider this recommendation closed.

Ref - Appendix 2 – Minutes of ExCo Sustainability Subcommittee

Recommendation 2.5.9 Professional Competency Review 2.5.9 Keep under review the full range of HSE and CSR competencies required across the business and consider the need for additional training, as appropriate, in relation to the IFC Performance Standards and Guidelines, human rights, vulnerable groups and the GRI Mining and Metals Sector

Supplement. Target November 2011. Across the group we employ a wide range of competent trained business and sustainability

professionals. To raise awareness of a training programme has been developed for management,

project and operations staff and technical experts to build capacity around the requirements of the

Vedanta Sustainability Framework and to raise awareness of international standards focusing on the

IFC performance standards, guidance notes and EHS guidelines.

All CEOs and senior managers have attended a summary course. 17 operations and project staff and

44 sustainability professionals have attended the two full courses held to date. This programme

included a section to train trainers who have returned to their respective companies and have begun

relaying the training and information from the courses to all staff. This programme complements the

wide range of training the company provides via the human resources development programme and

the roll out of the Vedanta Sustainability Framework.

While we have made significant progress, this work is ongoing and we expect it to be closed by

June 2012.

Appendix 11 – Sustainability Framework Training Rollout Programme (T1 Summary)

Appendix 12 – T1, T2 & T3 Training and Attendees

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Recommendation 2.5.16 Human Rights Policy 2.5.16 Adopt a specific human rights policy demonstrating its commitment to the UN Declaration of Rights and procedures to ensure its implementation. This should be communicated to all stakeholders

via its web site. Target November 2011.

Following the modifications to the Vedanta Code of Conduct and as a part of the Vedanta

Sustainability Framework we have developed and published the Vedanta Human Rights Policy,

reflecting our commitment to the UN Declaration of Rights. It was approved by the sustainability

committee in July 2011 and has been rolled out across the group as part of the Sustainability

Framework roll out programme. It is available for view at the Vedanta website at

http://www.vedantaresources.com/sustainability/our_policies.html

As part of our security management programme, training is given to guards at our group companies

and as part of the development of professional competencies we are developing training for all

employees.

Appendix 13 – Vedanta Resources plc Human Rights Policy

Appendix 14 – Guard Training Course Material

We consider this recommendation to be closed and future actions to be part of the roll out of the Sustainability Framework.

Recommendation 2.5.24 External Audit 2.5.24 Undertake an audit of Group and Company environmental and social performance against international standards (IFC, ICMM, OECED) after 12 months of implementing the recommendations in this report (i.e. June 2012). Recommendations which are not implemented will be included in a Remedial Action Plan and their compliance reviewed every 6 months. Target: November 2012/June 2013

Internal Audit Programme

An important part of the sustainability organisation at group level will be an assurance team to

develop and implement the group sustainability assurance programme. The new leader of this team

is in place and the Self Assessment Questionnaire will be sent to all CEO’s in February for completion

and signing at the end of the financial year. This will become an annual process and signal

compliance with the requirements of the group sustainability policies and standards within the

sustainability framework or detail a corrective action plan. In this way, a systematic programme of

continuous improvement will be created and compliance will be assured to the Vedanta Board and

to other stakeholders.

By the time of the June progress report, we expect to have the Self Assessment Questionnaires

completed and have begun the site visit programme. This will be a significant step in moving to the

last part of the programme and completing the final external audit.

Appendix 15 – Draft Self Assessment Questionnaire

Appendix 16 – Audit Programme 2012-13

Final External Audit

We fully expect the external audit to be commissioned within the suggested timeframe.

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Section 2 Company Level Progress During the latter half of 2011, significant progress has been made at the group company level. All

our new projects are following the new management standard for New Project Development; this

process is supported by the implementation of the following technical standards: Production of

ESIAs to International Standards, Stakeholder Engagement, Water, Biodiversity, Cultural Heritage,

Grievance Mechanisms and Land and Resettlement. These standards include specific sections on

vulnerable social groups. We have engaged competent environment and social consultants to

support our work in this area at each new project.

Further, all companies have carried out a GAP analysis between their own policies and management

systems and the requirements of the Vedanta Sustainability Framework. Where gaps have been

identified time-bound actions plans are in place. Examples of the Sesa Goa and Balco’s own

sustainability policies can be seen in Appendix 6.

Of the seven company level recommendations we consider three to be completed and the

remaining four to be well advanced.

Recommendation 2.5.15 International Standard Best Practice 2.5.15 Produce and test EIAs and EMPs against the IFC Performance Standards and ICMM best practice and define clear links between the EIAs, EMPs and Environmental Management Systems. Specifically EIAs should be expanded in relation to biodiversity and habitat identification, the identification of cultural heritage (scheduled and non-scheduled sites) and social and human rights impacts. Vedanta should commission independent reviews of one or more major EIAs each year in order to ensure compliance with IFC Standards. Immediate implementation

All our new projects will follow the Vedanta Sustainability Framework of Policies and Technical

Standards. As such they are aligned to the IFC Performance Standards and Guidance notes together

with the EHS guidelines.

Specific standards include:- New Projects, Planning Processes & Site Closure Management Process;

Stakeholder Materiality and Risk Management Standard; Land and Resettlement Management;

Security Management; Cultural Heritage; Stakeholder Engagement; Social Investment Management

and Grievance Mechanisms.

We have assessed our new project sustainability risks and the summary is attached in Appendix 17.

We will continue to test our EIAs against the IFC performance standards as a part of our audit

process and believe that all new ESIAs will meet the requirements of the Vedanta Framework.

We consider that using our sustainability framework as a guide all new projects will meet international standards and as such we consider this recommendation to be suitable for closure in July when the ESIAs will be available.

Appendix 17 – New Project Risk Assessment

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Recommendation 2.5.11 Land Management 2.5.11 Develop a policy and implementation practices to more proactively manage land in their ownership in order to maximise environmental gains and promote biodiversity. This would include the development of environmental management plans for all non-operational land and the carrying out of habitat surveys for all new sites prior to development. Target: To be implemented in time for the 2011 Annual Report and Sustainability Report to be published in June 2012

In order to promote the management of water and biodiversity, we have made a review across all

the company operations and mapped all our sites using the IBAT mapping tool

https://www.ibatforbusiness.org/ developed by a consortium of NGOs. This process has led to a risk

assessment which is being used to set priorities for the development of Biodiversity Action Plans. Of

the 47 sites we have reviewed using the tool; we have defined eight sites as a higher risk and

requiring further investigation because they are situated within one kilometre of an area of high

biodiversity value. A further fourteen sites are categorised as a medium risk as they are situated

between two and ten kilometres of a high biodiversity area and the remaining 25 sites are of lower

risk.

Further, we have joined forces with the World Business Council for Sustainable Development to help

refine the granularity of their World Water Tool for better use in India. This will take some time to

complete after which we intend to map all our sites and develop a risk assessment for water.

Whilst we have Biodiversity Action Plans in place at some of our higher risk sites, we expect BAPs

to be in place for all higher risk sites by June 2012 at which time we expect to close this item.

Appendix 18 – Biodiversity Risk Assessment

Recommendation 2.5.23 Register of Social and Labour Incidents 2.5.23 Maintain a register of major social and labour incidents at their plants and report to VRL Target:

April 2011

All group companies have developed a reporting process and database of incidents beginning 1st

April 2011 or earlier in the case of Lanjigarh. A monthly report is supplied to Vedanta Corporate,

where a full register is kept. The complete register is circulated back to all companies within the

group for awareness, learning and risk management purposes. We now consider this a fully

implemented part of our business management system.

We consider this recommendation now implemented the item to be closed.

Appendix 19 – Social and Labour Incident Register

Recommendation 2.5.12 Environmental Communication 2.5.12 Communicate environmental monitoring regimes at plants and regularly report to stakeholders, including local communities, on their environmental performance, benchmarking this against international standards (e.g. IFC Guidelines) and reporting in their 2012 Sustainability Report. Target November 2011

Following our Stakeholder Engagement Technical Standard, we are producing Stakeholder

Engagement plans at all group companies.

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Within these plans, we have developed meeting schedules and registers to maintain the records that

we already had in place and we are developing our Environmental and Social Performance Report.

We consider that this recommendation is progressing well and will be completed by June 2012.

Appendix 20 – Stakeholder Engagement Plan – VAL-Lanjigarh

Recommendation 2.5.17 New project planning and development Standard Community Consultation Processes within new project development 2.5.17 Develop a standardised approach to community consultation for new developments which responds to IFC guidance and communicate this to all stakeholders via its web site. Target November

2011

Solid progress has been made to develop the new project management process as a part of the

sustainability framework and the group is committed to following international standards,

particularly the IFC standards for producing EIAs and conducting public consultation for new

projects.

All our new projects will follow the New Project Development and Site Closure Process as part of the

Sustainability Framework. This is supported by our Stakeholder Engagement Technical Standard

which adheres to the IFC performance Standards and guidance notes. This requirement has been

included in the training courses given to operations, project and sustainability specialists.

We consider that this recommendation is now included in our Sustainability Management

programme for all new projects and thus closed.

Appendix 21 – New Project Planning Process and Site Closure Management Standard

Appendix 22 – Vedanta Social Policy

Ref - Appendix 10 – Stakeholder Engagement Technical Standard

Ref - Appendix 17 – New Project Database including Risk Assessment

Recommendation 2.5.20 Vulnerable Social Groups 2.5.20 Adopt a specific policy in relation to engagement with and assistance to social groups that may be vulnerable to change and communicate this to all stakeholders on its web site. Target November 2011

As part of the Stakeholder Framework we have adopted a Human Rights policy to support the

statements in our Code of Conduct. The “Conducting ESIAs to International Standards” technical

standard requires human rights considerations to be taken into account for all new projects.

This requirement has been included in the training courses given to operations, project and

sustainability specialists. Further, based on the results of the IFC mapping project that we used to

ensure the Sustainability Framework meets international standards, we are developing a technical

standard / guidance note in for Vulnerable Social Groups to provide more detailed support to our

group companies in this area.

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We expect the Technical Standard / Guidance note to be added to the Sustainability Framework

and we believe this recommendation will be closed in July.

Appendix 23 – Vedanta Human Rights Policy

Appendix 24 – Conducting ESIAs to International Standards Technical Standard

Recommendation 2.5.22 Cultural Heritage 2.5.22 In developing new sites adopt a standardised approach to the identification of sites of cultural heritage value involving formal documentary sources, site surveys and community consultation. Target

November 2011

Our New Project Development Process is a key part of the Sustainability Framework and as such it

must be considered in all new projects. Included in this process and specifically in the Conducting

ESIA to International Standards and Cultural Heritage Technical Standards are the Vedanta

Requirements for all companies and projects to follow.

Whilst the scope of the assessment will depend on the nature and scale of the project and

sensitivities in terms of cultural heritage, all our new projects require a cultural heritage feasibility

study to be carried out

This requirement has been included in the training courses given to operations, project and

sustainability specialists.

As this is now a part of the management system, we consider that this recommendation is now

closed.

Appendix 25 – Vedanta Cultural Heritage Technical Standard

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Section 3 Lanjigarh Progress At Lanjigarh the team takes all matters of Sustainability very seriously and a Sustainability Officer has

been appointed to increase focus in this area. The organisation chart for this position is shown

below.

A focussed effort to complete the improvement program at the VAL refinery in Lanjigarh has been

undertaken and the results to date are described below. These include a systematic gap analysis of

Health and Safety and, Environment and Social management against the Vedanta Sustainability

Framework and IFC and ICMM standards, the implementation of a grievance cell that operates a

weekly surgery managed by the VAL Lanjigarh community relations team, improvements to the

filtration system and air monitoring together with a housekeeping drive and a review and update of

the disaster management plan in line with UNEP recommendations.

Recommendation 3.3.20 Environmental and Social Management 3.2.20 Undertake a systematic gap analysis of the EMS against the Industry Best Practice criteria and update it accordingly. Target: April 2011 A gap analysis study with reference to Indian law, IFC Performance Standards, ICMM guidelines,

OECD guidelines and the UNGC has been completed by ERM India. Within this report 126 items were

checked which has led to two overarching actions to be completed in the coming six months. These

are:

i) the creation of an Environmental and Social Management Plan to summarise all the work we

have completed to develop the VAL-Lanjigarh sustainability management system including

guidelines for contractor camps, development of organisational capacity, procurement of

local content, waste management and resource efficiency. The goal is to create a world class

management programme.

ii) The creation of a stakeholder engagement plan to include all the work we have completed

on our grievance mechanism, engagement with all stakeholders and the continued

development of an integrated development plan for the area.

This work will be completed by June 2012 when we expect this recommendation to be closed.

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Appendix 26 – VAL–Lanjigarh HSE Policy

Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan

Recommendation 4.5.8 Grievance Mechanism 4.5.8 Establish and strengthen a simple and accessible grievance mechanism by which villagers can identify any concerns about the operation of the refinery by using the village coordinators already deployed by VAL. Target: May 2011

The public grievance system has been implemented in Lanjigarh by the Rehabilitation & Peripheral

Development Advisory Committee (RPDAC), we have implemented our own public grievance and

open communication mechanism. Every Friday, the vice president of human resources holds an open

forum to hear issues and complaints & take-up the issues with concerned parties.

A total of 634 people were seen between April 2011 and January 2012. In case of issues related to

the government, such as; a local community requesting a special relief package over and above the

package previously announced by the government and agreed during the public consultation before

the plant was built, then the matter is referred to the Government of Orissa for direction and

Vedanta facilitated meeting with the person and the government representatives. In the cases of

requested for employment we were able to help some people but not all. All other issues have been

resolved amicably.

The Grievance Mechanism and documentation has been upgraded and modified based on the

feedback given during last Scott Wilson visit. All the grievances have been complied into categories:

education, land, livelihood, financial support, employment etc. The manual registers are being

replaced with computerized documentation for easy access.

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Appendix 28 – Vedanta Grievance Technical Standard

Appendix 29 – Grievance Summary Data Analysis and Actions Taken

We consider this now recommendation to be a part of the ongoing management of the site and as

such it is closed

Recommendation 3.3.3 Housekeeping

Closed by Scott Wilson Review of Progress Report - June 2011

Recommendation 3.4.3 Proposed expansion

If the expansion of the refinery is to proceed, a supplementary report be prepared to augment

and update the existing EIA, thus meeting international best practice. This report would be

used to guide further development and would be made available to key stakeholders (No

defined target date = dependent upon court approval to proceed).

The Expansion Project currently remains ‘on hold’ and there is no certainty when the court order

might be lifted. The company has committed to preparing a supplementary report, which should

reflect the requirements of Recommendation 2.5.15 (company level example on international best

practice) and the detailed findings of the updated gap analyses required for Recommendation 3.3.20

(Lanjigarh).

As and when the project is approved we shall implement the action of a supplementary report.

Recommendation 3.3.79 Disaster management plan

Review the Disaster Management Plan against recognised industry guidance (such as the

ICMM / UNEP publication “Good practice in emergency preparedness and response”, 2005)

and upgrade its emergency prevention and response arrangements including improved drill

and simulation exercises (Original target = April 2011).

Alumina refineries are classed as potentially hazardous plants and are therefore obliged to have a

Disaster Management Plan (DMP) that deals with any significant risks including those associated

with ‘off-site’ facilities like red mud and ash ponds.

VAL-Lanjigarh has updated its Disaster Management Plan. The revised DMP has been submitted to

the Director of Factories and Boilers, the regulatory body, and final approval is awaited.

We believe that the plan meets the Vedanta Technical Standard, Emergency and Crisis Management

and the Emergency Preparedness criteria of the UNEP recommendations as follows:

1. Roles & responsibilities - covered on page number: 87 of DMP.

2. Risks & hazards - covered on page numbers: 2,28,31,92 of DMP.

3. Emergency plan - covered on page numbers: 71, 77 of DMP.

4. Identify required response tasks – covered in page numbers: 87-91 &132-142 of DMP.

5. Match task to resource availability - covered in page numbers: 144, 161 of DMP.

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6. Improve the Plan using drills and integrate it into the overall Community Plan – see Stakeholder

Engagement Plan and Drill Plan

7. Endorsement & approval – internally approved, government approval received.

8. Emergency plan training – covered in page numbers: 77 of DMP

9. Establishing procedures for periodic testing – see Drill Plan.

10. Communicate to general community - as part of communication "Safety hand book” was made.

Appendix 30 – Lanjigarh Emergency Preparedness Management Plan

Appendix 31 – Lanjigarh Emergency Preparedness Plan – Safety Handbook

Appendix 32 – Lanjigarh Emergency Preparedness Plan – Drill Plan

We consider Emergency Preparedness to be a part of the ongoing management of the site and as

such it is closed.

Recommendation 3.3.32 Retrenchment Planning 3.2.32 Develop suitable and sufficient retrenchment plans to mitigate the adverse impacts of future suspension or closure of the refinery on both direct and indirect employees. Target: November 2011

There is a robust an established legal framework and retrenchment can only be made after obtaining

approvals from the government (except termination on account of disciplinary/integrity issues). The

procedure and standing orders that have been set up by the government and are jointly signed by

VAL & the Government of Orissa’s director of factories have been and will be followed.

We consider management of retrenchment to be a part of the ongoing management of the site

and as such it is closed.

Recommendation 3.3.48 Contractor accommodation 3.3.48 Undertake a gap analysis for contractors’ labour accommodation against IFC/EBRD guidance and any serious deficiencies addressed. VAL should therefore amend its contractual documentation to specify minimum expectations for contractors in regard to labour accommodation, and then enforce contractors’ adherence to its specified requirements. Target: November 2011

The labour camps in Lanjigarh were built by contractors on private land and it is not possible for us

to remove or dismantle these camps at present. However, our CSR team regularly visit the camps to

ensure that proper hygiene & sanitation conditions are maintained. We continue to organize health

camps through our mobile health units. We are developing a camp checklist for the CSR specialists to

use on their visits and this will be used to maintain standards if the camps are used in future. We

have also developed a VAL standard operating practice for the minimum requirements of contractor

facilities in line with IFC guidelines. This will be used when the expansion project begins.

We consider management of contractor accommodation to be a part of the ongoing management

of the site and as such it is closed

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Appendix 33 – Vedanta Supplier and Contractor Management Technical Standard

Appendix 34 – VAL–Lanjigarh Contractor Accommodation Standard Operating Practice

Recommendation 4.5.5 Dust reduction plus health monitoring 4.5.5 Review the issue of sporadic dust nuisance, seek to reduce such pollution and monitor both dust emissions and incidence of respiratory infections in the immediate locality of the refinery. Target:

November 2011

In 2011, as part of our continuous improvement programme, US$10 million was invested for the

installation of vacuum dust collection systems, bag filters, various dust suppression systems such as,

sprinklers, dry fog etc. and continuous online monitoring is being made for ambient air quality as per

international norms. This information is being displayed at the plant gate and is continuously online

at the government offices in Bhubaneswar.

Scott Wilson commented that this is item can be closed with the plan for roadside dust control. To

this end, alumina transportation by road has been stopped completely and the road transfer of

bauxite from the nearby railway station has already been reduced. Presently, one full train per day is

now received directly in the plant reducing dust by 33% and by March 2012. All trains will be

received in the plant ending vehicular movement for bauxite transportation by road. In the

meantime, we will continue to use trucks with tarpaulin covers and with water sprinkling to

minimize any dust.

We consider this recommendation now implemented and the item closed.

Recommendation 4.6.8 Additional livelihood programmes 4.6.8 Give further consideration to accelerating livelihood training programmes for villagers via self-help and business start-up support, especially in those villages close to the refinery and monitor local employment creation in these villages and the Lanjigarh block. Target: November 2011

We are continuing to work with the LPADF and others in the region to help support people in the

villages near to our refinery.

In addition, to the work we do with the LPADF, a detailed action plan has been prepared in

consultation with the Government of Orissa and a Human Development specialist. The basic

objective of the plan is to improve livelihood opportunities by linking Government schemes with the

needs of the area. Vedanta’s role will be to provide a bridge between the villagers and the

government and to ensure the adoption of the latest systems in agriculture, health, marketing agro

products etc.

VAL-Lanjigarh is also developing many other important projects, the first is the new school nearby,

which now has 450 pupils and a new infant section that opened recently and which is

oversubscribed. It should be noted that over 50% of the pupils are from the tribal communities. The

second major project is a hospital, open and free to anyone, that treats about 150 people per day,

market days being particularly busy. Details of other projects are available on the VAL website

http://lanjigarhproject.vedantaaluminium.com/community.htm

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We consider that this recommendation is part of 4.6.12 and we consider this is now an integrated

part of the site management and thus the item closed.

Recommendation 4.6.12 Integrated Community Development 4.6.12 Work together with local government to develop and publicise an integrated rural development strategy for the area. Target: April 2012

Vedanta is a long term player and will continue to actively seek ways to help develop the area

around Lanjigarh. The work of the LPADF and the coordination with the Dongria Kondh Development

Agency (DKDA) will play an important role in the future. Further, our Integrated Village Development

Plan is attached and further discussions are in progress to merge the finding with the Livelihood

Development plan discussed above.

The wider community

The wider community is vital to the success of any business like ours. For Vedanta, a company with

strong Indian roots, working in our homeland; we feel a strong obligation for our business to be a

force for good and development in the community as well as being a commercial success. It is the

practical manifestation of our view that we must add to India’s development, not only through our

business activities, but also through active “bottom-up” community programmes.

Our community engagement vision is:

“Sustainable development of the local community living in the core and periphery habitations and

emerging as a responsible corporate partner of the government and the people at large”

Since the earliest days of the project we have had a professional community outreach department

with staff specialised in diverse areas including a professional anthropologist. They are supported by

a network of outreach workers recruited from the Dongria Kondh and the Kutia Kondh. In addition

to the jobs we have created directly, our strategic areas of focus in community development are:

Infrastructure development:

This has included extensions to rural areas through the building 50 kms of approach roads to isolated

villages, culverts, dams, check dams, 43 tube wells eight community centres and seven places of

worship, in addition to the general improvements to local roads, rail, water and power systems for

business reasons. We have also invested extensively in the development of the town of Lanjigarh.

Access to water is a key issue in this drought prone area and the 2007 District Statistical Handbook

records that there were no villages in Lanjigarh that had access to tube wells and other sources of

piped water at that time.

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Education, sports and culture

We have set up 36 childcare centres, have supported the State of Orissa’s fortified food supplement

scheme in 400 pre primary schools (known as Aganwadi) in Kalahandi and 678 in Rayagada. We are

opening a mid-day meals centre to provide food and reduce school drop out in the 166 schools of

Lanjigarh. We have supported 31 tribal schools to get their first computers and in addition have

built the only English language school in Lanjigarh with 400 students of which roughly half are from

tribal families.

We are very committed to the maintenance and enrichment of local culture and festivals and

support religious and cultural events as well as provide and sports grounds and activities.

Health and sanitation

We have partnered with the government to significantly upgrade the Lanjigarh hospital and we have

built our own hospital on site for staff which also provides free services for the community catering

for about 200 patients a day of who over 50% are from the tribal groups. We provide mobile health

units to travel to the villages of the Dongria Kondh and other surrounding areas. We also run health

awareness and education camps over a wide area to promote interventions on child feeding,

vaccinations, family planning, and protection against malaria and communicable diseases. As the

paragraphs below show, we are making progress in improving health indicators. The hospital houses

the only equipment for detecting sickle cell anaemia in Orissa.

Sustainable livelihoods

Our programme of support for sustainable livelihoods covers several areas. Firstly, we work with

farmers to improve their agriculture. We have a vegetable growing project with 150 farmers in 13

villages, sunflower cultivation with 150 farmers in 8 villages and for the first time in Kalahandi, the

commercial production of organic cotton with 150 farmers in 8 villages. For women, we have

project Sashakti to help women’s self employment and have provided sewing machines and skills

training and specifically for tribal women we have built on their traditional skills to make and market

leaf plates that are sold in surrounding districts and about 600 participate in the project.

All this work includes a degree of environmental awareness and the protection of natural resources

and bio-diversity is also part of our programmes. For us this work is not philanthropy or old style

benevolent paternalism. It is community investment and development. Which means we want to

see real returns for the inputs we make and by working with others in key projects, we have helped

achieve measurable improvement in community well being through active partnerships. For

example;

The rate of child immunization in Kalahandi has risen from 35% to 71% between 2005 and 2008,

Child malnutrition has dropped from 58% in 2005 to 31% in 2008.

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Diagrammatic depiction of Vedanta’s Community Development methodology concerning participation

and feedback of consultations.

School attendance rates have increased from 45% in 2005 to 70% in 2008 while drop out rates have reduce from 70% to 20% over the same period and we have played a role in this progress.

We can also measure the increase in the incomes of the farmers and women we work with and they are significant for a district where half the population use to live on less than $US1 per day.

We have subjected our community programmes to independent review by the non-profit Xavier

Institute of Social Service and to further expand on our performance.

In addition, we have reviewed our programmes in light of the priorities set by the Millennium

Development Goals (MDG) as an important international benchmark of social performance. For

example, we contribute to six of the 10 MDG goals such as eradicating poverty and hunger,

empowering women and combating HIV/AIDS, malaria and other diseases. We have helped double

the local immunisation rate and 20,000 people have attended the HIV/AIDS awareness workshops

we sponsor. As part of our planning for future engagement and to understand the needs of the

poorest in a district which has a history of drought and famine; we have commissioned an

independent study into food insecurity and vulnerability in Lanjigarh and it give a good insight into

the lives of the poor who are our neighbours.

The diagram below shows the feedback loop we use to develop the community projects we design

and implement.

We feel that this recommendation is now closed.

Appendix 35 – Integrated Livelihood Development Plan

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Recommendation 3.3.63 Contractor and Community Health and Safety 3.3.63 Undertake a gap analysis against the occupational and community health and safety

requirements set out in the Lender’s Industry Best Practice criteria (specifically the IFC’s General and applicable sector EHS Guidelines) and take appropriate measures to address any outstanding gaps. Target: November 2011

Vedanta is committed to providing a safe working environment for all our employees and contractors and for surrounding communities. The safety management systems at Lanjigarh have been certified to OHSAS 18001 and we remain dedicated to continuous improvement. The VAL Lanjigarh HSE Policy is attached. A gap analysis has been completed as a part of Recommendation 3.2.20 Environment and Social Management and actions arising are included in the action plan associated with this analysis, see Appendix 17 This work will be completed by June 2012 when we expect this recommendation to be closed.

Ref - Appendix 27 – Lanjigarh ES and HS GAP Analysis and Action Plan