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Indigenous Engagement Strategy Toolkit

Our Indigenous Engagement Strategy Toolkit can be used as a framework or tool to assist proponents as they develop their Indigenous Engagement Strategy. 

NAIF Staff CEO Craig Doyle Indigenous Outcomes Director Darren Chong And Senior Associate Jamari Buli Pointing To IES Report In Park
While the Indigenous Engagement Strategy Toolkit can be employed as a framework or instrument to guide proponents through the development process, it's crucial to understand that its purpose is not to impose restrictions or dictate the precise content of an IES.

The responsibility for shaping and executing the IES rests squarely with the proponent, who is accountable for delivering a strategy that aligns with their specific project and goals.

Objective

NAIF financed projects are varied in a number of ways including by sector, location or local demographics and so to the Indigenous Engagement Strategies are also varied and there is not a one-size-fits-all solution.

The intent of the Indigenous Engagement Strategy is to transform good intentions into a clear, culturally appropriate, locally contextual plan with tangible commitments. The strategy may also aid in structuring engagement with the appropriate stakeholders who will be vital to the implementation of the strategy.

The following information should be read with the Indigenous Engagement Strategy Guideline.

Please find below templates and examples:

What is a Satisfactory Indigenous Engagement Strategy?

A satisfactory Indigenous Engagement Strategy is one that provides appropriate opportunities for participation, procurement and employment which reflects the regional Indigenous community commensurate with the nature, scope and location of the project, and the capacity of the proponent.

The focus is on ensuring the strategy is realistic, achievable and considers any existing approach to Indigenous engagement adopted by the proponent and how this can be best applied to the project.

This toolkit provides advice to proponents in the development of a satisfactory Indigenous Engagement Strategy.

Tips for Writing Your Strategy

You may have some ideas for your Indigenous Engagement Strategy and are eager to get straight into writing. We would recommend you consider a few tips first. 

 Tip 1

If this is unfamiliar territory for you or your organisation, do not be concerned. NAIF’s existing portfolio of proponents were at different stages of their Indigenous engagement journey at the time of writing their IES but were all able to successfully deliver a satisfactory IES which was tailored to the opportunities of the proposed project and their capability. We would recommend proponents who are inexperienced with Indigenous engagement or Aboriginal and Torres Strait Islander cultures to start by building a baseline understanding and cultural capability. We have listed a few external resources as a start below, but this is not intended to be exhaustive.

 Tip 2

The NAIF Indigenous Outcomes Team (IOT) who will review and endorse your IES are able to review multiple drafts and discuss any ideas you may have. The IOT can also connect you to key networks and agencies who may also help in developing and delivering your IES.

 Tip 3

Like any strategy it is important to have a strong foundation underpinning it. We recommend practically thinking about how you may achieve what you put in your IES and to take ownership of what is contained therein as this will be your strategy to deliver.

 Resources:

Inclusive Language – Aboriginal and Torres Strait Islander Peoples - Australian Government Style Manual

Demonstrating Inclusive and Respectful Language

Share Our Pride

What Does an Indigenous Engagement Strategy Look Like?

The Indigenous Engagement Strategy has two components:

  1. Component One.
    The main body is the written component and should have the detailed background information and the strategies and methodologies of how the Proponent aims to achieve local Indigenous participation, employment, and procurement outcomes.
  2. Component Two.
    The Schedule of Obligations is attached to the main strategy document which is a table outlining clear commitments and timeframes that are highlighted in the Indigenous Engagement Strategy. The commitments outlined in the Schedule of Obligations will be what the Proponent reports on throughout the life of the NAIF loan.

Main Body of the Strategy

Acknowledgement of Country

 Expectation: Include an Acknowledgement here for the Traditional Owners of where the project is proposed or where you operate from or more generally.

 Examples: [Insert Proponent] acknowledges all Aboriginal and Torres Strait Islander Traditional Custodians of Country and recognises their continuing connection to land, sea, culture and community. We pay our respects to Elders past and present.

Helpful Tip: You can use resources in section 2 ‘Participation’ to identify Traditional Owners and refer below for more information about acknowledgements.

 Resources:

Reconciliation Australia - Acknowledgement of Country and Welcome to Country

1. Introduction

This is an opportunity to introduce the proponent and give a brief overview of the project and opportunities for Indigenous involvement.

Example Structure

1.1 About Proponent

 Expectation: Introduce the proponent, what you do, your story, purpose, industry etc.

1.2 About Project/Program

 Expectation: Introduce the project. Include map, if possible, of the project footprint and any native title/Traditional Owner boundaries.

1.3 Indigenous Engagement

 Expectation: Detail (if any) experience with Indigenous engagement and any existing initiatives such as a Reconciliation Action Plan, Indigenous employment strategies, Indigenous procurement initiatives etc. Include case studies if possible.

1.4 Demographics of Region

 Expectation: Provide a snapshot of the local demographics in the footprint area including relevant data around Indigenous populations and growth, Indigenous working age population, local Indigenous businesses etc.

 Resources:

Search Census data | Australian Bureau of Statistics

2021 ABS Census

1.5 Opportunities for Indigenous Participation

 Expectation: Provide an overview of the opportunities for Indigenous involvement to be provided through the proposed project. Identify how the project can support Indigenous aspirations and outcomes.

2. Participation

The NAIF Investment Mandate contains a mandatory criterion that proponents are required to meet to be eligible for NAIF finance which states “the project proponent must provide a strategy which sets out objectives for Indigenous participation, procurement and employment that reflect the Indigenous population in the region of the proposed project”.

In this section, you can begin to set out objectives for one of the pillars which is Indigenous participation and insert strategies of how the project will involve and engage Traditional Owners and/or Indigenous stakeholders.

Example Structure

2.1 Traditional Owners/Indigenous Stakeholders

 Expectation: Identify local Traditional Owners and/or relevant Indigenous stakeholders. Outline any existing initiatives or relationships with Traditional Owners and/or Indigenous stakeholders including any formal agreements e.g., Memorandums of Understanding, contracts, agreements subject to Native Title Act and/or the Aboriginal Land Rights (Northern Territory) Act.

 Helpful Tip: There are a number of ways you can identify who the local Traditional Owners and/or relevant Indigenous stakeholders are for your proposed project.

One way is to identify if the location of your proposed project is subject to native title. If it is, there will be several requirements you must adhere to which are established under the Native Title Act. You can learn about native title here:

 Resources:

About native title | AIATSIS

Native Title in Australia — Agreements, Treaties and Negotiated Settlements

To identify if your project is subject to native title see below:

Alternatively, if your project is located somewhere which does not have a native title determination/claim, you can find out who the Traditional Owners are and/or relevant Indigenous stakeholders in other ways. In the Northern Territory (NT), your project may be subject to the Aboriginal Land Rights Act 1976 (ALRA).

You can learn more about the ALRA and Land Councils below:

NT Aboriginal Land and Permits

You can also view these additional resources:

There are also key Indigenous agencies and organisations which can provide further assistance including:

2.2 Engagement Plan

It is important to understand that historical engagement between governments, the wider settler society and Aboriginal and Torres Strait Islander people in Northern Australia, affects contemporary engagement today.

Early experiences may have involved forced displacement, violent conflict and protectionist policies that entrenched discrimination and denied basic rights for Indigenous people. The effects of these historical policies (some of which ended only in the 1970’s) reverberate through Aboriginal and Torres Strait societies and families in Northern Australia to this day. As such, Indigenous people may be wary of governments and non-Indigenous organisations, so it is important to make sure that any engagement with Indigenous peoples considers these factors and that engagement is meaningful and respectful of cultural heritage, protocols, and knowledge.

 Expectation: Establish a purpose and plan for engagement and communication with identified Traditional Owners and/or Indigenous stakeholders.

 Helpful Tip: Once you have identified who the relevant Traditional Owners and/or relevant Indigenous stakeholders are, we recommend planning out how you will engage them. Whether you have an existing relationship or not we would recommend ensuring your engagement methods are effective.

We have included a few external resources on best practice engagement and things to consider before you engage.

 Resources:

2.3 Engagement Principles

 Expectation:  Consider what your guiding principles are for your engagement and Indigenous Engagement Strategy.

 Helpful Tip: You may wish to establish your own charter of principles.

 Resources:

United Nations Declaration on the Rights of Indigenous Peoples

Best Practice Charter for Renewable Energy Projects

Indigenous First Impact Framework | First Australians Capital

Free Prior and Informed Consent:

FPIC Snapshot 2020

International Finance Standards:

International Finance Corporation (IFC) Guidance Note 7 - Indigenous Peoples

Equator Principles - see Principle 5 Stakeholder Engagement

Examples of Principles:
  • Early and meaningful engagement
  • Transparency
  • Centring Aboriginal and Torres Strait Islander people, perspectives, priorities, and aspirations
  • Strengths-based approach rather than a problem to be solved.
  • Respect

2.4 Engagement Methods

 Expectation: Detail your engagement methods. Will you establish an Indigenous Working/Reference Group, formalise a Memorandum of Understanding, will it be face-to-face, workshops or one-on-one?

 Helpful Tip: We would recommend referring to the International Association for Public Participation’s (IAP2) Public Participation Spectrum when it comes to engagement methods. The IAP2 Public Participation Spectrum is a quality assurance standard that helps to define community engagement processes and provide guidance to the public service and not-for-profit sectors, private industry, and communities. This has also been adapted by the CQ University Office of Indigenous Engagement in their First Nations Community Engagement: Industry Guide Phase 1.

 Resources:

IAP2 Engagement Spectrum

CQ University First Nations Community Engagement Industry Guide

 Helpful Tip: Early and proper engagement between the Proponent and the Indigenous stakeholders is crucial to the overall success of the project. Proper, and effective engagement requires high effort and typically the best results occur when there is a dedicated role or resource for engagement. You may benefit from appointing an Indigenous Liaison Officer or Community Engagement representative (preferably from the community where your project is located) for ongoing engagement/relationship building plus coordinating delivery of IES obligations and reporting.


2.4.1   First Nations Community Engagement Scale

Level of engagement

Inform

Consult

Involving

Partnerships

Self-determination

Engagement Goal

To provide community with information that helps to understand the problem, alternatives, opportunities and/or solutions and the impact.

Community feedback on the issue, analysis or decision. Communities know what they need and what will work. Assists with making informed decisions. Active listening required.

Involving the community early in the process to ensure community views are understood and considered. Build trust early through ongoing community connection (e.g through an advisory committee).

Partnering with the community in decision-making and co-creating for solutions. 

Drawing on community knowledge and expertise, sharing tools and knowledge to deliver outcomes. 

Place decision-making with the community. 

Community drives the decisions and the outcomes. 

Supports self-sufficient and sustainable communities. 

Transfer of resources and power to communities. 

Engagement Commitment

To keep the community informed.

To keep community informed, listen to and acknowledge issues, provide feedback as to how input affected the decision. 

To ensure concerns and aspirations are directly reflected in the alternatives developed and to provide feedback as to how input affected the decision. 

To seek advice and innovation from the community to formulate solutions and incorporate the advice into alternatives to the maximum extent possible. 

To implement what the community decides. 

Figure 1: IAP2 Engagement Spectrum First Nations Adaptation

Source:  Daniels, C, Stewart, M, & Miller, A 2021, First Nations Community Engagement: Industry Guide Phase I. (2022). Central Queensland University, Rockhampton, Queensland.

2.5 Indigenous Events and Activities

 Expectation:  Indicate any significant community events and activities you may participate in or host or networks you might join.

 Helpful Tip: Some dates of significance include:

  • National Apology Day
  • National Close the Gap Day
  • National Sorry Day
  • 1967 Referendum
  • National Reconciliation Week
  • Mabo Day
  • Coming of the Light
  • NAIDOC Week
  • National Aboriginal and Torres Strait Islander Children's Day
  • International Day of the World's Indigenous Peoples
  • Indigenous Literacy Day
  • Anniversary of the UN Declaration on the Rights of Indigenous People

 Resources:

Supporting NAIDOC Toolkit

2.6 Cultural Capability

 Expectation: Identify strategies to build the Proponent’s cultural capability i.e., undertake cultural competency training by a local service provider or commission training by a Traditional Owner group for staff or, develop or enhance a Reconciliation Action Plan (RAP).

 Resources:

Reconciliation Action Plan (RAP)

Aboriginal and Torres Strait Islander Cultural Capability Framework with the Australian Public Service Commission

Aboriginal cultural capability toolkit – VPSC

3. Procurement

The second pillar of your IES will be procurement. In this section you can begin to insert strategies of how the Proponent will involve and engage Indigenous businesses (see definition below) and set out objectives for Indigenous procurement for the project.

Procuring goods and/or services from Indigenous businesses creates enormous benefits for Aboriginal and Torres Strait Islander people, empowering Indigenous communities to generate and grow their economic prosperity, in turn benefitting local economies and the wider Australian economy. Indigenous businesses are over 100 times more likely to hire Indigenous workers than non-Indigenous businesses which contributes to a positive cycle of social and economic empowerment.

3.1 Definition of an Indigenous Business

To ensure that Indigenous peoples and businesses truly benefit from the IES, it is essential to maintain a consistent approach to verifying the Indigeneity of businesses. For the purposes of this guideline, any reportable Indigenous business spend must meet the following criteria:

Ownership, management, and control: The business must have at least 51 percent Aboriginal and/or Torres Strait Islander ownership and/or directorship and be operated for the benefit of Aboriginal and Torres Strait Islander communities.

Business Structure: “Business” is a general term which can include Aboriginal and/or Torres Strait Islander community-controlled organisations, charities, not-for-profit organisations, or entities incorporated under Commonwealth, state or territory legislation.

Registration: The business may be listed on the public register maintained by the Office of the Registrar for Indigenous Corporations (ORIC).

Certification: The business may be certified by recognised authorities such as Supply Nation or the Northern Territory Indigenous Business Network (NTIBN).

Joint Ventures: In the case of actively incorporated Indigenous joint ventures, the joint venture must have at least 51 percent Aboriginal and/or Torres Strait Islander ownership and/or directorship and be operated for the benefit of Aboriginal and Torres Strait Islander communities.

It is the responsibility of the Proponent or procuring official to ensure that any reported Indigenous Business procurement outcomes comply with this definition. By adhering to these guidelines, we can ensure that Indigenous businesses are accurately identified and supported, leading to meaningful Indigenous participation and economic benefits within the project.

Example Structure:

3.2 Indigenous Procurement Opportunities

 Expectation:  Identify Indigenous procurement opportunities for the involvement of Indigenous Businesses. Outline procurement opportunities in the construction and/or operations phase including goods and services, to procure etc.

3.3 Indigenous Procurement Target

 Expectation:  Proponents can set Indigenous procurement targets to work towards and track progress. Targets can be tailored to the project and procurement opportunities; they may be a percentage or value and can be staggered by project phase or escalate over a time period to best reflect the opportunities.

 Helpful Tip: Targets can be ‘hard’ or ‘soft’ targets. A hard target may include the proponent “will” achieve a target. A soft target could be such that the proponent will “seek” to achieve a target that may be more aspirational.

We encourage all proponents to include a procurement target to measure progress and drive performance. See section 4.3.1 Indigenous Participation Target Calculator as one example of setting targets.

3.4 Indigenous Business Networks/Registries

 Expectation:  Identify, connect, or become a member with relevant Indigenous Business network/s

 Resources:
Indigenous Business Registries

Indigenous Chambers of Commerce

Noongar Chamber of Commerce & Industry (Western Australia)

Pilbara Indigenous Business Network Group (Western Australia - Pilbara)

Karratha & Districts Chamber of Commerce & Industry (Western Australia - Karratha) - not specifically an Indigenous Chamber of Commerce

Goldfields Aboriginal Business Chamber (Western Australia - Goldfields)

Western Cape Chamber of Commerce (Queensland - Cape York)

CQ Indigenous Business Consortium (Queensland - Central)

Black Coffee Australia (National)

Please note this list is not exhaustive.

 Helpful Tip:

Look for opportunities outside of construction i.e., commission an Indigenous artist, Welcome to Country service, catering, or office supplies.

3.5 Engaging Indigenous Businesses

 Expectation:  Indicate (if known) which Indigenous Businesses you intend on engaging for what portion of work. Develop an Indigenous supplier registry to start scoping opportunities to engage with Indigenous Businesses prior to construction or commencement of your program.

 Helpful Tip: You may also look to host ‘meet the buyer’ sessions with Indigenous Businesses prior to the commencement of your project.

 Resources:

Indigenous Supplier & Employment Register - TEMPLATE

3.6 Barriers to Indigenous Supplier/Business Involvement

 Expectation:  Identify any barriers or limitations to achieving Indigenous procurement outcomes for the project.

 Examples: Limited supplier capacity and ability to compete with other tenderers, experience, or remoteness of project. Could be more opportunities in construction but limited needs in operations.

3.7 Methods to Increase Indigenous Business Involvement

 Expectation: Once you have identified what the potential barriers are to achieving Indigenous procurement outcomes, indicate what steps or strategies you will implement to overcome such barriers.

 Examples:
  • Design smaller work packages for Indigenous businesses into contracts for tenders.
  • Create purchase order terms and conditions that encourage the use of local Indigenous Businesses
  • Provide feedback upon request for unsuccessful tenderers.
  • Provide individual business mentoring.
  • Flexible tendering
    • Streamlining the tender processes to encourage smaller Indigenous businesses with limited resources.
    • Extending tender response timelines: Indigenous businesses may have limited access to resources, such as technology, information, and administrative support. Indigenous businesses operating in regional and remote areas may face logistical challenges in accessing information, submitting documents, and participating in the tender process.
  • Establish a focused internal Indigenous procurement policy that offers a clear and openly disclosed promotion of Indigenous businesses.
  • Sole Sourcing/Set asides – setting aside a certain tender package only for a selected Indigenous business to undertake.
  • Inclusion of non-price criteria for Indigenous subcontracting and Indigenous employment in tenders e.g;
    • information on the level of Indigenous employment
    • Indigenous business subcontracting
    • Indigenous training programs
    • Indigenous employment strategies/policies
    • Other initiatives to attract and retain Indigenous staff and contract Indigenous businesses.

3.8 Communication Plan

 Expectation: Create a targeted communications plan to promote and attract Indigenous procurement opportunities.

 Examples:
  • Send procurement opportunities to an Indigenous representative body i.e., Land Council, Prescribed Body Corporate, Indigenous Business Registry
  • Promotion of Indigenous supplier participation on Proponent’s website.
  • Created an online contact form on a website.
  • Distribute notifications to all social media subscribers for Indigenous procurement opportunities and processes.
  • Send an email to the entire mailing distribution list to outline Indigenous procurement opportunities and processes.

3.9  Quality Assurance/Accountability

 Expectation:  Indicate how you will ensure Indigenous peoples and businesses are the genuine beneficiaries of the procured goods/services and the reporting of outcomes is accurate.

 Examples:
  • Incorporate reporting obligations into successful contracts with reporting requirements on numbers, percentages and value of Indigenous contracts and employees to assist the Proponent. Examples include:
    • Number of contracts
    • Value of contracts $ and % of contracts as a total of the whole with Indigenous suppliers 
    • Number of hours worked, and number of local Indigenous people represented in the FTE and total number of employees.
    • Duration and position/type of employment of Indigenous employees (e.g., full time, part time, casual, unskilled/semiskilled/skilled)
  • Ensure all reported Indigenous procurement outcomes to NAIF are in accordance with the NAIF definition of an Indigenous Business.
  • Establish a quality assurance process for verifying Indigenous business status.
  • Accurate recording and validation of data.
 Resources:

Supply Nation What is Black Cladding

You can use the Employment & Procurement Outcomes Template or develop something similar for capturing outcomes.

 Helpful Tip:

A key contributor to the level of Indigenous procurement outcomes for your Project is your Head Contractor. We would recommend working closely with your Head Contractor and structuring terms in the contract that promote performance, compliance, and reporting.

4. Employment

The third pillar of your IES will be employment. In this section you can begin to insert strategies of how the proponent will involve and engage Indigenous employees and set out objectives for Indigenous employment for the project.

Example Structure:

4.1 Demographics

 Expectation: You may want to begin with understanding the general demographics of the region where your project is proposed such as the Indigenous population and working age population, employment status etc. We have compiled some resources to assist you with this.

 Resources:

Search Census data | Australian Bureau of Statistics

2021 ABS Census

4.2 Indigenous Employment Target

 Expectation:  Proponents can set Indigenous procurement targets to work towards and track progress. Targets can be tailored to the project and procurement opportunities; they may be a percentage or value and can be staggered by project phase or escalate over a time period to best reflect the opportunities.

 Helpful Tip:

Targets can be ‘hard’ or ‘soft’ targets. A hard target may include the proponent “will” achieve a target. A soft target could be such that the proponent will “seek” to achieve a target that may be more aspirational. We encourage all proponents to include an employment target to measure progress and drive performance.

 Examples:

One method for calculating participation targets as applied by the Department of Infrastructure, Transport, Regional Development, Communications and the Arts “Indigenous Employment and Supplier-Use Infrastructure Framework”.

 Example:

10,000 / 120,000 = 8% Participation Target
This target can be achieved through an employment component, procurement component or a combination of both (example below).

Employment 3% FTE (i.e., 1 FTE of 33 total FTE positions)
Procurement 5% total contract value (i.e., $600,000 of $20,0000 awarded to Indigenous Businesses)

4.2.1   Indigenous Participation Target Calculator

Download the Indigenous Engagement Strategy Toolkit to use the Indigenous Participation Target Calculator.

4.3 Barriers to Indigenous Employment Outcomes

 Expectation:  Identify any barriers or limitations to achieving Indigenous employment outcomes for the project.

 Examples: Low-skilled workforce, limited workforce, surrounding competitive industries.

4.4 Indigenous Staff Recruitment Strategies

 Expectation:  Identify recruitment opportunities through the project.

 Examples: Outline recruitment strategies to attract Indigenous staff including

  • engagement with Indigenous employment providers.
  • provide opportunities across entry level, experienced and specialised roles.
  • advertise job vacancies through Indigenous media.
  • hold information sessions with the Indigenous community on job opportunities.
  • develop an employment register
  • develop/maintain a culturally safe workplace.
 Resources:

Job advertising

Recruitment

4.5 Indigenous Staff Retention Strategies

 Expectation: Outline retention strategies

 Examples: Career development pathways, accredited training opportunities, mentor programs, development of an Indigenous staff network or upskilling and capacity-building initiatives.

4.6 Indigenous Employment Programs

 Expectation: You may also wish to leverage existing Indigenous employment initiatives.

 Resources:

CareerTrackers Indigenous Internship Program

The Indigenous Skills and Employment Program

Workforce Australia

4.7 Quality Assurance/Accountability

 Expectation:  Indicate how you will ensure Indigenous peoples are the genuine beneficiaries of meaningful employment opportunities and how data is collected appropriately and accurately.

 Examples:
  • Incorporate reporting obligations into successful contracts with reporting requirements for employment to be measured in terms of full-time equivalent (FTE) employees.
  • Ensure all reported Indigenous job outcomes to NAIF are in accordance with the criteria in the NAIF Indigenous Engagement Strategy Guideline 2023
  • Accurate recording and validation of data.
 Resources:

You can use the Employment & Procurement Outcomes Template or develop something similar for capturing outcomes.

5. Community Development/Cultural Heritage

Although the three pillars of the Indigenous Engagement Strategy are participation, procurement and employment, you are able to and encouraged to include initiatives that fall outside of these categories. This may include community development or cultural heritage initiatives. In this section you can insert these strategies.

 Expectation: Identify any commitments supporting community development or promoting Indigenous cultures, caring for country, local Indigenous community, and cultural heritage.

 Examples:
  • Sponsoring community events/sporting teams
  • Education Scholarships
  • Supporting local Indigenous community initiatives.
  • Secondments
  • Business development assistance
  • Formalising/actioning Cultural Heritage Management Plans
  • Supporting the conservation of culturally significant areas
  • Project rehabilitation

 Resources:

Caring for Country

Education

Financial Services

Schedule of Obligations

The Schedule of Obligations is attached to the Indigenous Engagement Strategy , and it is here where you will need to outline deliverables and clear commitments and timeframes. The commitments outlined in the Schedule of Obligations will be what the proponent reports on throughout the life of the NAIF loan.

Your reporting requirements will be contained within your finance documents but typically reporting is every six months in the construction phase and annually in the operational phase.

The reporting period commences once the Proponent reaches Financial Close. Reporting can help identify positive outcomes being achieved and good news stories that NAIF will look to celebrate and promote with approval from the Proponent. 

Reporting can also identify any issues affecting the strategy delivery including wet season, Sorry Business and project delays. If there are issues with delivering on your strategy commitments, NAIF will work with the Proponent to help mitigate or provide support to the Proponent.

As part of the reporting process, for each Progress Report the Indigenous Outcomes Team will endeavour to have a meeting with the Proponent to talk through the outcomes in the report, the challenges, and any support that NAIF can provide to the Proponent.


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