EBRD would like to take this opportunity to respond to the Business and Human Rights Report both from a general E&S governance viewpoint and to provide some clarifications on the specific projects mentioned in the report. There are specific allegations made which do not reflect EBRD’s involvement or experience of the Projects discussed, as clarified below...

• Zangezur Copper Molybdenum Combine (Armenia): EBRD has participated in a Bond raised by ZCMC, the proceeds of which are to finance environmental improvements at the mine. EBRD is in no way linked to mining operations or the historical legacy issues such as tailings management cited in the report. However, an E&S Action Plan was included in EBRD’s participation agreement and an improvement in E&S standards at the mine is being realised...
• KazMunaiGas (Kazakhstan): EBRD has provided a loan to the Atyrau oil refinery for environmental improvements and upgrade of vital environmental mitigation infrastructure such as wastewater treatment. While Atyrau refinery is a subsidiary of KMG, EBRD is in no way linked to the other KMG assets or issues cited in the report...
• Tengizchevroil (Kazakhstan) (via investment in infrastructure). EBRD has not financed any aspect of the TCO project in Kazakhsthan and EBRD takes the opportunity to clarify the situation by way of this response.
• North Caspian Operating Company (Kazakhstan) (via investment in infrastructure): Similarly to TCO, EBRD takes the opportunity to clarify that EBRD has not financed the NCOC in any form.
• Lydian Armenia: EBRD would like to clarify that no element of the Amulsar mine was project or debt financed by EBRD, however, EBRD was a minority shareholder in the parent company until the point of liquidation as a result of forced mine closure. A formal review of EBRD’s shareholding participation is currently underway and will be disclosed at the conclusion of that process. However, the issues cited in the report - such as impacts associated with cyanide use - should be corrected as the mine construction did not reach conclusion and no cyanide was ever deployed at Amulsar. Equally, the project ESIA should be referred to with regard to all other E&S issues cited...