AYA Gold & Silver



Project number:


Business sector:

Natural resources

Notice type:


Environmental category:


Approval date:

19 Oct 2022



PSD disclosed:

25 Oct 2022

As permitted by paragraph 2.6 of Section III of the Access to Information Policy, disclosure of this PSD was deferred in accordance with paragraph 1.4.4 of the Directive on Access to Information.

Project Description

Provision of up to USD 100 million senior loan to support expansion and upgrade of its Zgounder silver mine in Morocco, including (i) a new state of the art 2,000tpd processing plant; (ii) a new power line with a renewable energy power purchase agreement; (iii) new wastewater facilities; and (iv) expansion of the underground and open pit mine. The facility will have 6-year tenor. USD 92 million will be underwritten by EBRD of which USD 50 will be syndicated after signing and USD 8 million to be provided from the Clean Technology Fund.

Project Objectives

The project will enable to support an independent mining company in Morocco in strengthening its competitiveness through gains in efficiency, skills, productivity and innovation.

Transition Impact

ETI score: 77

ETI score: 77

The Transition Impact of the Project is expected to derive from the following qualities:

i Competitive: the project will support a technology in line with the international BAT standards and new operational approaches enabling significant efficiency of operations;

ii Green: the project will support refinery circuits, processing plant's tailings & water management upgrade and energy sourcing switch to renewable energy.

Client Information


Zgounder Millennium Silver Mine S.A is a silver mine company owned at 85% by Aya Gold & Silver Inc., while 15% is owned by National Office of Hydrocarbons and Mines ("ONHYM"). Aya Gold & Silver Inc. is a Toronto Stock Exchange-listed Canadian company focused on operation, acquisition, exploration and development of silver and gold deposits.

EBRD Finance Summary

USD 92,000,000.00

Provision of up to USD 100 million senior loan in favour of Zgounder Millennium Silver Mine "ZMSM"  located in the region of Agadir, of which (i) USD 92 million to be underwritten by the EBRD and further reduced by USD 50 million in the syndication process after signing (with the Bank's final hold of USD 42 million), and (ii) USD 8 million (provided from the Clean Technology Fund) The loan will be guaranteed by the Sponsor, Aya Gold & Silver Inc.

Total Project Cost

USD 182,450,000.00

The transaction will be part of AYA Gold & Silver Inc. USD 182.45 million capex plan to further expand its operations in Morocco ("the Project"). The ultimate beneficiary will be Zgounder Millennium Silver Mine "ZMSM" 


Financing Structure:

EBRD support of the project will help to cover a funding gap, structure the transaction to enable mobilise commercial financing required to fund the project

Resource mobilisation:

EBRD will aim to syndicate USD 50m of the loan facility.

Risk mitigation

-   EBRD's long-term relationship with a client provides comfort to the client to be willing to take on more risk and/or finance, enabling outcomes such as innovation or expansion into new markets.

-   EBRD provides comfort to clients and investors, financial or strategic, by mitigating non-financial risks, such as country, regulatory, project, economic cycle, or political risks.

-   EBRD helps the client to mitigate climate governance risks and take climate action, such as to improve its internal corporate governance for managing climate risks.

Environmental and Social Summary

Categorised B (2019 ESP). ESDD was carried out by a consultant and included the review of documentation prepared by the Company, a site visit (together with the Bank) and interviews with Company management and workers. The E&S risks and impacts associated with the expansion of the existing mine and the construction of a 92km, low voltage (60kv) transmission line, were identified and assessed through project appraisal and will be managed through implementation of an ESAP, which has been agreed with the Company. While the expansion project for this mine required a national EIA (permitted in 2022), EBRD has categorised this project category B, considering there is an existing underground mine, the relatively small-scale of the overall mine and due to the fact that the local area has a long history of mine development.  Further, the open pit will be less than 25 ha in surface area, and review of the EIA and the ESDD did not identify significant additional E&S risks. During the project appraisal, additional assessments and documents were prepared to satisfy EBRD's E&S requirements.  This included a Critical Habitat Assessment (CHA) and development of a Stakeholder Engagement Plan (SEP), a Non-Technical Summary (NTS) and a Land Acquisition and Resettlement Framework (LARF).  As the local EIA did not sufficiently cover social aspects, a complementary social baseline study has been commissioned by the Company. The Company will assess and mitigated the impacts of the transmission line, particularly with respect to land and social impacts and biodiversity even though this line will be operated by the national power company.

EBRD's initial involvement in 2015 resulted in various E&S improvements.  In 2020, a management change was made and since then considerable additional effort has been made in formalise and improve environmental, health and safety (EHS) practices and management at the mine.  The Company has a framework Quality, Safety, and Environment (QSE) Management System (MS), which at the operational level is implemented through an HSE program within the mine. An HSE and Communities Policy is available at corporate level. A road map outlining HSE actions to be implemented was developed in 2021. Unfortunately, a fatal accident (contractor) took place in November 2021 at the underground mine. Following the accident, the Company enacted a series of mitigation measures including further training, review of safety procedures, recruitment of an underground safety manager and purchase of equipment to prevent this from reoccurring. The QSEMS and practices will continue to be enhanced and this is reflected in the ESAP including with respect to HSE resources. The Company does not yet have a workers grievance redress mechanism but there are five personnel representatives and a mechanism will be established and implemented soon as per the ESAP. Worker accommodation is available on site and is of good condition, consistent with EBRD Guidelines.

The mine has sourced its main water supply from two natural springs since the early 1980's and will continue to do so for its future operations (an agreement covering this is signed with local communities). An analysis of alternatives was conducted in 2022 to define the water sourcing strategy of the Project. To meet the water requirements of the expanded operations (400,000m3 per year), two new water holding/balancing reservoirs will be constructed; these reservoirs will be topped up using surface water when the Zgounder river flows (during precipitation events) via pumps installed behind two additional walls to be constructed on the river, which will restrict water flow and allow for abstraction.  A review of the water quality results from the mine's monitoring programme indicates that there appears to be elevated metals and metalloids in the surface water (above Moroccan limits for potable and irrigation use, and not unusual for a mineralised area like the mine site) but that by 1km down gradient of the mine the water quality is suitable for irrigation.  There is no use of water by local communities within 1km downstream of the mine. The Project will not discharge wastewater, and contamination of water will be prevented by runoff retaining infrastructure. With regards to air emissions, the flux mixing system and the refinery (smelting furnace) will both be connected to a dust collection system. A Waste Management Plan is in place and is being further enhanced to cover the new operation. The BAT for the non-ferrous metals industries apply to the Project. The BAT gap analysis concluded that the Project process facilities align with most BAT requirements, and exceed others, and the implementation of the ESAP commitments will bring the facilities into full alignment. The Company has committed to developing the new tailing facility according to the Global Industry Standard on Tailing Management. Existing tailings facilities will be closed and rehabilitated. The company is enhancing its emergency response plan.

The nearest settlements to the mine include six villages (located between 1.3 and 2.7km from the mine). The wider area is used for grazing or crossing to grazing sites. Due to the local arid conditions and resulting low biomass density the overall grazing area is vast.  A temporary land occupation contract was signed between the Company and local authorities, representing the ethnic groups (as the land is communal land). The Project will not require additional permits/leases, nor additional land take as the land needed falls within the current footprint defined by the contract. For the transmission line, land take is needed for pylons (approx. 300 pylons). Land surveys including an inventory of land plots, affected people, and compensation are being carried out according to Moroccan legal requirement and the LARF (aligned with PR5). There is no evidence of any cultural heritage elements at the mine site. The presence of cultural heritage elements will be further assessed as part of the complementary social baseline study.

As per the high level Critical Habitat Assessment conducted in August 2022, which considered secondary data and data from rapid surveys by the CHA team, it is unlikely that critical habitat exists at the mine site or along the transmission line route. The CHA indicates that no migratory or congregatory trigger species are expected the study area. Three bird species may be present on the Moukhtar Soussi Reservoir during the rainy season; further surveys would be required to confirm this (the reservoir will not be directly affected by the project but is hydrological linked -30km i to the mine site). Spring botanical surveys will also be undertaken to verify the presence or likely absence of five key species. If present, a well-implemented biodiversity action plan would avoid and reduce impacts and enable a no net loss or a net gain, as required, to be achieved. These additional biodiversity surveys are included in the ESAP. The most significant plant species endemic to the region is the argan tree, which is the key species of the Biosphere Reserve De I'Arganerie (a UNESCO Biosphere Reserve), located to the west of the mine site, and that will be crossed by the transmission line. This area will likely qualify as a Priority Biodiversity Feature (PBF) as per PR6 and  the transmission line route will have to be mapped by a biodiversity expert to ensure that  the pylons avoid locations and potential impacts to  the  argan trees to ensure a no net loss (required by the ESAP).

Grievances from affected communities are treated informally on an ad hoc basis and mostly channelled by local authorities or local leaders of the communities employed by the mine. The Company will implement a formal grievance mechanism, as reflected in the SEP and ESAP. The Company has enhanced its engagement activities since 2020 and this will be continued through SEP implementation and verified by our monitoring.

The Bank will monitor closely implementation of the ESAP, through review of annual E&S Reports as well communications with the Company and regular site visits.

The national EIA, Stakeholder Engagement Plan (SEP), the Non-Technical Summary (NTS) and the Land Acquisition and Resettlement Framework (LARF) are available on the Company website.



Technical Cooperation and Grant Financing

A TC will aim to review the client's current practises regarding CCG against international best practices and propose relevant improvement and mitigation measures. Up to EUR 75,000 will be mobilised from the CTF Facility to finance the TC on a 85/15% co-sharing basis with the client. 

Company Contact Information

Ugo Landry-Tolszczuk
+1 (647)-919-2227
1320 Graham, suite 132 Ville Mont-Royal, QC H3P 3C8

PSD last updated

25 Oct 2022

Understanding Transition

Further information regarding the EBRD’s approach to measuring transition impact is available here.

Business opportunities

For business opportunities or procurement, contact the client company.

For business opportunities with EBRD (not related to procurement) contact:

Tel: +44 20 7338 7168
Email: projectenquiries@ebrd.com

For state-sector projects, visit EBRD Procurement:

Tel: +44 20 7338 6794
Email: procurement@ebrd.com

General enquiries

Specific enquiries can be made using the EBRD Enquiries form.

Environmental and Social Policy (ESP)

The ESP and the associated Performance Requirements (PRs) set out the ways in which the EBRD implements its commitment to promoting “environmentally sound and sustainable development”.  The ESP and the PRs include specific provisions for clients to comply with the applicable requirements of national laws on public information and consultation as well as to establish a grievance mechanism to receive and facilitate resolution of stakeholders’ concerns and grievances, in particular, about environmental and social performance of the client and the project. Proportionate to the nature and scale of a project’s environmental and social risks and impacts, the EBRD additionally requires its clients to disclose information, as appropriate, about the risks and impacts arising from projects or to undertake meaningful consultation with stakeholders and consider and respond to their feedback.

More information on the EBRD’s practices in this regard is set out in the ESP.

Integrity and Compliance

The EBRD's Office of the Chief Compliance Officer (OCCO) promotes good governance and ensures that the highest standards of integrity are applied to all activities of the Bank in accordance with international best practice. Integrity due diligence is conducted on all Bank clients to ensure that projects do not present unacceptable integrity or reputational risks to the Bank. The Bank believes that identifying and resolving issues at the project assessment approval stages is the most effective means of ensuring the integrity of Bank transactions. OCCO plays a key role in these protective efforts, and also helps to monitor integrity risks in projects post-investment.

OCCO is also responsible for investigating allegations of fraud, corruption and misconduct in EBRD-financed projects. Anyone, both within or outside the Bank, who suspects fraud or corruption should submit a written report to the Chief Compliance Officer by email to compliance@ebrd.com. All matters reported will be handled by OCCO for follow-up. All reports, including anonymous ones, will be reviewed. Reports can be made in any language of the Bank or of the Bank's countries of operation. The information provided must be made in good faith.

Access to Information Policy (AIP)

The AIP sets out how the EBRD discloses information and consults with its stakeholders so as to promote better awareness and understanding of its strategies, policies and operations following its entry into force on 1 January 2020. Please visit the Access to Information Policy page to find out what information is available from the EBRD website.

Specific requests for information can be made using the EBRD Enquiries form.

Independent Project Accountability Mechanism (IPAM)

If efforts to address environmental, social or public disclosure concerns with the Client or the Bank are unsuccessful (e.g. through the Client’s Project-level grievance mechanism or through direct engagement with Bank management), individuals and organisations may seek to address their concerns through the EBRD’s Independent Project Accountability Mechanism (IPAM).

IPAM independently reviews Project issues that are believed to have caused (or to be likely to cause) harm. The purpose of the Mechanism is: to support dialogue between Project stakeholders to resolve environmental, social and public disclosure issues; to determine whether the Bank has complied with its Environmental and Social Policy or Project-specific provisions of its Access to Information Policy; and where applicable, to address any existing non-compliance with these policies, while preventing future non-compliance by the Bank.

Please visit the Independent Project Accountability Mechanism webpage to find out more about IPAM and its mandate; how to submit a Request for review; or contact IPAM  via email ipam@ebrd.com to get guidance and more information on IPAM and how to submit a request.


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