follow the requirement

Authors, Dr Rowena Olegario, Case Study Editor, Dr William Harvey, Research Fellow, and Milena Mueller, DPhil Candidate at the Oxford University Centre for Corporate Reputation.

© University of Oxford 2011

The University of Oxford makes no warranties or representations of any kind concerning the accuracy or suitability of the information contained herein for any purpose. All such information is provided “as is” and with specific disclaimer of any warranties of merchantability, fitness for purpose, title and/or non-infringement. The views expressed are those of the contributors and are not necessarily endorsed by the University of Oxford.

The Oxford University Centre for Corporate Reputation would like to thank QMM/Rio Tinto for their co-operation in the writing of this case study.

Saïd Business School cases

QMM/Rio Tinto in Madagascar

Case A: Protecting the Island’s Biodiversity Oxford University Centre for Corporate Reputation

MAY 2011

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QMM/Rio Tinto in Madagascar

CASE A: Protecting the Island’s Biodiversity

The potential for impact on biodiversity makes our projects potentially sensitive for regulators, local communities, investors, non government organizations and employees. Rio Tinto’s long term success depends on our ability to understand and manage these issues.

Rio Tinto, Annual Report 2008

In 1986 QMM (QIT Madagascar Minerals), a subsidiary of the Rio Tinto mining group, started an exploration program for heavy mineral sands along the eastern coast of Madagascar. The exploration led to the discovery of three economically viable mineral sand deposits in the Anosy region near Fort Dauphin, an undeveloped area on Madagascar’s southeastern coast. Mineral sand mining involves extracting sand, up to 20 metres deep, by means of a floating dredge. For this, the vegetation cover of the mining area has to be removed. Sand mining is a straightforward process, but from a reputational perspective, the location of the mine made it one of the most sensitive projects that Rio Tinto had ever attempted. Madagascar

is considered one of the world’s 25 biodiversity hotspots, with a very rich collection of species that exist nowhere else in the world. Hundreds of species of mammals (including lemurs), reptiles, amphibians, and birds can be found there that are unique to the island nation. In recent times, the country has lost some 75 percent of its native flora species due to human activities.1

The area where the ore deposits were identified happened to be in

one of the ecologically most diverse regions of Madagascar. Before the mining project could proceed, QMM - which is 80 percent owned by Rio Tinto and 20 percent owned by the government of Madagascar - had to understand the potential impact its mine would have on this sensitive environment. It also had to demonstrate to sceptical outside observers that its actions would contribute economic benefits to the region while leaving no lasting environmental and social harm.

From 1989 to 1992, external consultants working for the company confirmed that there were three types of environments in the proposed mining sector: the littoral forest, the wetlands and the open degraded land. Littoral forest is a subtype of rainforest that occurs along the sandy coastal plain of the Anosy region. It harbours a great diversity of flora and fauna with many

Ilmenite Mine, Fort Dauphin © Photo Oxford University Centre for Corporate Reputation

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endemic plant species, as well as vulnerable and endangered wildlife species. Several villages are adjacent to the proposed mining site, but there were no dwellings on the sites themselves. Villagers relied heavily on the forest and wetlands for many of their everyday survival needs – wood for building and cooking, medicinal plants, basketry material, fruit, and game. The site threatened a vital source of survival for these local people, but environmental studies also found that their subsistence activities were responsible for the area’s severe deforestation.2

By the mid-1990s international conservation groups had become aware of Rio Tinto’s exploration activities in Madagascar. John Buchan, a lemur expert at the London Zoo, warned that the mines could lead to the extinction of an endangered lemur species. NGOs such as Friends of the Earth started a campaign against the mining project. “Destroying these unique forests for the sake of a quick profit is madness,” the NGO wrote in 1996. “The international community should mobilise resources for developments that will help and not wreck the local economy and irreplaceable wildlife.” 3 This opposition was part of the powerful global environmental movement that campaigned against climate change, the overexploitation of natural resources and the destruction of ecosystems, among other causes. The origins of this “green agenda” can be traced back to the 1970s, when a generally adversarial campaign against negative business externalities such as pollution was launched. Since then the movement has gained currency. An important milestone was the 1992 Earth Summit in Rio de Janeiro where more than 170 nations discussed sustainable development. The focus of environmental concern shifted from local to global issues, and environmental groups increasingly sought partnership solutions with business. 4

The Strategy

In 1996, Rio Tinto established a full-time environmental and conservation team in Madagascar, led by Manon Vincelette. The company had recruited the Canadian-born forest engineer from Conservation International, an NGO that focused on teaching local communities to make conservation a part of their livelihoods rather than simply trying to preserve places intact. Vincelette did not see a natural contradiction between conservation and economic development: “Even if you love forest and conservation, you should never fight development,” she argued. “ . . . I think this country needs development. I mean, it has the potential. It has resources.” 5

The biodiversity team included both expatriates like Vincelette and Malagasy technicians like Christian Rarivoson, who was hired to be Superintendent of Mine Rehabilitation. They learned their jobs on the ground, through experimentation and trial-and-error. “In 1996, QMM did not yet know how to rehabilitate sites,” recalled Rarivoson. “It took five years of testing.” Vincelette described how the team carried out a mini rehabilitation on an area of only several square metres to see if extracting ilmenite and zircon from the sandy soil would have any effect on plant life (it didn’t).

As part of the team learning process, QMM sent Rarivoson and others to a coastal dune rehabilitation project in Richards Bay, on the eastern coast of South Africa. Richards Bay Minerals, a company jointly owned with BHP Billiton (but managed by Rio Tinto), was successfully restoring the forest ecosystem in that region. Recalling his initial impressions, the Madagascar-born Rarivoson had felt that it was “like landing on the moon!” The scale of the rehabilitation and the means employed impressed him enormously. But he and his colleagues soon discovered that the ecological conditions in Richards Bay were not the same as in Fort Dauphin. “The properties of the soil are better at Richards Bay,” said Rarivoson. “That site was

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very remote from town and people didn’t use the natural resources there” the way they did in Fort Dauphin. Invasive species were worse in Fort Dauphin, as was the danger of brush fires. 6

The team researched the biodiversity of the littoral forests around Fort Dauphin, not only in the proposed mining sites but also in neighbouring areas. Team members sought active engagement with local, national and international stakeholders. They established collaborations with Malagasy and international universities, research institutes, and NGOs such as Kew Gardens, Birdlife International, Conservation International, Flora and Fauna International and the Missouri Botanical Gardens.

As the team were to learn repeatedly, Madagascar’s unique ecosystem, and the proposed mine’s close proximity to a number of villages, limited the amount of learning that could be transferred from Rio Tinto’s sites elsewhere.

NGO pressure against the project continued. Friends of the Earth and World Development Movement lobbied Rio Tinto’s institutional shareholders to withdraw support from the project:

Large institutional investors need to consider carefully the environmental and social consequences of their investment decisions. Insurance and pension companies' customers don't want their money used to sacrifice the environment for profits. They know it is ultimately a self-defeating strategy. That is why the investors need to use their influence to raise standards as well as dividends. 7

In 1998, a framework was agreed between the company and the government that provided a reference point and general direction for QMM’s proposed projects.8 Between 1998 and 2001, QMM did a Social and Environmental Impact Assessment (SEIA), the first of its kind ever conducted in Africa. The company felt it was important to involve the public in assessing the problems associated with the proposed mine. As part of the consultation process, the government established an independent council. Local people from the 120 or so villages that surrounded the site were also invited to respond, and their comments were recorded in registers. QMM took the comments seriously. When residents objected to the original site for the new port, the company reassessed many other potential sites and finally agreed to move it to Ehoala, located 25 km away. It also agreed to divert a major road away from the town of Fort Dauphin.9

The assessment paved the way for the government of Madagascar to issue an environmental permit in 2001 for what is now known as the Mandena mine, the first of three proposed sites. This environmental permit required QMM to comply with explicit social and environmental obligations during each project phase. Future mining activities in the two other mining sites would also involve the issuance of environmental permits based on an SEIA. In 2001, a number of internationally renowned NGOs and biodiversity experts founded an independent advisory committee at QMM’s initiative to review its strategy and on-the-ground conservation activities. QMM also partnered with a number of respected organizations to work on high-visibility projects on biodiversity. Partner organisations included the US Agency for International Development, which provided matching funds with QMM ($6 million over four years) for forest conservation, nurseries, reforestation and social programmes. QMM also worked with Kew Gardens and the Missouri Botanical Gardens on the publication of a Littoral Forest Flora Field Guide. The company contributed indigenous seed lots to Kew Gardens’ Millennium Seed Bank, the largest plant conservation project in the world.

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QMM proposed a Project Environmental Management Plan (PEMP) for the Mandena site in 2002. The Plan consisted of a list of obligations that Rio Tinto put together, in accordance with the framework that had been agreed with the government in 1998 as well as with Malagasy laws. Ny Fanja Rakatomalala, a Malagasy who has been president of QMM since 2008, described the Plan as “holistic,” in that it included environment, social, and economic considerations and outlined the commitment from local authorities. The Plan “sets the boundaries of responsibilities,” he explained. 10

Included in the Plan were commitments to the ecological restoration and reforestation of mined areas and the establishment of a conservation area of littoral forest and wetlands. The Mandena site had a few remaining forest fragments and some wetland areas, but it consisted

primarily of bare zones due to several decades of deforestation by the local people. To protect the Mandena site’s remaining fragments of littoral forest the Plan ensured the establishment of a conservation site, removed from the mining activities and involving the communities and government, to help

preserve native flora and fauna. The plan also provided for the rehabilitation of the mining site by planting fast-growing species, such as eucalyptus and acacia trees, that would serve as a sustainable source of wood for local residents.

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International conservationists questioned if the proposed measures would be enough. Friends of the Earth wrote in 2007:

Rio Tinto claim that they will restore the area to its former glory once dredging is complete. But they plan to use non-native plants in this. The conservation areas set up are too small and may not even be able to sustain their current species diversity in the future. The project will threaten the delicate mix of species that have evolved on the island making it so unique. 12

Implementation

In 2005, nearly two decades after starting its exploration of Madagascar’s eastern coastline, Rio Tinto took the investment decision to go ahead with the mining project. The construction phase was initiated in 2006, with mining operations projected to start in 2009. QMM’s environmental team aimed to achieve a net positive impact (NPI) on the region’s biodiversity. This meant that the company had to demonstrate that its actions had a positive effect that outweighed the inevitable negative effects associated with mining. The idea for NPI originated in 2003 in a working group within Rio Tinto that included Manon Vincelette. Madagascar was chosen as the first site for implementing NPI, with the view of eventually

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rolling it out to the rest of Rio Tinto. 13

Johny Rabenantoandro was appointed Head of Flora Biodiversity and Ecological Restoration in 2003. A Malagasy who had worked at Missouri Botanical Gardens before joining QMM, Rabenantoandro had built a reputation for competence and integrity within the company and among local people and NGOs.

14 He explained that only 10 percent of the littoral forest remained, and that without QMM’s conservation efforts even this would not have survived – an assessment that many NGOs and local people confirmed.15

The company designated the largest forest remnant in Mandena, an area of about 230 hectares, as a conservation zone. Under Rabenantoandro’s supervision, QMM established Madagascar’s largest native tree nursery and set up a program of seed storage and propagation within the zone. Restoration is a painstaking process involving the collection of seeds, carefully gathered by workers sifting through the topsoil by hand or from plants in the nursery. QMM also restored and reforested some of the very degraded areas.

QMM created non-invasive plantations to provide locals with wood for fuel. According to Rarivoson, 3,000 hectares of eucalyptus trees will be required to meet the needs of the residents of Fort Dauphin in the next few years. The use of charcoal from eucalyptus trees is widespread in Madagascar. Even in the relatively more developed area around Tana, 80 percent of the population rely on these energy sources for basic activities such as cooking. The company researched the viability of non-timber forest products and monitored and managed the animals living in the affected area. From 2002-2009, QMM co-managed the conservation zone with the two communes that bordered it, and the local forestry service. The co-management contract was meant to empower local communities to protect and manage the resources on which they depend. Vincent Mbola, a local resident who was president of the conservation zone’s management committee, reported that people were happy to hear about the plan. But even so, “it was hard to explain” the details to them. 16

QMM engaged in a consultation process with interested local parties, including those who opposed the project. The agreement was based on a customary Malagasy contract called a dina that provides the basis for mutual consultation and participation to avoid potential

conflict. Although originally informal, dinas have attained formal legal status within Madagascar.

Beginning in 2010, QMM ceded more and more of the management responsibilities for the conservation zone to locals. Seventeen people sat on the board of the management committee. They hired and supervised the eight security guards who patrolled the zone to prevent local residents from extracting wood and other forbidden products. QMM paid half of the security guards’ wages, and the rest was paid by the management committee with income earned from honey production and tourism. 17 Workers provided

support for 2,000 hectares in the mining area, including helping people drive their cattle (zebu)

Seeds collected by QMM and workers within the conservation zone, Fort Dauphin © Photo Oxford University Centre for Corporate Reputation

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across roads when the company was operating bulldozers and other machinery there. A total of 75 staff managed the biodiversity programme, of which 60 were locals. 18

The biggest challenge, according to Mbola, was preventing the intrusion into the forest by local people. Protocol required the mayor of the commune to communicate the new prohibitions to the residents and external parties. People who were caught were charged and fined, with the commune and the Water and Forest Department responsible for administering penalties. The number of intruders caught and formally charged was small -- a total of only six people in 2009. But the new rules caused some anger. “People know it’s forbidden [to extract resources from the forest], but they say they are starving,” said Mbola. He felt that the community generally understood the reasons behind the restrictions, and that only about 5 percent opposed them. Mbola surmised that the bad feelings among this unhappy minority arose because they “feel they don’t have an opportunity to benefit from the company.” 19 QMM’s own survey showed that the residents around the protected zone did not always understand the rationale behind the dina and that intermediaries sometimes miscommunicated the company’s intentions.20

According to Rabenantoandro, the key to continued success in the area of biodiversity is to have a long-term entity on site, in Fort Dauphin, to see the various programmes through. This can be a company, he said; but equally, it can be an NGO or other organisation. But as a representative of Azafady, a local conservation NGO, acknowledged, NGOs in Fort Dauphin did not work together much. A Civil Society Platform that used to be in place enabled such groups to share ideas, but it no longer existed because of lack of funding. As a result, NGOs worked together on an ad hoc basis only and tended to compete for status and the meagre amounts of available funding. “They need to pool their resources together more,” said the Azafady representative, “otherwise, QMM is the only long-term organization in place.” She added that there was absolutely no money in government to fund biodiversity initiatives.

21

Given the realities of Madagascar, and QMM’s immense resources compared to the government and local not-for-profit organisations, the mining company appears to be the best long-term candidate. Rio Tinto has made a 40-year commitment to the mine in addition to the nearly twenty years it spent in the area during the exploration phase. Its investment in ensuring the survival of Fort Dauphin’s biodiversity has been substantial. According to its own estimates, such programmes have cost Rio Tinto about 10 percent of the expected revenues from the mine.

22 By 2010, QMM had invested $15 million in local communities to attain sustainability, with a significant portion spent on educating the local population about how to incorporate biodiversity practices into their traditional activities.23

Investment within QMM itself was also significant. As of 2010, Manon Vincelette’s department had a budget of $3 million, about 5 percent of QMM’s total budget. With 85 employees, the department is one of the company’s largest. Vincelette reported directly to QMM’s president, and the department lay outside of operations, so it had a fair amount of autonomy within the company. She said the department had the authority to stop projects that were deemed to be in violation of the company’s biodiversity goals. The costs of maintaining such a large department were justified because, as Vincelette pointed out, the mine itself could never have existed if the sustainability programmes had not been implemented.

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Perspectives

Rio Tinto considered its concept of net positive impact (NPI) to be pioneering, and it hoped to extend it to other countries in which it operated. The company’s experiences in the littoral forests of Madagascar served as an example of what it termed “leading practice.” Its biodiversity programmes were lauded by outside bodies. In 2009, QMM won the prestigious Nedbank Green Mining Awards for its commitment to the environment and biodiversity and its work towards net positive impact. 25

But the implementation of QMM’s biodiversity programme continued to inspire mixed reactions. Some international NGOs charged that there was a lack of understanding of the biodiversity programme among local communities and that QMM’s activities disrupted the everyday lives of local people:

The adjudication of the awards involved an interview with an expert panel and a site visit by the judges to QMM in Fort Dauphin.

New conservation rules have not been properly communicated, leading to the criminalisation of some local people [for continuing to extract resources from the conservation area] and divisions within and between communities. Some locals say they have lost out to conservation areas, not only due to loss of resources but also because they place an additional management demand on them with insufficient remuneration. 26

The NGO ClientEarth argued that the biodiversity programme would become irrelevant without successful implementation on the ground:

The Rio Tinto [Annual 2008] Report provides no substantive, balanced detail on the nature of the strategy, how it is being implemented in Madagascar, or any problems that are being experienced. The Companies Act of 2006 requires details not only of the policies of the company in relation to environmental matters (including the impact of the company’s business of the environment), but also details of the effectiveness of those policies. 27

Representatives from Azafady, the local conservation NGO, voiced concern that the mine “will take a good deal more of the forest.” They pointed out that QMM confined its activities to the conservation zone and were ignoring the remaining forest fragments. Even so, Azafady acknowledged that NGOs needed to collaborate with the mining company to achieve their common objectives, and that a number of QMM people such as Johny Rabenantoandro were working effectively with locals to ensure the forest’s survival. 28

Madagascar’s national environmental office (ONE), an independent governing body that is mandated by the national government, regulates the “disturbance impact” to natural resources and biodiversity of some 14 projects in Madagascar. ONE spent a large portion of its resources monitoring QMM’s activities in and around Fort Dauphin. Its chairwoman said that local residents had positive perceptions of QMM’s biodiversity programmes and the development of Fort Dauphin. But she added that a negative perception persisted that the rehabilitation of the mine had not yet begun. ONE also oversaw the impact on natural resources (fish) near the weir that QMM had built at the mouth of Lake Ambavarano, located near Fort Dauphin. The weir was installed to prevent salt water coming in from the ocean which would prevent the rehabilitation of the site after the mining. The chairwoman said that it was “sometimes difficult to find consensus” with QMM. It took 18 months, for example, to resolve the resource decrease

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around the weir. The expectation, she continued, was that everything is not perfect, but if the disagreements had been resolved more quickly, “there would be no problems now.” 29

Conclusion

The QMM ilmenite mine is critical to both Rio Tinto and the local communities within Madagascar’s Anosy region. According to a researcher who has studied the project in depth: “QMM is one of the first and most advanced Greenfields mining project developments in the emerging market context for Rio Tinto in recent history, and therefore is a significant stepping stone for the organisation. This relatively small project will provide much needed experience for Rio Tinto’s significantly larger Greenfield development such as the US $10 billion iron ore project currently underway in Guinea.” He adds that to date, the mine is the only considerable single direct investment, public or private, in the region. 30

The QMM mining project presented Rio Tinto with difficult environmental challenges. From the outset the potential negative impact on Madagascar’s vulnerable biodiversity system was scrutinised by external stakeholders, especially environmental NGOs. QMM responded with a complex biodiversity strategy that is regarded by Rio Tinto and industry observers as the current best practice. Generally, QMM’s biodiversity programmes have been considered successful. But significant concerns were raised around the strategy’s implementation, and NGOs and local bodies continue to push QMM to improve.

It has a massive impact on livelihoods and standards of living, as well as cultural effects that have yet to be fully understood.

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APPENDIXES

Appendix A: About Rio Tinto

Rio Tinto is a combination of two companies: Rio Tinto plc, based in the UK, and Rio Tinto Limited, based in Australia. The British based Rio Tinto Company was formed by investors in 1873 to mine ancient copper workings at Rio Tinto near Huelva in southern Spain. The Consolidated Zinc Corporation was incorporated in 1905 to treat zinc bearing mine waste at Broken Hill, New South Wales, Australia.

The RTZ Corporation (formerly The Rio Tinto-Zinc Corporation) was formed in 1962 by the merger of The Rio Tinto Company and The Consolidated Zinc Corporation. CRA Limited (formerly Conzinc Riotinto of Australia Limited) was formed at the same time by a merger of the Australian interests of The Consolidated Zinc Corporation and The Rio Tinto Company.

RTZ and CRA were unified in December 1995. Directed by a common board of directors, the companies operate as a single entity even though they maintain separate shareholder lists in the UK and Australia. This places the shareholders of both companies in substantially the same position as if they held shares in a single enterprise owning all of the assets of both companies.

In June 1997, The RTZ Corporation became Rio Tinto plc and CRA Limited became Rio Tinto Limited, together known as the Rio Tinto Group. Rio Tinto plc is listed on the London and New York Stock Exchanges. Rio Tinto Limited is listed on the Australian Stock Exchange. Since the 1995 merger, the Group has continued to invest in developments and acquisitions in keeping with its strategy.

From “Who we are,” www.riotinto.com.

Appendix B: Chronology

1986-89 BP Minerals conducts preliminary phase of exploration for ilmenite in southern Madagascar.

1989 Rio Tinto/QMM acquires ilmenite sites from BP Minerals; continues exploration. 1990-92 First phase of social and environmental studies and impact assessment. 1996 Rio Tinto establishes full-time environmental and conservation team, led by

Manon Vincelette. 1998 Framework Agreement signed between Rio Tinto/QMM and government and

ratified by Deputy General Assembly. It provides reference point and general direction for the company’s proposed projects.

1998 – 2001 QMM conducts Social and Environmental Impact Assessment (SEIA) Phase 2,

the first of its kind ever conducted in Africa, and in compliance with Malagasy

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law. Paves the way for government to issue first of three environmental permits.

2001 Presidential elections in Madagascar result in political deadlock that divides the country, leads to unrest, and negatively affects the national economy.

Internationally renowned NGOs and biodiversity experts found

independent advisory committee to review QMM’s strategy and on-the- ground conservation activities.

2002 QMM proposes Project Environmental Management Plan (PEMP) for Mandena

site. Plan consisted of a list of obligations that Rio Tinto put together in accordance with the SEIA and the framework agreement of 1998.

Reforestation programme launched to plant 100 hectares of fast-growing trees

per year to provide locals with wood for their everyday needs.

Dina arranged between QMM and local community concerning the co- management of natural resources and conservation zones around the Mandena mining district.

2003 President Marc Ravalomanana implements wide ranging economic, social, and governance reforms. These include free market privatisation. 2005 Government launches integrated Growth Poles (PIC) project, co-funded with

World Bank, to support regions with strong potential for growth. Anosy is one of three regions identified.

Investment decision from RioTinto to go ahead with ilmenite mine. 2006 Pre-mobilisation and start of construction of roads, port, and mine.

Ravalomanana wins a second term in office.

2007 Government launches Madagascar Action Plan (MAP), a five-year economic program.

2009 Mining operations begin. QMM wins prestigious Nedbank Green Mining Awards for its commitment to the environment and biodiversity and its work towards net positive impact. QMM introduces mystery shopper programme to monitor inflation. Political coup.

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Endnotes 1 Rio Tinto company website, http://www.riotinto.com/ourapproach/17194_features_17019.asp. 2 Panos London, A Mine of Information? Improving Communication Around the Rio Tinto Ilmenite Mine in Madagascar(Panos: London, 2007). 3 Friends of the Earth, “Madagascar Mine Threatens New Lemur Species,” press release, 7 May 1996. 4 Ken Peattie and Martin Charter, “Green Marketing” in Michael J. Baker, The Marketing Book (Oxford: Butterworth-Heinemann, 2003): 726-756. 5 M. Vincelette, et. al., “The QMM/Rio Tinto Project History in Tolagnaro and its Social and Environmental Concepts,” in J.U. Ganzhorn, et. al., (eds.), Biodiversity, Ecology and Conservation of Littoral Ecosystems in Southeastern Madagascar, Tolagnaro (Fort Dauphin) (Washington, D.C.: Smithsonian Institution, 2007): 1-8. 6 Interview, Christian Rarivoson, Superintendent of Rehabilitation of Mine and Head of Union, QMM Mandena offices, Madagascar, July 8, 2010. 7 Tony Juniper in Friends of the Earth, 1997. available at http://www.foe.co.uk/resource/press_releases/19970507100057.html

8 Interview, Armand Zafinandro, Mayor of Fort Dauphin , Madagascar, July 7, 2010. 9 Presentation by Ny Fanja Rakatomalala, President of QMM, Mandena offices, Madagascar, July 5, 2010. 10 Rakatomalala presentation, 2010. 11 QMM, “Ilmenite Project, Social and Environmental Impact Assessment, Environmental Management Plan,” Presented by QMM S.A. to the Madagascar National Environment Office, September 2001. 12 Friends of the Earth, “Mining Madagascar -- forests, communities and Rio Tinto’s white wash,” media briefing, London, October 2007. 13 Telephone interview, Gary O’Brien, President of QMM (2006-2009), August 2, 2010. 14 Interview, Azafady representatives, Fort Dauphin, Madagascar, July 7, 2010. 15 Interview, Johny Rabenantoandro, Head of Flora and Biodiversity and Ecological Restoration, conservation zone, Madagascar, July 6, 2010; interview, Azafady representatives, 2010; interview, Vincent Mbola, President of COGE (management committee of the Conservation Zone), Mandena offices, Madagascar, July 8, 2010. 16 Interview, Mbola, 2010, 17 Interview, Mbola, 2010. 18 Interview, Rabenantoandro, 2010. 19 Interview, Mbola, 2010. 20 Interview, Willy Rasamoelina, Community Relations Manager, Mandena offices, Madagascar, July 8, 2010. 21 Interview, Azafady representatives, 2010. 22 Rio Tinto company website, http://www.riotinto.com/ourapproach/17194_features_17019.asp 23 Presentation by Manon Vincelette, Head of Community Affairs, Biodiversity and Sustainable Development, Mandena offices, Madagascar, July 5, 2010. 24 Vincelette, presentation, July 5, 2010. 25 Nedbank is a South African capital firm. 26 Panos London, A Mine of Information?, p. 14.

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27 ClientEarth, “Referral to the Financial Reporting Review Panel, Re: the Rio Tinto Group Annual Report 2008,” 2010. 28 Interview, Azafady, 2010. 29 Interview, Mamialisoa Andrianasolo, Chairwoman of ONE, Fort Dauphin, Madagascar, July 7, 2010. 30 Tobias Puhlmann, “The Impact of QIT Madagascar Minerals (QMM) on Local Economic Development of Fort Dauphin, Madagascar,” MBA thesis, Graduate School of Business, University of Cape Town, December 2008, pp. 14, 18.