On 22 February 2023, the Government of RA signed a tripartite Memorandum with the Eurasian Development Bank and “Lydian Armenia” CJSC to resume the exploitation of the Amulsar gold quartzite mine.
According to the memorandum, “Lydian Armenia” CJSC donated 12.5% of its shares to the government, by virtue of which the Government undertook corporate policy commitments together with its partners in the Amulsar project – the Eurasian Development Bank and “Lydian Armenia”.
We express our profound concern over the relaunch of a project that was negatively assessed by specialized representatives of the Armenian and European civil society in terms of the protection of fundamental human rights, and also recognized as economically unsustainable and destructive to local communities and the environment.
Thus, in June 2022, the International Federation of Human Rights, the international network “CEE Bankwatch Network” and the Civil Society Institute published a report entitled “Amulsar: Human Rights Violations and Environmental Negligence in the Search for Gold”.
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The report contains ample evidence of serious violations of a wide range of rights during the operation of the Amulsar gold mine, ranging from substantive and procedural environmental rights to social, economic and political rights of the affected individuals and communities. Moreover, there are examples of significant barriers to justice and effective remedies for those right-holders who have so far unsuccessfully sought redress through judicial and extrajudicial mechanisms.
There is also convincing evidence that the Armenian Government repeatedly violated international law regarding the Amulsar issue and did not protect the rights to health, a healthy environment, peaceful assembly, freedom of speech and information, to participation in decision-making processes and access to justice.
Although most of these human rights violations had been committed by the authorities before the Velvet Revolution of 2018, unfortunately, the new Government has not taken sufficient steps to protect the environment and human rights defenders, the rights of the people of local communities, or to eliminate the violations of the past.
The reports of the UN Special Rapporteurs on Human Rights and the Compliance Committee of the Aarhus Convention call on the Armenian state to provide substantive consultation on the Amulsar project.
In addition, the UN Human Rights Commission’s 2020 report on Armenia contains Armenia’s recommendations on civil and political rights and anti-corruption measures, and requires that the state “provides detailed information on corruption allegations surrounding the Amulsar gold mine.”
We also express our astonishment regarding the involvement of the capital of the Russian Federation through the Eurasian Bank, in which the latter has a 44% share, in the Amulsar re-exploitation plan. It contains the risk of increasing Armenia’s already impermissibly high dependence on Russia, as well as the risk of application of EU and other international sanctions to this company in the future.
We appeal to the Government of the RA, the Delegation of the European Union to Armenia, and the EU member states – the parties to the Comprehensive and Enhanced Partnership Agreement – urging them to support the Armenian civil society in their fight for the protection of the rights of the people of local communities.
We also urge the named parties to assess the Memorandum having regard to the sanctions against the Russian Federation and the revealed facts of human rights violations in the Amulsar project, to facilitate the conduct of broad public discussions on the Amulsar project, and to disclose the terms and obligations of the Memorandum, as well as any other information on the relevant classified facts.