Validation

Guidance

Performance Expectations

Updated February 2025

Contents
01 Introduction  02
02 Annex A: Tabular summary of Performance Expectations,
clarification of intent or applicability, and evidence of implementation  07
Principle 1: Apply ethical business practices and sound systems of corporate
governance and transparency to support sustainable development 08

Principle 2: Integrate sustainable development in

company strategy and decision-making processes 10

Principle 3: Respect human rights and the interests, cultures, customs and values of
workers, communities, and other vulnerable groups, such as human rights defenders,
who may be affected by our activities.  11

Principle 4: Implement effective risk-management strategies and systems based

on sound science and which account for stakeholder perceptions of risks 21

Principle 5: Pursue continual improvement in physical and psychological

health and safety performance with the ultimate goal of zero harm 23

Principle 6: Pursue continual improvement in environmental performance

issues, such as water stewardship, energy use and climate change 25

Principle 7: Contribute to the conservation of biodiversity

and integrated approaches to land-use planning 32

Principle 8: Facilitate and support the knowledge-base and systems for responsible design,
use, re-use, recycling and disposal of products containing metals and minerals 34

Principle 9: Pursue continual improvement in social performance and contribute to the

social, economic and institutional development of host countries and communities 35

Principle 10: Proactively engage key stakeholders on sustainable development

challenges and opportunities in an open and transparent manner.
Effectively report and independently verify progress and performance 38

03 Annex B: Position Statement Commitments and Applicability  41

04 Annex C: Glossary of terms and list of abbreviations  56
05 Annex D: Key resources  62

ICMM Contents 01
Introduction 01

Validation Guidance Introduction 02

The purpose of this Performance It must be read in conjunction with the Assurance and
Validation Procedure where many of the key concepts
Expectations (PEs) Validation Guidance or related terms are explained in more detail.
document is to supplement the ICMM
This guidance document informs company members
Assurance and Validation Procedure and VSPs on the evaluation of the company’s
and to provide explanatory information conformance with the intent of the PEs. It is not
to company members and validation intended to be a complete list of all elements of a
management system nor is it designed to provide
service providers (VSPs) on the
‘compliance criteria’ for each of the ICMM Principles
implementation and evaluation of the and related PEs1.
Performance Expectations. This guidance document is organised by the 10
Principles and associated PEs and provides
information regarding the intent and applicability of
the PEs and examples of evidence that would be
indicative of successful PE implementation at the
asset2 level.

The intention is that this be a ‘living document’ that will

be subject to periodic revision in light of experience.

How the Document Is Structured

The major part of this guidance is included as Annex A
(Tabular summary of Performance Expectations,
clarification of intent or applicability, and evidence of
implementation). This is structured as follows:

Performance Expectation
The wording of each of the PEs is provided in full.

Intent of the PE
Where deemed useful, remarks to clarify the intent of
each PE are provided. The remarks answer, in plain
language, the questions:

— What is the expectation of the PE?

— W
 hy is it important to the sustainable development
of the company member and its stakeholders?

Applicability of the PE
This indicates whether the PE is applicable at a
Corporate level, Asset level, or both a Corporate and
Asset level.

Examples of Evidence of PE Implementation

For each PE, examples of evidence of PE
implementation are presented in response to
the questions:

1. As a point of principle, the guidance document has not been written in a prescriptive
manner.

2. A member’s portfolio of assets is likely to change over time due to acquisitions or

disposals. Newly acquired assets that meet the criteria for PE implementation should
implement the PEs within a 3-year timeframe. If a member acquires an asset from another
member, due consideration should be given to previous work to implement the PEs at the
asset level.

ICMM Introduction 03
— What are you doing to achieve the intent of the PE? PE Validation Process
As outlined in detail in section 3.2 of the Assurance
— What evidence do you have to demonstrate this?
and Validation Procedure, PE Validation comprises the
It is important to acknowledge that the evidence of following elements:
implementation will often differ markedly at the
— Self-assessments of all assets subject to PE
Corporate level as opposed to Asset level.
validation.
In addition, basic information is provided below on the
— Prioritisation of assets for third-party validation.
PE validation process and outcomes, as well as the
relationship between PEs and ICMM’s position — 3rd party validation.
statements. Guidance is also provided on completing
— Disclosure.
the self-assessment template (see here). For further
information, please refer to the Assurance and Outcomes of Validation Activities
Validation Procedure. The PE validation activities evaluate the
implementation of the PEs individually. There is no
PE Validation Process and Outcomes overall outcome for a given asset. The possible
PE Validation includes two types of activities related to a outcomes for the validation of an individual PE are
member’s implementation of the PEs at the asset level. ‘Meets’, ‘Partially Meets’, and ‘Does not Meet’ as
These are: defined below:

— Self-assessment – First-party confirmation (ie — Meets – Systems and/or practices related to the PE
self-assessment) of the existence and integrity of have been implemented and there is sufficient
systems and/or practices relating to implementation evidence to demonstrate that the intent of the PE is
of the PEs, to the extent that they are applicable in a being met, however opportunities for improvement
given context. may still remain.

— 3
 rd party validation – Independent confirmation of — P
 artially Meets – Systems and/or practices related
the reasonableness and authenticity of assertions to meeting the intent of the PE have been only
made in self-assessments. This review may take partially implemented. Gaps or weaknesses persist
place in conjunction with a separate system, eg an that may contribute to an inability to meet the
ISO 14001 environmental management system audit. intended outcome of the PE, or insufficient
verifiable evidence can be provided to demonstrate
For the purposes of this procedure, these two types of
that the activity is aligned to the intent of the PE.
activities are referred to as ‘PE validation activities’.
— D
 oes not Meet – Systems and/or practices
required to support implementation of the
substantive intent of the PE are not in place, or are
not being implemented, or cannot be evidenced.

Validation Guidance Introduction 04

Position Statements and Their (and are relevant to validation), either ‘individually or
Relationship to the PEs collectively’ (which may or may not be relevant to
All ICMM position statements include a number of validation), or ‘collectively’ (which are not applicable for
commitments that company members are required the purposes of validation). It identifies which of the
to implement. These may either apply to individual PEs the position statement commitments connect to.
company members or can be delivered collectively It also indicates whether individual commitments are
through membership of ICMM. Where position applicable at a Corporate level, Asset level, or both a
statement commitments apply to individual company Corporate and Asset level.
members, they are also referred to in Annex B of the For self-assessment and 3rd party validations,
ICMM Assurance and Validation Procedure as members are required to provide evidence of
‘mandatory requirements’. implementation of the mandatory requirements of
The introduction of the PEs has caused a degree of related position statements. For those PEs that have
uncertainty regarding the status of position statement related mandatory requirements, the determination of
commitments as many, but not all, of the mandatory ‘meets’, ‘partially meets’ or ‘does not meet’ needs to be
requirements have been incorporated within the PEs. made on the basis of the wording of the PE and any
To avoid ambiguity, where a PE has related position related mandatory requirements. Where position
statement commitments, these are explicitly linked to statement commitments apply either ‘individually or
the relevant PE within this guidance document. collectively’, member companies have sole discretion to
A tabular summary of position statement commitments choose whether or not to include them within the scope
is included as Annex B. This indicates whether the of validation.
commitments apply individually to member companies

ICMM Introduction 05
Applying the Self-Assessment Template 4. Where a requirement of a programme for which
A self-assessment template is provided (see here) that ICMM has undertaken an equivalency comparison is
may be used to document validation activities. The ‘Partially meets’ (as opposed to ‘Meets’), the basis
following considerations apply to the completion of the for that distinction is clearly outlined in the
self-assessment template. comments section of the equivalency comparison
table on ICMM’s intranet. Where an equivalent
1. The first step in the self-assessment process is to
programme has a requirement that only partially
consider Applicability of the PEs – as in some cases,
meets (or does not meet) the corresponding ICMM
a PE may not be applicable to an asset or company.
PE, an asset should provide evidence that it is
If a member determines that a PE is not applicable at
meeting the supplementary elements of the PE
a given asset, select ‘Not Applicable’ from the
in order to ‘Meet’ the PE requirements (which
drop-down menu and provide comments explaining
should be included in the Evidence of
this determination in the ‘Evidence’ column. The two
implementation column).
options from a drop-down menu in this column are
‘Applicable’ and ‘Not applicable’. 5. T
 he next step is to Evaluate PE implementation. In
evaluating the implementation of individual PEs,
2. The next step in the self-assessment process is to
aspects such as frequency, quality and extent
consider Equivalency (see section 3.3.1 of the
should be considered (see section 3.3.1 of the
Assurance and Validation Procedure) for each
Assurance and Validation Procedure for definitions).
individual PE. Please note that ‘equivalent
The options available from the drop-down menu are
programmes’ are defined as having standards/
‘meets’, ‘partially meets’ and ‘does not meet’ (or not
requirements and validation requirements that are
applicable, if so determined).
similar in scope and intent as the ICMM PEs
validation process. Equivalency applies at the 6. T
 he choice from the first three of these options is
individual PE level, rather than at the overall based upon two related questions: what are you
programme level. ICMM will maintain details on its doing to achieve the intent of the PE and what
intranet3 on an ongoing basis regarding what other evidence do you have to demonstrate this? In the
equivalent programmes can be recognised as such Evidence of implementation column, for each
– and the extent to which their requirements are applicable PE members should include details of
equivalent to each individual PE. Where the what they are doing to achieve the intent of the PE
requirements of PEs are incorporated into a and the evidence to demonstrate this. This might
members’ ISO 14000 environmental management include links to relevant internal or publicly available
system or other management systems that are documents. The evidence that supports the self-
subject to certification, these can also be considered assessment determinations will be used for
as equivalent. subsequent third-party validations. For this reason,
the better the quality of evidence collected
3. If a PE has been validated by an equivalent
during self-assessment the better-placed an asset
programme in the past 3-years, this should be
will be for third-party validations.
indicated by either selecting ‘Covered by equivalent
programme’ or ‘Partially covered by equivalent 7. Lastly, the Implementation gaps column will help
programme’ from the drop-down menu and assets establish action plans to close any identified
providing comments explaining this determination gaps and will facilitate future disclosures, as outlined
in the ‘Evidence of implementation’ column. For in section 3.3.5 of the Assurance and Validation
example, this might include ‘See link to our ASI Procedure.
certification or TSM verification for this site’.
Some additional sources of guidance (mostly ICMM
The options from the drop-down menu in this
documents) are provided in Annex D.
column are ‘Covered by equivalent programme’,
‘Partially covered by equivalent programme’ and If you require further information relating to PE Validation or this guidance,
‘Not covered’. please contact ICMM at [email protected] (and include the words ‘Validation
query’ in the subject line).

3. Where ICMM and the owners of equivalent programmes have made a mutually agreed
determination of equivalency and where both parties agree, ICMM supports public
disclosure of the comparison table.

Validation Guidance Introduction 06

Annex A: Tabular Summary 02
of Performance Expectations,
Clarification of Intent or Applicability,
and Evidence of Implementation

ICMM Annex A 07
Principle 1
Apply ethical business practices and sound systems of corporate
governance and transparency to support sustainable development.

Performance Expectation 1.1

Establish systems to maintain compliance with applicable law.4

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

ICMM’s company members are required to comply with all — Mechanisms to identify relevant legal requirements exist.
applicable laws in the countries where they operate. Many
— Legal requirements, permits and other relevant documentation
stakeholders want mining companies to show that they have
are accessible to those who need them.
strong systems in place aimed at ensuring legal compliance.
— M
 echanisms to track, assess, implement and communicate
It is unreasonably onerous to provide evidence of compliance with
changes to relevant legal and other requirements.
‘all applicable law’. An informed conversation between the
company and validation service provider and the demonstration of — Mechanisms to evaluate compliance (eg monitoring and
compliance with a representative sample of laws relevant to measurement) are in place and working effectively.
sustainable development should be sufficient to agree that ‘all
applicable law’ has been complied with.

The ‘systems’ referred to in the PE are expected to ensure that the

company tracks and complies with all applicable law, they cannot
be expected to demonstrate compliance with all law.

Applicability: Corporate and Asset level

Performance Expectation 1.2

Implement policies and practices to prevent bribery and corruption,
and to publicly disclose facilitation payments.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Discourage corruption and bribery and encourage disclosure of — A policy or equivalent exists that covers the company’s
facilitation payments in order to comply with laws and to build trust expectations in relation to preventing bribery and corruption,
with stakeholders. and under what circumstances facilitation payments are
considered acceptable.
Applicability: Corporate and Asset level
— Training is delivered to employees and contractors on policies
and prohibited practices.

— M
 echanisms to identify and prevent potential bribery and
corruption are in place.

— Anonymous mechanisms for reporting potential non-

compliances exist.

— P
 ublic disclosure of facilitation payments, if applicable, is
provided for.

4. ICMM’s member companies already comply with all applicable law in the countries that
they operate in. However, many stakeholders say they want mining companies to show that
they have strong systems that ensure legal compliance.

Validation Guidance Annex A 08

 Performance Expectation 1.3
Implement policies and standards consistent with the ICMM policy framework.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

The ICMM policy framework consists of ICMM Principles, PEs and — Internal assessment of alignment of company policies and/or
position statements. Company members are required to embed standards with the ICMM policy framework requirements.
the requirements contained within these documents.
— M
 anagement systems, processes and/or approaches are in
Applicability: Corporate level place to incorporate content within the ICMM policy framework
throughout the company as applicable.

— Mechanisms to demonstrate implementation of the above-noted

management systems, processes and/or approaches.

Performance Expectation 1.4

Assign accountability for sustainability performance at the Board and/or Executive Committee level.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Senior leaders assume responsibilities that support the — B

 oard and/or Executive Committee level roles and
sustainability performance of the company. responsibilities for ongoing oversight of sustainability
performance are in place and documented.
Applicability: Corporate level
— Records to demonstrate Board and Executive Committee’s
participation in sustainability matters.

Performance Expectation 1.5

Disclose the value and beneficiaries of financial and in-kind political
contributions whether directly or through an intermediary.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Be transparent about political contributions and in order to be — M

 echanisms in place that provide for the approval, tracking
clear to stakeholders about any political affiliations the company and disclosure of the value and recipients of financial and
may have. in-kind political contributions.

Applicability: Corporate level

ICMM Annex A 09
Principle 2
Integrate sustainable development in company
strategy and decision-making processes.

Performance Expectation 2.1

Integrate sustainable development principles into corporate strategy and decision-making processes
relating to investments in the design, operation and closure of facilities.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Ensure sustainable development plays an important role in — Sustainable development principles reflected in company
decision-making, and to provide the resources necessary to strategy.
manage risks throughout the life of an asset.
— Mechanisms
 in place to review material sustainable
Applicability: Corporate level development risks and opportunities in business strategy,
planning and budgeting activities and provide appropriate
resources for their management throughout the mining life cycle.

Performance Expectation 2.2

Support the adoption of responsible physical and psychological health and safety5, environmental, human
rights and labour policies and practices by joint venture partners, suppliers and contractors, based on risk.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Encourage those with whom the company does business to act — Policies and practices, or equivalent, are in place to define
responsibly and sustainably to minimise physical and company expectations in the value chain with respect to physical
psychological health and safety, social, environmental and and psychological health and safety, environmental, human rights
human rights impacts in the value chain. and labour practices.

Applicability: Corporate and Asset level — Mechanisms in place, based on risk, to support the physical and
psychological health and safety, environmental, human rights,
labour performance of suppliers and contractors.

— Mechanisms to demonstrate and evaluate implementation of

above-noted policies and practices.

5. Psychological health in the workplace is defined in international literature as the ability to

think, feel and behave in a manner that enables workers to perform effectively.
Psychological safety in the workplace is defined as the risk of injury to the psychological
wellbeing of a worker.

Validation Guidance Annex A 10

Principle 3
Respect human rights and the interests, cultures, customs and values
of workers6, communities, and other vulnerable groups7, such as human
rights defenders, who may be affected by our activities.

Performance Expectation 3.1

Support the UN Guiding Principles on Business and Human Rights by developing a policy commitment to
respect human rights, undertaking human rights due diligence (including undertaking processes that assess
perceived, potential and actual human rights impacts on rightsholders, including human rights defenders and
other vulnerable groups), and providing for or cooperating in processes to enable the remediation of adverse
human rights impacts that members have caused or contributed to.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Corporate and Asset level — Policy commitment to avoid causing or contributing to adverse
human rights impacts from operational activities or from
activities directly linked to the operations, products or services
by business relationships.

— Mechanisms to identify, assess, and control potential/actual

human rights risks and impacts in consultation with subject
matter experts and with potentially affected
rightsholders(including human rights defenders and other
vulnerable groups)suppliers, and stakeholders, as appropriate to
the size of the company and the nature and context of the asset.

— Grievance mechanism for employees, contractors,

communities, and other rightsholders, including human rights
defenders and other vulnerable groups, who may be adversely
impacted by company activities. (See examples of grievance
mechanism per 9.3.)

— M
 echanisms to communicate Human Rights Impacts in an
appropriate manner to potentially impacted individuals or
groups, where applicable.

— Mechanisms in place to remediate any human rights impacts in

a prioritised manner.

6. ‘Workers’ is defined in the Health and Safety Performance Indicators Guidance, 2021, as
‘people who are engaged in work-related activities on behalf of an employer. Workers may
be employees, contractors or third parties’.

7. A group that has specific characteristics that make it more at risk of health, safety and
economic challenges (eg, may include Indigenous Peoples, human rights defenders,
households headed by women or children, people with disabilities, the extremely poor, the
elderly, religious and ethnic minorities, migrant workers, minorities, LGBTQ+ and
gender-diverse people, and in some societies, women)

ICMM Annex A 11
 Performance Expectation 3.2
Avoid the involuntary physical or economic displacement of families and communities. Where this is not
possible apply the mitigation hierarchy and implement actions or remedies that address residual adverse
effects to restore or improve livelihoods and standards of living of displaced people.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Avoid compelling people to move from their homes or businesses — Policy statement covering the avoidance of involuntary
due to the impact of operations. If relocation is necessary, work to resettlement to the extent possible.
restore or improve peoples’ overall physical and economic
— R
 isk assessment includes consideration of the mitigation
conditions. This is important because resettlement can be
hierarchy.
disruptive to communities, their livelihoods and the social fabric of
the area. — R
 esettlement plans and examples of compensation provided
where involuntary resettlement has taken place.
Applicability: Asset level
— M
 echanisms to monitor and review agreed actions of the
above-noted action plans.

Performance Expectation 3.3

Implement, based on risk, a human rights and security approach consistent
with the Voluntary Principles on Security and Human Rights. This includes
identifying potential and actual human rights impacts on vulnerable groups7.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

In providing security for people and assets, it is important to avoid — Human rights risk assessment conducted based on local or site
adversely impacting the rights of others. Activities must be carried context, in consultation with affected rightsholders and
out consistent with the Voluntary Principles on Security and Human stakeholders, including vulnerable groups, and mitigation
Rights. These are the only security and human rights guidelines measures implemented as appropriate.
designed specifically for extractive sector companies.
— H
 uman rights training for public and private security personnel
Applicability: Asset level and contractors.

— Investigation of incidents related to interactions between

security personnel and the public and appropriate actions
taken.

— Consultation with potentially affected rightsholders and

stakeholders, including vulnerable groups, and supervision of
private security.

Validation Guidance Annex A 12

 Performance Expectation 3.4
Respect the rights of workers by: not employing child or forced labour; avoiding human trafficking;
not assigning hazardous/ dangerous work to those under 18; eliminating all forms of harassment and
discrimination; respecting freedom of association and collective bargaining; and providing an appropriate
mechanism to address workers grievances.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Respect the rights of workers directly engaged by the assets by — Mechanisms to identify, assess, and eliminate potential
observing international labour standards. employment and human rights risks related to child labour,
forced labour and human trafficking, the assignment of
Applicability: Corporate and Asset level
hazardous/dangerous work to those under 18, and all forms of
harassment and discrimination.

— Mechanisms to enable workers’ grievances to be brought

forward and addressed in a manner appropriate to the nature
of the grievance. Mechanisms should be confidential,
appropriately sensitive and staffed by trained individuals.

Performance Expectation 3.5

Equitably remunerate employees with wages that equal or exceed legal requirements
or represent a competitive wage within that job market (whichever is higher) and assign
regular and overtime working hours within legally required limits.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Provide employees with fair working hours, pay and benefits. — Standards, procedures, programmes or agreements (eg
Fairness takes into consideration both the local and company collective agreements) governing employee remuneration.
context.
— When government regulations are absent or insufficient,
Applicability: Corporate and Asset level internal remuneration criteria have been developed to meet the
intent of PE 3.5.

— Monitoring of working hours (inc. overtime) and checks against

legally required/maximum agreed limits (whichever is lower).

— Mechanisms to demonstrate and evaluate implementation of

fair remuneration.

ICMM Annex A 13
 Performance Expectation 3.6
Respect the rights, interests, aspirations, culture, Indigenous knowledge and natural resource-based
livelihoods of Indigenous Peoples in project design, development and operation; carry out due diligence to
address potential adverse impacts; and share benefits in a manner that is aligned with Indigenous Peoples’
aspirations for social and economic development.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Refer to the Explanatory Notes and Glossary in the Indigenous Note: The examples below have been drawn from the Indigenous
Peoples and Mining Position Statement for further guidance and Peoples and Mining Position Statement Explanatory Notes. See the
clarity on the intent and definitions of key terms. Key terms are Explanatory Notes for further guidance on each PS requirement.
highlighted in bold.
— Early and comprehensive identification and documentation of
Note: In some countries, the term ‘Indigenous’ may be controversial Indigenous Peoples and groups, their rights and interests, and
and local terms may be used that are broadly equivalent (i.e., Tribal who may be potentially affected by/benefit from company
Peoples, First Peoples, Native Peoples, Aboriginal, First Nations, activities.
Traditional Owners, Customary Landowners, etc.). In other
— Reviews or comprehensive and appropriate mapping of lands,
situations, there may be no, or ambiguous, recognition of
territories and resources, potential title or land claims, and their
Indigenous Peoples by States, or the term may have negative
physical or cultural usage by Indigenous Peoples, including
associations that discourage people from acknowledging
those that may be displaced or Peoples in vulnerable situations
Indigenous identity. Irrespective of the local context, ICMM
in the area of a proposed project or activity. Evidence to show
members reject any discrimination or disadvantage that may be
that Indigenous Peoples, and/or relevant State authorities and
related to culture, identity or vulnerability and will apply the
other responsible agencies have been engaged in the reviews
principles embodied in the ICMM Indigenous Peoples and Mining
and mapping.
Position Statement to groups that exhibit the commonly accepted
characteristics of Indigenous Peoples. — Appropriate consultation and engagement processes agreed
upon and being implemented with potentially affected
While there is not one official definition for ‘Indigenous Peoples’,
Indigenous Peoples or groups. These processes should be
ICMM recognises the definition of ‘Indigenous Peoples’ and their
consistent with Indigenous Peoples’ procedures, protocols,
commonly accepted characteristics as defined in article 1 of ILO 169.
governance structures and decision-making processes, and
We also respect and utilise regional terms and, where possible,
such processes can be documented in an engagement plan.
recognise and use the specific names as identified by a group,
supporting self-identification. Indigenous Peoples have the right to — Evidence that due diligence processes, such as social, human
determine their own identity or membership in accordance with rights and environmental baseline analyses and impact
their customs and traditions. Indigenous Peoples can share some or assessments have been conducted, and conducted early and
all of the following characteristics: in advance of any project activities to identify those Indigenous
Peoples who may be impacted by a project as well as the
— Self-identification as Indigenous.
nature and extent of potential adverse impacts on Indigenous
— Historical continuity with pre-colonial and/or pre-settler Peoples’ rights.
societies.
— Opportunities for Indigenous Peoples’ aspirations for social
— A common experience of occupation, colonialism and
and economic development identified and progress towards
oppression.
suitable realisation/delivery for benefit sharing is evident. The
— Occupation of or a strong link to specific lands and territories. agreement-making process can also identify opportunities for
— Distinct social, economic, and political systems. benefits that are aligned with Indigenous Peoples’ aspirations
— Distinct language, culture and beliefs that vary from dominant for social and economic development. These may include
sectors of society. equitable economic benefits as well as those that are not solely
financial and that catalyse long-term sustainable development
— Resolve to maintain and reproduce their ancestral environments
and strengthen self-determination.
and distinctive identities.
These general criteria of ‘Indigenous Peoples’ are purposely
inclusive and are thus meant to encompass the diversity of
worldwide Indigenous Peoples’ experiences, while still separating
‘Indigenous Peoples’ from other national minorities and local
communities as unique and distinct groups and providing a basis
for the kinds of rights that they claim.

Applicability: Asset level

Validation Guidance Annex A 14

 Performance Expectation 3.6 continued

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Indigenous Peoples and Mining Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 1: Respect Indigenous Peoples’ rights by embedding Note: The examples below have been drawn from the Indigenous
measures across governance and management processes to avoid Peoples and Mining Position Statement Explanatory Notes. See the
infringing Indigenous Peoples’ rights, and to adequately address Explanatory Notes for further guidance on each PS requirement.
potential adverse impacts to rights from mining and mining-related
— Stand-alone or integrated policy commitments in line with
projects. This includes developing and implementing policy
Position Statement requirement 1.
commitments and promoting cross-cultural understanding and
awareness through relevant educational programmes to meet the — Cultural awareness education and training for relevant
responsibility to respect Indigenous Peoples’ rights. It also includes employees and contractors, scaled to their roles, and may
supporting efforts for reconciliation with Indigenous Peoples and include materials on the history, social and cultural traditions
the advancement of the exercise of their rights, where appropriate. and patterns, the rights of Indigenous Peoples and the
See Explanatory Note: Commitment 1. (Individual, Asset and company’s responsibility to respect these rights.
Corporate level)
— Inter-cultural dialogue training to personnel engaging with
Requirement 2: Carry out due diligence to identify, prevent, Indigenous Peoples.
mitigate and account for possible adverse impacts on Indigenous
— Actions that contribute to, or support for, Indigenous-led and/
Peoples’ rights. Due diligence processes should include the early
or government led reconciliation initiatives.
and comprehensive identification of and meaningful engagement
with Indigenous Peoples who may be affected by a project. The — Co-developed capacity-building activities supporting
process should respect Indigenous Peoples’ right to participate in Indigenous Peoples’ and other communities participation in
decision-making on matters that affect them and be guided by the project engagement in-place for project.
principles of FPIC. Due diligence should also seek to prevent or
— Documentation of participatory involvement of potentially
mitigate potential adverse impacts on Indigenous Peoples’ rights
impacted Indigenous People in the identification of project
that may be caused or contributed to by companies or directly
impacts.
linked to their operations, products or services by their business
relationships. Due diligence should be ongoing, recognising that — Evidence that due diligence processes, such as social, human
the risks to Indigenous Peoples’ rights may change over time as a rights and environmental baseline analyses and impact
company’s operations and/or operating context evolves. See assessments have been conducted and conducted early and
Explanatory Note: Commitment 2 (Individual, Asset level) in advance of any project activities to identify those Indigenous
Peoples who may be impacted by a project as well as the
Requirement 3: Agree on appropriate engagement processes with
nature and extent of potential adverse impacts on Indigenous
potentially affected Indigenous Peoples and relevant State
Peoples’ rights.
authorities as early as possible in project planning. This is to enable
their inclusive, equitable and meaningful participation in due — Ongoing, agreed-upon engagement plan and consultation
diligence processes and for the good faith negotiation of processes in place with potentially impacted Indigenous
agreements that can demonstrate their consent. Engagement communities to allow their meaningful participation in
processes should be co-designed, culturally appropriate, inclusive culturally-appropriate decision-making.
and carried out through the procedures, protocols and governance
— Project plans or equivalent define what constitutes consent
structures of potentially affected Indigenous Peoples. Where
from Indigenous communities that may be adversely impacted
Indigenous Peoples do not have access to the legal or other
by the project.
technical support necessary to participate equitably in negotiation,
companies will offer them reasonable financial or other agreed- — Evidence of support for Indigenous People’s capacity to
upon assistance as required. See Explanatory Note: Commitment 3 engage in decision-making and agreement-making, for
(Individual, Asset level) example by providing access to independent expert advice
where appropriate, capacity building, facilitation and mediation,
Requirement 6: Enable benefit sharing that reflects and is aligned
or involving external observers.
with Indigenous Peoples’ aspirations for social and economic
development. Benefit sharing should be equitably distributed and — Opportunities for benefit sharing are evident through
facilitate positive outcomes that extend beyond the life of commercial participation in projects; and/or financial benefits
operations. See Explanatory Note: Commitment 6. (Individual, Asset or various other types of benefit such as social and economic
level) development outcomes, including in-kind participations such

ICMM Annex A 15
 Performance Expectation 3.6 continued

Requirement 7: Respect and incorporate Indigenous knowledge in as education and training, cooperation in environmental and
collaboration with Indigenous Peoples through the design and cultural heritage conservation projects and health initiatives. In
implementation of due diligence and methods of engagement; in some instances, companies may face scenarios where
agreements for benefit sharing, sustainable environmental and Indigenous Peoples do not wish to participate in engagement
social investment programmes; and in closure planning and over a proposed project. Without prejudice to the rights of
execution. Respect that Indigenous Peoples have the right to Indigenous Peoples to withhold their agreement, the company
maintain, control and protect their Indigenous knowledge and should document the steps taken to engage with Indigenous
knowledge systems. Respect and support Indigenous cultural and Peoples and the rationale taken in each step. Companies will
intellectual property and obtain permission if collecting, storing, continue to respect the rights of Indigenous Peoples even
accessing, using and/or reusing cultural and intellectual when Indigenous Peoples do not wish to engage.
information and knowledge. See Explanatory Note: Commitment 7.
— Evidence that Indigenous knowledge has been considered in
(Individual, Asset level)
impact assessments, due diligence, environmental and social
Requirement 8: Respect and celebrate cultural heritage, both investment programmes and closure planning and execution.
tangible and intangible, and the historical and ongoing spiritual Companies should show evidence that they have obtained
connections of Indigenous Peoples to such heritage, particularly permission if collecting, storing, accessing, using and/or
prioritising the avoidance of impacts on cultural heritage that is reusing the cultural and intellectual information and knowledge
critical to Indigenous Peoples’ cultures or spiritual life. This includes of Indigenous Peoples.
collaborating with Indigenous Peoples to identify risks to and
— Evidence that cultural heritage management plans are
potential adverse impacts on cultural heritage from proposed
informed through ongoing engagement that remains adaptive
activities and developing mitigation measures and management
and incorporates new information as it becomes known.
plans through due diligence and agreement-making. Companies will
also promote, celebrate and support the revival of cultural heritage — Initiatives to support the promotion, revival and celebration of
where appropriate and agreed upon by Indigenous Peoples. See cultural heritage, where agreed upon by Indigenous Peoples,
Explanatory Note: Commitment 8. (Individual, Asset level) by implementing awareness and education initiatives,
participating in festivals and events, supporting language
preservation endeavors, and other efforts.

Validation Guidance Annex A 16

 Performance Expectation 3.7
Obtain agreement with affected Indigenous Peoples demonstrating their consent to anticipated impacts to
their land or other rights, and setting out the terms by which impacts may occur and be managed. Where
potential impacts include the relocation of Indigenous Peoples from their lands or territories, or significant
impacts to their critical cultural heritage, companies will explore feasible alternatives to project design in order
to avoid such impacts. If relocation and/or significant impacts on critical cultural heritage are unavoidable,
companies will obtain agreement demonstrating the consent of affected Indigenous Peoples in accordance
with ICMM’s Indigenous Peoples and Mining Position Statement. In any instance where agreement is not
obtained, ICMM members will develop a policy or approach outlining the steps they have taken to fulfil the
commitments set out in the position statement.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Refer to the Explanatory Notes and Glossary in the Indigenous Note: The examples below have been drawn from the Indigenous
Peoples and Mining Position Statement, for further detail and Peoples and Mining Position Statement Explanatory Notes. See the
clarity on the intent and definitions of key terms. Key terms are Explanatory Notes for further guidance on PS each requirement.
highlighted in bold.
— Early and comprehensive identification and documentation of
Applicability: Asset level Indigenous Peoples and groups, their rights and interests, and
who may be potentially affected by/benefit from company
activities.

— Appropriate engagement plan and processes agreed upon

and being implemented.

— Documentation to show that agreements with Indigenous

Peoples have been made in accordance with their own
decision-making processes and representative institutions.
Agreements can reflect consent and/or be a means to
demonstrate consent.

— Adverse impacts identified through a due diligence process

and differentiated mitigation measures are developed/
implemented to address these.

— Where Indigenous Peoples do not provide their agreement to

anticipated impacts, there is documentation of a policy or
approach that outlines appropriate steps taken and
management of impacts to their land or other rights. This can
entail seeking mediation or advice from mutually acceptable
parties, and/or pursuing processes that have been designed by
States for such situations, and/or escalating issues to the
highest relevant corporate-level decision-makers (i.e., senior
management, executive and Board-level) for a decision on how
the activity should progress.

— If relocation and/or significant impacts on critical cultural

heritage are unavoidable, companies will obtain an agreement
demonstrating the consent of affected Indigenous Peoples.

— Evidence that cultural heritage management plans are

informed through ongoing engagement that remains adaptive
and incorporates new information as it becomes known.

ICMM Annex A 17
 Performance Expectation 3.7 continued

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Indigenous Peoples and Mining Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 4: Obtain agreement with affected Indigenous Note: The examples below have been drawn from the Indigenous
Peoples demonstrating their consent to anticipated impacts to Peoples and Mining Position Statement Explanatory Notes. See the
their land or other rights, and setting out the terms by which Explanatory Notes for further guidance on each PS requirement.
impacts may occur and be managed. In accordance with the
— Documentation of engagement and agreement outcomes and
principles of FPIC, agreement should be achieved through
processes.
informed and meaningful engagement and good faith negotiation,
through means that advance intercultural understanding and that — Documentation to show that agreements with Indigenous
facilitate freely giving or withholding agreement. The agreement Peoples have been made in accordance with their own
should include, at a minimum, demonstration of consent to decision-making processes and representative institutions.
anticipated impacts, mitigation measures developed through the Agreements can reflect consent and/or be a means to
due diligence process, and a redress mechanism for potential demonstrate consent.
infringements of the agreement or of Indigenous Peoples’ rights. It
— Where decision by a company has been made to proceed with
is expected that the agreement be faithfully implemented, with
a project without agreement demonstrating consent, there is
ongoing monitoring supporting the effective realisation of the
evidence to demonstrate that efforts to reach agreement in
terms of the agreement (and conditions therein). When a project is
good faith have been extensive and exhaustive and that it has
to be developed within Indigenous Peoples’ lands or territories, or
been preceded by a due diligence process and consultation
otherwise with substantial anticipated impacts on their rights, the
with internal and external experts and relevant State
agreement should also include benefit sharing. Where potential
authorities. This due diligence should include a review of the
impacts include the relocation of Indigenous Peoples from their
States process to obtain free, prior and informed consent
lands or territories, or significant impacts to their critical cultural
(FPIC) of affected Indigenous Peoples, and an assessment of
heritage, companies will explore feasible alternatives to project
the company’s capacity to conform with its responsibility to
design in order to avoid such impacts. If relocation and/or
respect Indigenous Peoples’ rights.
significant impacts on critical cultural heritage are unavoidable,
companies will obtain an agreement demonstrating the consent of — Where Indigenous Peoples do not provide their agreement to
affected Indigenous Peoples in accordance with this Commitment. anticipated impacts, there is documentation of a policy or
See Explanatory Note: Commitment 4 (Individual, Asset level) approach that outlines appropriate steps taken and
management of impacts to their land or other rights. This can
Requirement 5: Address differences of opinion that arise and work
entail seeking mediation or advice from mutually acceptable
to resolve disagreements. ICMM members recognise that
parties, and/or pursuing processes that have been designed by
achieving agreement and demonstrating such consent, can enable
States for such situations, and/or escalating issues to the
long-term relationships based on mutual respect, trust and benefit.
highest relevant corporate-level decision-makers (i.e., senior
Hence, ICMM members will start from the position that a proposed
management, executive and Board-level) for a decision on how
project or activity should proceed with agreement as outlined in
the activity should progress.
Commitment 4. Recognising that there may be circumstances in
which agreement is not obtained, this Position Statement sets out — Documented processes which have been mutually designed
the process that ICMM members will take in this instance. ICMM for dealing with disagreements or setbacks and include
members will develop a policy or approach outlining the steps they avenues for recourse and access to mediation.
have taken to fulfil these commitments where agreement is not
— Where mediation is required, documentation that
obtained. See Explanatory Note: Commitment 5 (Individual, Asset
demonstrates that the selected mediator is mutually
and Corporate level)
acceptable to the parties.
Requirement 9: Provide, or cooperate in, remediation where a
— Evidence to demonstrate that an adequate grievance
company’s activities are found to have caused or contributed to
procedure is available and has been designed with the
infringement of the rights of Indigenous Peoples. Companies will
involvement of concerned Indigenous Peoples.
establish or participate in, and make available, effective grievance
mechanisms (including, where appropriate, independent
mechanisms) to resolve disagreements and facilitate remediation.
See Explanatory Note: Commitment 9. (Individual, Asset level)

Validation Guidance Annex A 18

 Performance Expectation 3.8
Implement policies and practices to respect the rights and interests of women that reflect gender-informed
approaches to work practices and job design, and that protect against all forms of discrimination and
harassment, and behaviours that adversely impact on women’s successful participation in the workplace8.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Have the systems in place to enable and enhance women’s — Gender equality strategy.
successful participation at work.
— Mechanisms for achieving and measuring gender efforts such
Applicability: Corporate and Asset level as targets/quotas and external citation accreditation.

— Standards, procedures and programmes or agreements

governing employment and compensation are based on
objective criteria and are not discriminatory based on gender.

— Mechanisms to redress gender pay inequalities and gaps.

— Mechanisms to ensure safe and secure facilities and

appropriate uniforms and PPE.

— Mechanisms that take the caring responsibilities of all workers

into account.

— Mechanisms to monitor and address sex-based harassment

and bullying in a confidential, independent, and appropriately
sensitive manner.

— Mechanisms to evaluate and address gendered and

hypermasculine behaviours, including appropriate gender-
based awareness training and education.

Performance Expectation 3.9

Implement policies and practices to respect the rights and interests of all workers9 and improve workforce
representation in the workplace so it is more inclusive.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Recognise and value the benefits of an inclusive workforce and — DEI strategy.
have the systems in place to enable and enhance all workers’
— Standards, procedures and programmes or agreements
successful participation at work, free from all forms of
governing employment and compensation are based on
discrimination and harassment.
objective criteria and are not discriminatory. Similar agreements
Applicability: Corporate and Asset level are agreed with contractors.

Mandatory requirements of related position statement: — Mechanisms to ensure safe and secure facilities, and
Diversity, Equity, and Inclusion Position Statement appropriate uniforms and PPE.

— Mechanisms to create flexible and appropriate job design and

— Accelerate Action: In addition to our existing individual and
work practices and recognition of the differing needs of diverse
collective actions, we will develop a roadmap for diversity,
employees and contractors.
equity and inclusion that accelerates efforts to eliminate
harmful behaviours from our workplaces and communities. — Monitor and address diversity-based harassment and bullying

8. ‘Workplace’ is defined in the Health and Safety Performance Indicators Guidance, 2021, under work environment as ‘the
establishment and other locations where one or more workers are engaged in work-related activities as a condition of
employment. The work environment includes not only geographic or physical locations but also the equipment or materials
used by the worker during the course of his or her work‘.

9. All workers regardless of sex, gender, national origin, Indigeneity, age, caring responsibilities, cultural background,
ethnicity, linguistic background, physical or mental ability status, religious affiliation, sexual orientation, gender identity,
intersex status, socio-economic background and/or other categories of underrepresentation.

ICMM 19
 Performance Expectation 3.9 continued

The roadmap will outline the proximity and direction of our in a confidential, independent and appropriately sensitive
ambition, setting out key milestones to achieving our goals (see manner.
below). It will support the development and execution of
— Mechanisms to evaluate and address inappropriate behaviours,
actions that will contribute to positive social change. The
including awareness training and diversity education within the
roadmap will include the development of tools and resources
workforce.
and expand the scope of our already strong physical health
and safety practices to address psychological wellbeing.
(Collectively)

— Set Goals: We will set company goals, relevant to our operating

contexts, to eliminate all forms of harassment and
discriminatory behaviours, and improve diversity, equity and
inclusion. Further, we will agree on a collective goal or goals
aimed at creating workplaces and communities that better
reflect the aspirations of society for diversity and inclusion.
Recognising the many contextual and operating differences of
reflect the aspirations of society for diversity and inclusion.
Recognising the many contextual and operating differences of
our membership, these goals will focus on the systematic
barriers to diversity, equity and inclusion that exist across the
mining and metals industry. They will help drive and
demonstrate progress. Further, we commit to revising the goals
as they are met in order to not only to sustain, but to drive
ongoing progress. (Collectively)

— Increase Transparency: We will disclose our aggregated

performance against our goals, such that it contributes to an
appropriate depiction of mining’s impact, in accordance with
the ICMM Social and Economic Reporting Framework,

disaggregating data by gender and ethnicity 10 where possible.11

In doing so, we will identify and report on areas in which we are
not sufficiently progressing and ensure there is continued
focus on them until we fulfil our commitment. This includes
embedding objectives for diversity, equity, and inclusion into
employee engagement, stakeholder consultation, reporting
frameworks, and monitoring and evaluating our progress.
(Collectively)

— Collaborate for Greater Effect: We will seek the participation of

people from underrepresented groups in the design of the
actions set out above, as well as engaging majority groups as
advocates. By working together as members and with industry
associations, governments, communities, investors and others
we will help find solutions to these pervasive challenges and
contribute to broader industry and social cultural change.
(Collectively)

10. There may be constraints on reporting some diversity information (eg ethnicity, gender,
and disabilities) because of regulatory and data privacy limitations. ICMM members are
expected to operate within the legal and regulatory requirements of the jurisdictions in
which they operate.

11. In some operating contexts it may not be appropriate to ask workers or communities to
identify their ethnicity or other identity characteristics as it might not support the desired
outcome of addressing inequalities but have unintended consequences, eg fuelling
conflict. ICMM members should consider carefully what is appropriate in each operating
context. More information can be found under “Reporting on Diversity” in the ICMM Social
and Economic Reporting Framework.

Validation Guidance 20
Principle 4
Implement effective risk-management strategies and systems based on sound
science and which account for stakeholder perceptions of risks.

Performance Expectation 4.1

Assess environmental and social risks and opportunities of new projects and
of significant changes to existing operations in consultation with interested and
affected stakeholders, and publicly disclose assessment results.12

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Assess and understand potential environmental and social impacts — Mechanisms for requiring and conducting environmental and
of activities in consultation with stakeholders and be transparent social impact studies and assessments (ESIAs) for new
about the results. projects or significant changes to existing operations
consistent with local regulatory requirements and international
Applicability: Corporate and Asset level
standards, including those related to consultation with
interested and affected stakeholders and public disclosure.

— P
 rocess for engaging with stakeholders on the results of
environmental and social impact studies and ESIAs, as
applicable.

Performance Expectation 4.2

Undertake risk-based due diligence on conflict and human rights that aligns with
the OECD Due Diligence Guidance on Conflict Affected and High Risk Areas, when
operating in, or sourcing from, a conflict-affected or high-risk area.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Check that operations or suppliers in countries where there is — Mechanism for identification, assessment, management and
conflict or high-risk of human rights problems, do not contribute reporting of risks related to conflict and human rights.
to human rights abuses, conflict or corruption (in line with OECD
— Implementation across operations and applicable elements of
Due Diligence Guidance on Conflict-Affected and High-Risk
the supply chain.
Areas) to minimise human rights impacts in the value chain.
— Mechanisms to demonstrate implementation of risk-based due
Applicability: Corporate and Asset level
diligence practices.

— As OECD Due Diligence is an ongoing process (continuous

improvement), not required to show that all identified risks have
been fully addressed.

12. These should cover issues such as air, water, biodiversity, noise and vibration, health,
safety, human rights, gender, cultural heritage and economic issues. The consultation
process should be gender sensitive and inclusive of marginalised and vulnerable groups.

ICMM Annex A 21
 Performance Expectation 4.3
Implement risk-based controls to avoid/prevent, minimise, mitigate and/or remedy physical and psychological
health, safety and environmental impacts to workers, local communities, cultural heritage and the natural
environment, based upon a recognised international standard or management system.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Follow an international standard to manage risks to workers, local — Implementation of a risk management standard or
communities, cultural sites, physical and psychological health and management system that includes identification, assessment,
safety and the environment by avoiding them, minimising them or mitigation and control of physical and psychological health and
compensating for any adverse impacts. safety and environmental impacts to workers, local
communities, cultural heritage and the natural environment.
Applicability: Asset level
— Mechanisms to manage risk of physical/psychological harm
caused by bullying, harassment, assault, racism, sexism and all
other forms of discrimination.

Performance Expectation 4.4

Develop, maintain and test emergency response plans. Where risks to external
stakeholders are significant, this should be in collaboration with potentially affected
stakeholders and consistent with established industry good practice.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Put effective plans in place to address foreseeable or likely — Identification of foreseeable hazards and risks that could lead to
emergencies to protect human health and the environment. emergency situations.

Applicability: Asset level — E

 mergency response plan(s) prepared that meet the
requirements set forth in any applicable legislation, regulations
and established industry good practice.

— P
 lans are developed, maintained and tested in collaboration
with emergency agencies and other stakeholders who may
be affected.

Validation Guidance Annex A 22

Principle 5
Pursue continual improvement in physical and psychological health
and safety performance with the ultimate goal of zero harm.

Performance Expectation 5.1

Implement practices aimed at continually improving workplace physical and psychological
health and safety, and monitor performance for the elimination of workplace fatalities,
serious injuries, psychosocial hazards and prevention of occupational diseases, based upon
a recognised international standard or management system.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Enable and maintain a physically and psychologically safe — Practices are in place to identify, assess, eliminate, or control
workplace. health and safety hazards (including all forms of bullying,
harassment and assault) and occupational diseases at the
Applicability: Corporate and Asset level
asset.
[Note: Psychosocial hazards are aspects of work which have the
— Practices utilise established guidelines, processes and
potential to cause psychological or physical harm including
methodologies, based on recognised international standards
bullying, mental stress, workplace violence.]
or management systems.

— Prevention processes to address threat of physical and

psychological health and safety hazards and occupational
disease.

— Mechanisms to monitor performance and demonstrate

implementation of above-noted practices.

Performance Expectation 5.2

Provide workers with training in accordance with their responsibilities for
physical and psychological health and safety and implement health surveillance
and risk-based monitoring programmes based on occupational exposures.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Corporate and Asset level — Mechanisms in place for identifying and implementing health
and safety training for employees that is aligned with their job
responsibilities.

— Mechanisms in place to determine which activities are required

to have baseline and routine health surveillance, with
frequencies specified based on risk.

— Mechanisms in place to provide training, health surveillance

and risk-based monitoring for all forms of bullying, harassment
and discrimination.

— Occupational exposure limits identified and documented in line

with the activities, materials and processes to which an
employee is exposed, and procedures to follow when exposure
levels are exceeded.

— Mechanisms to demonstrate implementation of above-noted

practices.

ICMM Annex A 23
 Performance Expectation 5.3
Safeguard the health of workers against exposure to diesel particulate matter (DPM)
emissions in all underground mining operations by implementing a comprehensive
DPM management programme.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

In all underground mining operations, implement a management — Practices are in place for conducting baseline DPM
programme to monitor and mitigate exposure of workers to diesel assessments, maintaining equipment inventories, and
particulate matter. monitoring worker exposure levels.

Applicability: Corporate and Asset level — DPM Management Plan(s) are prepared and implemented with
regular internal progress reporting on DPM monitoring,
management and reduction initiatives.

— Implementation of health surveillance protocols and risk-based

monitoring programmes based on occupational exposures to
DPM.

— Mechanisms to provide training on DPM risks and control

measures, ensuring workers are informed and competent at
implementing control measures in line with established
industry good practice.

— Maintenance of organized documentation systems, including

equipment registers, performance audits and emission data
management, to support data-driven decision-making.

— Mechanisms to ensure compliance with regulatory

requirements, monitor advances in emission control practices
and identify gaps to continuously improve DPM management
practices.

Validation Guidance 24
Principle 6
Pursue continual improvement in environmental performance
issues, such as water stewardship, energy use and climate change.

Performance Expectation 6.1

Plan and design for closure in consultation with relevant authorities and stakeholders,
implement measures to address closure-related environmental and social aspects, and make
financial provision to enable agreed closure and post-closure commitments to be realised.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

The term ‘financial provision’ in the context of closure is defined in — Closure plans and closure cost estimates (liabilities) are
ICMM’s Financial Concepts for Mine Closure document. This established that comply/align with international good practice
definition should be referred to when implementing this PE. and/or applicable government regulations related to physical
and socio-economic mine closure provisioning and are
Applicability: Corporate and Asset level
updated and verified.

— Financial provision for mine closure and post-closure aspects

that considers applicable physical, chemical and socio-
economic rehabilitation requirements.

Performance Expectation 6.2

Implement water stewardship practices that provide for strong and transparent water
governance, effective and efficient management of water at operations, and collaboration
with stakeholders at a catchment level to achieve responsible and sustainable water use.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Implement an effective approach to water management that — Stakeholder engagement on water management at the
encompasses areas potentially impacted by the company’s catchment level.
activities. Water is a precious shared resource with high social,
— Identification and management of water risks and opportunities
cultural, environmental and economic value. Access to water is
relating to the asset’s activities.
recognised as a human right.
— Monitoring of water-related activities.
Applicability: Corporate and Asset level

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Water Stewardship Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 1. Apply strong and transparent corporate water — Key accountabilities for water identified and documented,
governance including clear responsibilities and accountabilities for water
governance, management and operational activities.
a. Publicly disclose the company’s approach to water stewardship.
— Short and long-term water considerations incorporated into
b. Allocate clear responsibilities and accountabilities for water –
business planning, including budgeting.
from board and corporate to site levels.
— Formal assessment of the contribution of operational water use
c. Integrate water considerations in business planning – including
to cumulative impacts in the context of other water users.
company strategy, life of asset and investment planning.
— A program for establishing context-based water targets across
d. Publicly report company water performance, material risks,
sites in water stressed areas and other areas where material
opportunities and management response using consistent
water related risks exist.
industry metrics and recognised approaches.
— Targets in place on key water-related metrics, such as reducing
(Individual, Corporate level)
freshwater reliance, and monitored.

ICMM Annex A 25
 Performance Expectation 6.2 continued

Requirement 2. Manage water at operations effectively — Documented assessment of catchment-level, water-related

risks and opportunities in line with risk management processes.
a. Maintain a water balance and understand how it relates to the
cumulative impact of other users. — Documented plans for or records of work with governments,
local authorities and other stakeholders at the catchment and
b. Set context-relevant water targets or objectives for sites with
broader level to advance or improve water stewardship
material water-related risks.
outcomes.
c. Proactively manage water quantity and quality to reduce
potential socio-environmental impacts and realise
opportunities.

d. Ensure all employees have access to clean drinking water,

gender-appropriate sanitation facilities and hygiene at their
workplace.

(Individual, Asset level)

Requirement 3. Collaborate to achieve responsible and

sustainable water use

a. Identify, evaluate, and respond to catchment-level water-

related risks and opportunities.

b. Identify and engage proactively and inclusively with

stakeholders that may influence or be affected by a site’s water
use and discharge.

c. Actively engage on external water governance issues, with

governments, local authorities and other stakeholders, to
support predictable, consistent and effective regulation that
underpins integrated water resource management.

d. Support water stewardship initiatives that promote better water

use, effective catchment management and contribute to
improved water security and sanitation.

(Individual, Corporate and Asset level)

Validation Guidance Annex A 26

 Performance Expectation 6.3
Design, construct, operate, monitor and decommission tailings disposal/storage facilities using
comprehensive, risk-based management and governance practices in line with internationally
recognised good practice, to minimise the risk of catastrophic failure.13, 14

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Tailings storage facilities are to be managed in a way that prevents — Identification and management of risks and opportunities
failures. Catastrophic failures are unacceptable and can cause relating to the asset’s tailings facilities.
significant damage to human health and the environment.
— Accountability, responsibility and competency for individuals
Applicability: Corporate and Asset level involved in the management of risks and opportunities relating
to the asset’s tailings facilities.

— Planning and resourcing of tailings-related activities.

— Change management processes for tailings facilities and

related activities.

— Emergency preparedness & response planning undertaken for

tailings-related incidents.

— Review & Assurance of tailings-related activities as

appropriate.

— Monitoring of tailings-related activities.

— Stakeholder engagement on tailings management.

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Tailings Governance Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 1. Accountability, responsibility and competency: For additional examples of evidence for the Tailings Governance
Accountabilities, responsibilities and associated competencies are Position Statement , refer to the relevant section of the
defined to support appropriate identification and management of Conformance Protocols for the Global Industry Standard on
TSF risks. Tailings Management.

— Accountability for the overall governance of tailings facilities

resides with the owners and operators.

— Organisational structures and roles are established to support

management of TSF risks and governance accountability.

— Communication processes are maintained to ensure that

personnel understand their responsibilities. Training is
conducted to maintain currency of knowledge and skills.

— Role competency and experience requirements are defined for

critical roles within the established organisational structures.
(Individual, Corporate and Asset level)

13. As of 5 August 2020, all ICMM members committed to implement the Global Industry
Standard on Tailings Management (GISTM). All tailings facilities operated by members with
“Extreme” or “Very high” potential consequences will be in conformance with the Standard
by 5 August 2023. All other tailings facilities operated by members not in a state of safe
closure will be in conformance with the Standard by 5 August 2025.

14. Riverine tailings, freshwater lake and/or shallow marine tailings disposal may be
considered only if deemed to be the most environmentally and socially sound alternative,
based on an objective and rigorous environmental and social impact assessment of tailings
management alternatives. The scope of the assessment should be agreed between the
company member and the host government.

ICMM Annex A 27
 Performance Expectation 6.3 continued

Requirement 2. Planning and resourcing: The financial and human

resources needed to support continued TSF management and
governance are maintained throughout a facility’s life cycle.

— TSF operating and capital costs, and human resource needs,

are included in relevant business planning processes.

— Resources necessary to implement and maintain activities

within this governance framework are provided.

(Individual, Corporate and Asset level)

Requirement 3. Risk management: Risk management associated

with TSFs includes risk identification, an appropriate control regime
and the verification of control performance.

— Risk controls and their associated verification activities are

identified based on failure modes and their associated
consequences, and evaluated on a TSFspecific basis
considering all phases of the TSF life cycle.

— Suitably qualified and experienced experts are involved in TSF

risk identification and analysis, as well as in the development
and review of effectiveness of the associated controls.

— Performance criteria are established for risk controls and their

associated monitoring, internal reporting and verification
activities.

(Individual, Corporate and Asset level)

Requirement 4. Change management: Risks associated with

potential changes are assessed, controlled and communicated to
avoid inadvertently compromising TSF integrity.

— Processes are applied that involve the identification,

assessment, control and communication of risks to TSF
integrity arising from both internally driven and externally driven
change, to avoid introducing uncertain, unacceptable, and/ or
unmanaged risks.

— Documents and records that support TSF planning, design,

construction, operation, surveillance, management and
governance are maintained and kept suitably current and
accessible.

(Individual, Corporate and Asset level)

Requirement 5. Emergency preparedness & response: Processes

are in place to recognise and respond to impending failure of TSFs
and mitigate the potential impacts arising from a potentially
catastrophic failure.

— Action thresholds and their corresponding response to early

warning signs of potential catastrophic failure are established.

— Emergency preparedness and response plans are established

commensurate with potential failure consequences. Such plans
specify roles, responsibilities and communication procedures.

— Emergency preparedness and response plans are periodically

tested.

(Individual, Corporate and Asset level)

Validation Guidance Annex A 28

 Performance Expectation 6.3 continued

Requirement 6. Review & assurance: Internal and external review

and assurance processes are in place so that controls for TSF risks
can be comprehensively assessed and continually improved.

— Internal performance monitoring and inspections and internal

and external reviews and assurance are conducted
commensurate with consequences of TSF failure to evaluate
and to continually improve the effectiveness of risk controls.

— Outcomes and actions arising from TSF review and assurance

processes are recorded, reviewed, closed-out and
communicated.

— Performance of risk management programs for TSFs is

reported to executive management on a regular basis.

(Individual, Corporate and Asset level)

Performance Expectation 6.4

Apply the mitigation hierarchy to prevent pollution, manage releases and waste,
and address potential impacts on human health and the environment.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Asset level — Practices are in place to identify, assess, and control sources of
potential pollution and their impacts on human health and the
environment.

— Sources of potential pollution are controlled in accordance with

the mitigation hierarchy: avoid, reduce, reuse, recycle and
dispose.

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Mercury Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 1. Not open any mines designed to produce mercury — Disclosure of significant point source mercury emissions from
as the primary product. (Individual, Corporate level) operations.

Requirement 2. Apply materials stewardship to promote the

responsible management of the mercury produced from ICMM
members’ operations including that which naturally occurs in our
products. (Individual, Corporate level)

Requirement 3. Identify and quantify point source mercury air

emissions from our operations and minimise them through the
application of cost effective best available technology, using a risk
based approach. (Individual, Asset level)

Requirement 4. Report significant point source mercury emissions

from our operations consistent with our commitment to report in
accordance with the GRI framework. Members who report against
the European Sustainability Reporting Standards (ESRS) can report
‘with reference to’ GRI. (Individual, Corporate level)

ICMM Annex A 29
 Performance Expectation 6.5
Implement measures to improve energy efficiency and contribute to a low-carbon future, and report the
outcomes based on internationally recognised protocols for measuring CO2 equivalent (GHG) emissions.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Corporate and Asset level — Practices in place to identify, assess and implement energy and
carbon efficiency measures.

— Monitor progress on energy, climate adaptation and low-

carbon actions. Review and revise as necessary.

— Report outcomes of energy and carbon risk and opportunity

assessments and action planning based on internationally
recognised protocols for measuring GHG emissions.

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Climate Change Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 1. Setting Scope 1 and 2 targets: We will build clear — Public disclosure of net zero commitment by 2050 or sooner.
pathways to achieving net zero Scope 1 and 2 GHG emissions by
— Public short and/or medium-term targets in place, covering
2050 or sooner, through meaningful short and/or medium-term
Scope 1 and Scope 2 emissions. Public commitment on a
targets. (Individual, Corporate level)
Scope 3 emissions reduction target.
Requirement 2. Accelerating action on Scope 3 GHG emissions:
— Defined board and executive roles and responsibilities in
We recognise that Scope 3 is critical to minimising our overall
implementing climate change strategy, and assessing and
impact and we will set Scope 3 targets, if not by the end of 2023,
managing climate-related risks and opportunities.
as soon as possible. Although all Scope 3 action depends on the
combined efforts of producers, suppliers and customers, some — Publicly available climate resilience strategy that includes host
commodities face greater technological and collaborative barriers community approaches, taking into consideration different
than others. We will play a leading role in overcoming these barriers climate-related scenarios.
and advancing partnerships that enable credible target setting and
— Records of engagement with host communities on climate
emission reductions across value chains. (Individual, Corporate
resilience.
level)
— Public reporting of progress on Scopes 1, 2 and 3 aligns with
Requirement 3. Covering all material sources: Our targets will
TCFD and has been externally verified.
cover all material sources of emissions, aligning to the GHG
Protocol definition of organisational boundaries and materiality.
(Individual, Corporate level)

Requirement 4. Focussing on absolute reductions: For some

operations, intensity rather than absolute targets may be more
appropriate in the short and medium term. Where intensity targets
are used, we will disclose the corresponding absolute increase or
decrease in GHG emissions. (Individual, Corporate level)

Requirement 5. Applying robust methodologies: We will use target

setting methodologies that are aligned with the ambitions of the
Paris Agreement and disclose in detail the assumptions we use.
(Individual, Corporate level)

Requirement 6. Integrating climate change in decision-making:

Implement governance, engagement, and disclosure processes to
ensure climate change risks and opportunities are considered in
business decision making. (Individual, Corporate level)

Validation Guidance Annex A 30

 Performance Expectation 6.5 continued

Requirement 7. Adaptation and Mitigation: Advance operational

level adaptation and mitigation solutions that can support the net
zero goal, taking in consideration local opportunities and
challenges. (Individual, Asset level)

Requirement 8. Supporting community resilience: Engage with

host communities on our shared climate change risks and
opportunities and help host communities understand how they can
adapt to the physical impact of climate change. (Individual, Asset
level)

Requirement 9. Disclosing openly and transparently: We will

report our progress on Scopes 1, 2 and 3 annually, obtain external
verification over our performance, and report in alignment with the
recommendations of the Task Force on Climate related Financial
Disclosures. (Individual, Corporate level)

Requirement 10. Engage with governments, peers, and others to

support the development of effective climate change policies.
(Individual or collective, validation at discretion of member)

Requirement 11. Support efforts to mitigate greenhouse gas

emissions, in collaboration with our peers by promoting innovation,
developing and deploying low emissions technology, and
implementing projects that improve energy efficiency and
incorporate renewable energy supply in our energy mix. (Individual
or collective, validation at discretion of member)

Requirement 12. Support carbon pricing and other market

mechanisms, that drive the reduction of greenhouse gas
emissions, deliver the least cost pathway to emissions reductions
and support predictable long-term pricing that incentivise
innovation. (Individual or collective, validation at discretion of
member)

NB. on Commitment 12: The position statement is not intended to

substitute for or pre-empt any requirement of applicable national
law, and where conflicts or duplication arise, applicable law shall
prevail.

ICMM Annex A 31
Principle 7
Contribute to the conservation of biodiversity
and integrated approaches to land-use planning.

Performance Expectation 7.1

Neither explore nor develop new mines in UNESCO World Heritage sites, respect legally
designated protected areas, and design and operate any new operations or changes to
existing operations to be compatible with the value for which such areas were designated.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and
position statement and what evidence do you have to
demonstrate this? For example:

Do not explore or develop new mines in UNESCO World Heritage — Policy or equivalent in place to prohibit the exploration or
Sites and avoid impacting the key cultural and biodiversity values of development of new mines in UNESCO World Heritage Sites.
other legally designated protected areas.
— Practices in place to identify, assess and mitigate (per 7.2)
Applicability: Corporate and Asset level potential adverse impacts related to legally designated
protected areas.
Mandatory requirements of related position statement:
— Conduct ecosystem services analysis, or similar evaluation, to
Nature Position Statement
understand value for which potential risk areas were
Requirement 1.1: Respect legally designated protected areas and designated and to provide that design and implementation
ensure that any new operations or changes to existing operations provide comparable direct and indirect contributions to human
are not incompatible with the objectives for which the protected well-being and biodiversity.
areas were established. (Individual, Corporate and Asset level)

Requirement 1.2: Not explore or mine in UNESCO World Heritage

sites. All reasonable steps will be taken to ensure that existing
operations in World Heritage sites as well as existing and future
operations adjacent to World Heritage sites are not incompatible
with the outstanding universal value for which these sites are listed
and do not put the integrity of these sites at risk. (Individual,
Corporate and Asset level)

Validation Guidance Annex A 32

 Performance Expectation 7.2
Assess and address material risks and impacts to biodiversity and ecosystem
services by implementing the mitigation hierarchy , to achieve a minimum of
no net loss (NNL) or net gain of biodiversity by completion of closure.15

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and
position statement and what evidence do you have to
demonstrate this? For example:

Assess the material risks and impacts to biodiversity and the — Policies, programmes, systems or practices in place to assess
benefits humans derive from nature and its functioning ecosystem and address potential risks and adverse impacts to biodiversity
(ecosystem services). The mitigation hierarchy should then be and ecosystem services.
applied where significant risks and impacts to biodiversity and
— Where significant risks and impacts to biodiversity and
ecosystem services have been identified: Avoid impacts where
ecosystem services have been identified, evidence that the
possible and otherwise minimise impacts, restore key biodiversity
approach included within policies, programmes, systems,
features that have been degraded or damaged, or compensate for
action plans or practices embeds the mitigation hierarchy, with
residual adverse impacts that could not otherwise be mitigated. For
an avoidance-first focus, then minimisation followed by
all new projects or significant expansions to existing projects the
progressive restoration, rehabilitation and/or reclamation and
mitigation hierarchy should be applied to balance any losses of key
finally offsetting commenced as early as possible for residual
biodiversity features with gains, to achieve a minimum of no net
adverse impact .
loss or net gain.
— Application of the mitigation hierarchy should also include a
statement of the intended outcome, that is the achievement of
Applicability: Corporate and Asset level a minimum of no net loss (NNL) or net gain of biodiversity,
within policy, program or systems, action plans and practices
Mandatory requirements of related position statement: for any new or significant expansions to existing projects.
Nature Position Statement
— Evidence to demonstrate implementation of above-noted
Requirement 1.3: Assess and address material† risks and impacts policies etc. For any new projects and significant expansions to
to biodiversity and ecosystem services by implementing the existing projects, this should include evidence of progress
mitigation hierarchy† actions to achieve a minimum of no net loss towards the achievement of a minimum no net loss or net gain.
(NNL) or net gain of biodiversity by completion of closure.7† Please see the Cross-Sector Biodiversity Initiative good practice
This includes through: tools for definitions and guidance. Members are also referred to IFC
Performance Standard 6 and its associated Guidance Note for
— Applying the mitigation hierarchy with an avoidance-first focus further information.
from the earliest feasible stage of exploration and continuing
throughout project lifecycles,

— Pursuing progressive restoration, rehabilitation and/or

reclamation† where feasible, and commencing with offsets for
residual adverse impacts as early as possible, and

— Transparently disclosing the relevant methodology used to

calculate no net loss or net gain, objectives and site-level
performance in 2030, 2040 and 2050, or more frequently.

For all new operations and significant expansions, no net loss or

net gain should be measured against a pre-operation or pre-
expansion baseline respectively. For existing operations† , this
should be measured against a 2020 or earlier baseline. For future
acquisitions, the baseline should be the date of takeover or earlier.
Where no net loss is not feasible at existing operations, disclose
how the mitigation hierarchy and additional conservation actions†
are applied to appropriately address negative impacts on
biodiversity(Individual, Asset level)

15. Achieving a minimum of no net loss or net gain by closure applies to new projects,
existing projects and major expansions to existing projects that impact biodiversity and
ecosystem services

ICMM Annex A 33
Principle 8
Facilitate and support the knowledge-base and systems for responsible design,
use, re-use, recycling and disposal of products containing metals and minerals.

Performance Expectation 8.1

In project design, operation and de-commissioning, implement cost-effective measures
for the recovery, re-use or recycling of energy, natural resources, and materials.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Corporate and Asset level — S

 ustainable development principles have been integrated into
the project design. For example, the asset has taken steps to
increase energy and water efficiency.

— Practices are in place to identify, analyse (eg cost-benefit,

lifecycle) and implement measures to economically recover,
recycle and re-use energy, natural resources and materials
throughout the life of the asset.

— Mechanisms in place to demonstrate the above-noted

practices.

Performance Expectation 8.2

Assess the hazards of the products of mining according to UN Globally Harmonized
System of Hazard Classification and Labelling or equivalent relevant regulatory systems
and communicate through safety data sheets and labelling as appropriate.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

It is important to emphasise that this PE relates to the products of — P

 ractices are in place to identify, assess and classify the
mining as opposed to any potential inputs. hazards of the products of the asset according to UN Globally
Harmonized System of Hazard Classification and Labelling or
Applicability: Corporate and Asset level
equivalent relevant regulatory mechanism.

— Communicate the hazards of products to internal and external

stakeholders, as appropriate, through safety data sheets for
hazardous substances and clearly labelled containers and
packaging with information regarding hazardous substances.

Validation Guidance Annex A 34

Principle 9
Pursue continual improvement in social performance
and contribute to the social, economic and institutional
development of host countries and communities.

Performance Expectation 9.1

Implement inclusive approaches with local communities to identify their development priorities
and support activities that contribute to their lasting social and economic wellbeing, in partnership
with government, civil society and development agencies, as appropriate.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Support community development through participatory — Participatory engagement practices are implemented to
engagement and partnerships to build trust and to achieve lasting identify, assess and implement community development
social and economic wellbeing. activities that address priorities with the intent that
communities can thrive, including post-closure.
Applicability: Corporate and Asset level
— Community development activities designed and implemented
in partnership with government, civil society and development
agencies where appropriate.

— Community development activities are designed and

implemented with principles of DEI in mind to address risks
associated with all forms of discrimination.

— Mechanisms in place to demonstrate the above practices.

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Mining Partnerships for Development Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 1. Either individually or collectively through ICMM — Mechanisms in place to understand social and economic
publicly express their willingness to work in partnership with contributions of projects, and evidence of engagement with
development agencies, host governments, civil society other stakeholder groups with the aim of ensuring the project’s
organisations, and local communities to enhance mining and potential socio-economic contribution is realised.
metals’ contribution to social and economic development.
— Process for evaluation of success of partnerships and
(Individual or collective, validation at discretion of member)
collaborations.
Requirement 2. For major investments in regions where socio-
— For additional examples of evidence for the Mining
economic outcomes are highly uncertain or where there are
Partnerships for Development Position Statement , refer to
significant opportunities to enhance such outcomes: (i) develop an
the relevant section of the Social and Economic Reporting
understanding of the social and economic contribution of the
Framework.
project, including an analysis of the barriers that might weaken this
contribution; and (ii) actively support or help develop partnerships
or collaborations with other stakeholder groups with the aim of
ensuring the project’s potential socio-economic contribution is
realised. (Individual, Asset level)

Requirement 3. Review the relative success of their development

partnerships and collaborations at suitable intervals and adapt
these over time to ensure they continue to contribute to the overall
goal of enhancing the social and economic contribution of mining.
(Individual, Asset level)

ICMM Annex A 35
 Performance Expectation 9.2
Enable access by local enterprises to procurement and contracting opportunities across the
project life cycle, both directly and by encouraging larger contractors and suppliers, and also
by supporting initiatives to enhance economic opportunities for local communities.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Corporate and Asset level — Consultation with local communities, to define, identify,
communicate and promote procurement opportunities for local
enterprises or contractors, directly and with larger contractors
and suppliers.

— Process in place to enable access to opportunities, if they exist.

— Consultation with local communities to identify, assess and

support initiatives to enhance their economic opportunities.

— Procurement activities are designed and implemented with

principles of DEI in mind to address risks associated with all
forms of discrimination. This may include expectations of
minimum DEI standards for contractors.

— Mechanisms in place to demonstrate the above-noted

practices.

Performance Expectation 9.3

Conduct stakeholder engagement based upon an analysis of the local context,
including with human rights defenders and other vulnerable groups7, and provide
local stakeholders with access to appropriate and effective mechanisms for
seeking resolution of grievances related to the company and its activities.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

An important part of community relations is to identify and resolve — Stakeholder mapping based on, for example, type of
stakeholders’ concerns. Companies need to understand who may stakeholder, level of influence, and capacity to engage.
be impacted by or influence their activities, in order to support
— Stakeholder engagement informed by social, economic and
lasting social and economic progress.
environmental assessments/baseline studies which have
Applicability: Asset level included consultation with human rights defenders and other
vulnerable groups.

— Stakeholder engagement activities are designed and

implemented with principles of DEI in mind to address risks
associated with all forms of discrimination.

— Grievance mechanism fit for purpose and aligned with the UN

Guiding Principles on Business & Human Rights.

— Monitoring for effectiveness of stakeholder engagement and

grievance resolution activities.

Validation Guidance Annex A 36

 Performance Expectation 9.4
Collaborate with government, where appropriate, to support improvements in
environmental and social practices of local Artisanal and Small-scale Mining (ASM).

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and
position statement and what evidence do you have to
demonstrate this? For example:

Support the efforts of local Artisanal and Small-Scale Miners (ASM) — Practices in place to collaborate with government and other
to operate in a manner that minimises impacts to human health stakeholders to identify and assess the risks and opportunities
and the environment. associated with ASM, and to establish a support mechanism or
control strategy, as appropriate.
Note: If ASM exists but the artisanal miners do not wish to engage
with either the member or the government, the PE should be — Mechanisms in place to demonstrate the above practices as
deemed ‘Not applicable’ and the reason for doing so should be well as provide environmental, health, safety or social support
clearly stated. or improvements related to ASM activities.

Applicability: Asset level

Mandatory requirements of related position statement:

Mercury Position Statement

Requirement 5. To participate in government-led partnerships to

transfer low- to no-mercury technologies into the ASM sector in
locations where ICMM member companies have operations in
close proximity to ASM activity such that livelihoods are enhanced
through increased productivity and reduced impacts to human
health. (Individual, Asset level)

ICMM Annex A 37
Principle 10
Proactively engage key stakeholders on sustainable development challenges
and opportunities in an open and transparent manner. Effectively report and
independently verify progress and performance.

Performance Expectation 10.1

Identify and engage with key corporate-level external stakeholders on
sustainable development issues in an open and transparent manner.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Corporate level — Practices are in place to identify and engage with key
corporate-level external stakeholders on issues relevant to the
stakeholder.

— Engagement includes the provision of relevant sustainable

development information to the stakeholders, provided in a
comprehensive, accurate, timely, accessible and balanced way,
using suitable reporting principles, frameworks and guidelines
that support comparability of information.

Performance Expectation 10.2

Publicly support the implementation of the Extractive Industries Transparency Initiative (EITI) and compile
information on all material payments, at the appropriate levels of government, by country and by project.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Support efforts to promote transparency and good governance of — Public policy or commitment supporting the implementation of
natural resources in collaboration with EITI. the EITI.

Applicability: Corporate and Asset level — Mechanisms to determine all material payments through the
country-specific EITI process and through engagement with
national multi-stakeholder groups, including government,
companies and civil society.

— E
 ITI principles integrated into asset guidelines or policies,
where appropriate.

— M
 onitoring, evaluation and reporting to demonstrate outcomes
and impacts of the EITI process from a government and
industry, company or project level.

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Transparency of Mineral Revenues Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 1. Include a clear endorsement of efforts at the — Disclosure of material payments at a country and project-level.
international level to enhance the transparency of mineral
— Mineral development contracts (post 1 January 2021) are
revenues, including EITI, on their website and/or in their sustainable
publicly disclosed.
development reports. To submit a completed international level
self-assessment form to the EITI Secretariat for posting on the EITI
website. (Individual, Corporate level)

Validation Guidance Annex A 38

 Performance Expectation 10.2 continued

Requirement 2. Engage constructively in countries that are

committed to implementing EITI, consistent with the multi-
stakeholder process adopted in each country. (Individual,
Corporate level)

Requirement 3. Compile information on all material payments by

country and by project at the appropriate levels of government. In
the case of EITI implementing countries, this should be provided to
the body assigned responsibility for reconciling details of payments
by companies and revenue data provided by government
according to the agreed national template. Material payments by
companies are expected to have been independently audited,
applying international standard accounting practices. (Individual,
Corporate level)

Requirement 4. Support the public disclosure (i.e. publication) of

material payments by country and by project. For EITI, this should
be in line with the implementation approach adopted in country.
(Individual, Corporate and Asset level)

Requirement 5. Engage constructively in appropriate forums to

improve the transparency of mineral revenues – including their
management, distribution or spending –either individually or
collectively through ICMM. (Individual or collective, validation at
discretion of member)

Requirement 6. Disclose all mineral development contracts granted

or entered into from 1 January 2021 that they have signed with host
governments, where such disclosure is not prohibited by law or
regulation. (Individual, Corporate level)

ICMM Annex A 39
 Performance Expectation 10.3
Report annually on economic, social and environmental performance
at the corporate level using the GRI Sustainability Reporting Standards
or the European Sustainability Reporting Standards (ESRS).

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Members who are required to report against the European Mechanisms in place to measure, monitor and publicly report
Sustainability Reporting Standards (ESRS) can report ‘with sustainability performance using the GRI Sustainability Reporting
reference to’ GRI and do not need to undertake additional reporting Standards or the European Sustainability Reporting Standards
to also report ‘in accordance’ with GRI Sustainability Reporting (ESRS).
Standards.

All other members continue to report ‘in accordance’ with GRI.

Applicability: Corporate level

Mandatory requirements of related position statement: What are you doing to achieve the intent of the
Mining Partnerships for Development Position Statement position statement and what evidence do you have
to demonstrate this? For example:

Requirement 4. Provide an overview of their work on such — Content in external reporting and communications relating to
partnerships, as appropriate, in their annual external reporting and work on partnerships.
communications. (Individual, Corporate level)
— For additional examples of evidence for the Mining
Partnerships for Development Position Statement , refer to the
relevant section of the Social and Economic Reporting
Framework.

Performance Expectation 10.4

Each year, conduct independent assurance of sustainability performance
following the ICMM guidance on assuring and verifying membership requirements.

Remarks to clarify the intent and/or applicability of the PE What are you doing to achieve the intent of the PE and what
evidence do you have to demonstrate this? For example:

Applicability: Corporate level — Mechanisms to conduct independent assurance.

— Independent assurance statement issued by the assurance

provider and included as part of the annual sustainability report.

Validation Guidance Annex A 40

Annex B: 03
Position Statement
Commitments and
Applicability

ICMM Annex B 41
Position Statement
Commitments and Applicability

The table below outlines the commitments from ICMM’s position statements.

The first column gives the position statement title and ‘Collectively’ to members and are therefore not
date of issue. The second outlines the commitments in applicable to validation (n/a). The ‘Related PE’ column
full – but does not include footnotes. The full text of the identifies which of the PEs the position statement
position statements including footnotes are available commitments connect to. The last three columns
here. The ‘Application’ column identifies which indicate whether a position statement commitment is
commitments apply to individual member companies applicable at a Corporate level, Asset level, or both a
(mandatory requirements) and should be considered Corporate and Asset level, for the purposes of
during validation. It identifies those that may be validation. Where position statement commitments
delivered ‘Individually or collectively’ (ie collectively apply either ‘individually or collectively’, member
through membership of ICMM) and may or may not be companies have sole discretion to choose whether or
relevant to validation. It also identifies those that apply not to include them within the scope of validation.

Applicability for PE
Position statements

Validation
Commitments

Application

Related PE

Corporate

Asset

Both
1. 1. Respect Indigenous Peoples’ rights by embedding measures across Individual 3.6
Mining and governance and management processes to avoid infringing members
Indigenous Indigenous Peoples’ rights, and to adequately address potential
Peoples adverse impacts to rights from mining and mining-related projects.
(July 2024) This includes developing and implementing policy commitments and
promoting cross-cultural understanding and awareness through
relevant educational programmes to meet the responsibility to
respect Indigenous Peoples’ rights. It also includes supporting efforts
for reconciliation with Indigenous Peoples and the advancement of
the exercise of their rights, where appropriate. See Explanatory Note:
Commitment 1.

2. Carry out due diligence to identify, prevent, mitigate and account for Individual 3.6
possible adverse impacts on Indigenous Peoples’ rights. Due members
diligence processes should include the early and comprehensive
identification of and meaningful engagement with Indigenous
Peoples who may be affected by a project. The process should
respect Indigenous Peoples’ right to participate in decision-making
on matters that affect them and be guided by the principles of FPIC.
Due diligence should also seek to prevent or mitigate potential
adverse impacts on Indigenous Peoples’ rights that may be caused
or contributed to by companies or directly linked to their operations,
products or services by their business relationships. Due diligence
should be ongoing, recognising that the risks to Indigenous
Peoples’ rights may change over time as a company’s operations
and/or operating context evolves. See Explanatory Note:
Commitment 2.

Validation Guidance Annex B 42

©Codelco
 Applicability for PE
Position statements

Validation
Commitments

Application

Related PE

Corporate

Asset

Both
3. Agree on appropriate engagement processes with potentially Individual 3.6
affected Indigenous Peoples and relevant State authorities as early members
as possible in project planning. This is to enable their inclusive,
equitable and meaningful participation in due diligence processes
and for the good faith negotiation of agreements that can
demonstrate their consent. Engagement processes should be
co-designed, culturally appropriate, inclusive and carried out through
the procedures, protocols and governance structures of potentially
affected Indigenous Peoples. Where Indigenous Peoples do not have
access to the legal or other technical support necessary to
participate equitably in negotiation, companies will offer them
reasonable financial or other agreed-upon assistance as required.
See Explanatory Note: Commitment 3.

4. O
 btain agreement with affected Indigenous Peoples demonstrating Individual 3.7
their consent to anticipated impacts to their land or other rights, members
and setting out the terms by which impacts may occur and be
managed. In accordance with the principles of FPIC, agreement
should be achieved through informed and meaningful engagement
and good faith negotiation, through means that advance
intercultural understanding and that facilitate freely giving or
withholding agreement. The agreement should include, at a
minimum, demonstration of consent to anticipated impacts,
mitigation measures developed through the due diligence process,
and a redress mechanism for potential infringements of the
agreement or of Indigenous Peoples’ rights. It is expected that the
agreement be faithfully implemented, with ongoing monitoring
supporting the effective realisation of the terms of the agreement
(and conditions therein). When a project is to be developed within
Indigenous Peoples’ lands or territories, or otherwise with
substantial anticipated impacts on their rights, the agreement
should also include benefit sharing.

Where potential impacts include the relocation of Indigenous

Peoples from their lands or territories, or significant impacts to their
critical cultural heritage, companies will explore feasible alternatives
to project design in order to avoid such impacts. If relocation and/or
significant impacts on critical cultural heritage are unavoidable,
companies will obtain an agreement demonstrating the consent of
affected Indigenous Peoples in accordance with this Commitment.
See Explanatory Note: Commitment 4

ICMM Annex B 43
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5. A
 ddress differences of opinion that arise and work to resolve Individual 3.7
disagreements. ICMM members recognise that achieving members
agreement and demonstrating such consent, can enable long-term
relationships based on mutual respect, trust and benefit. Hence,
ICMM members will start from the position that a proposed project
or activity should proceed with agreement as outlined in
Commitment 4. Recognising that there may be circumstances in
which agreement is not obtained, this Position Statement sets out
the process that ICMM members will take in this instance. ICMM
members will develop a policy or approach outlining the steps they
have taken to fulfil these commitments where agreement is not
obtained. See Explanatory Note: Commitment 5.

6.  nable benefit sharing that reflects and is aligned with Indigenous

E Individual 3.6
Peoples’ aspirations for social and economic development. Benefit members
sharing should be equitably distributed and facilitate positive
outcomes that extend beyond the life of operations. See
Explanatory Note: Commitment 6.

7.  espect and incorporate Indigenous knowledge in collaboration

R Individual 3.6
with Indigenous Peoples through the design and implementation of members
due diligence and methods of engagement; in agreements for
benefit sharing, sustainable environmental and social investment
programmes; and in closure planning and execution. Respect that
Indigenous Peoples have the right to maintain, control and protect
their Indigenous knowledge and knowledge systems. Respect and
support Indigenous cultural and intellectual property and obtain
permission if collecting, storing, accessing, using and/or reusing
cultural and intellectual information and knowledge. See
Explanatory Note: Commitment 7.

8. R
 espect and celebrate cultural heritage, both tangible and Individual 3.6
intangible, and the historical and ongoing spiritual connections of members
Indigenous Peoples to such heritage, particularly prioritising the
avoidance of impacts on cultural heritage that is critical to
Indigenous Peoples’ cultures or spiritual life. This includes
collaborating with Indigenous Peoples to identify risks to and
potential adverse impacts on cultural heritage from proposed
activities and developing mitigation measures and management
plans through due diligence and agreement-making. Companies
will also promote, celebrate and support the revival of cultural
heritage where appropriate and agreed upon by Indigenous
Peoples. See Explanatory Note: Commitment 8.

9. P
 rovide, or cooperate in, remediation where a company’s activities Individual 3.7
are found to have caused or contributed to infringement of the members
rights of Indigenous Peoples. Companies will establish or
participate in, and make available, effective grievance mechanisms
(including, where appropriate, independent mechanisms) to resolve
disagreements and facilitate remediation. See Explanatory Note:
Commitment 9.

Validation Guidance Annex B 44

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2. 1. Direct operations
Nature
1.1. Respect legally designated protected areas and ensure that any Individual 7.1
(Jan 2024)
new operations or changes to existing operations are not members
Note: For incompatible with the objectives for which the protected areas were
sections which established.
include
optionality of 1.2. Not explore or mine in UNESCO World Heritage sites. All reasonable Individual 7.1
commitments, steps will be taken to ensure that existing operations in World members
members Heritage sites as well as existing and future operations adjacent to
should include World Heritage sites are not incompatible with the outstanding
the universal value for which these sites are listed and do not put the
commitment/s integrity of these sites at risk.
of their choice
in their annual 1.3. Assess and address material† risks and impacts to biodiversity and Individual 7.2
reporting, but ecosystem services by implementing the mitigation hierarchy† members
do not need to actions to achieve a minimum of no net loss (NNL) or net gain of
mention, nor biodiversity by completion of closure.
mark as N/A, This includes through:
the remaining
commitments — Applying the mitigation hierarchy with an avoidance-first focus
which they from the earliest feasible stage of exploration and continuing
have not throughout project lifecycles,
chosen to — Pursuing progressive restoration, rehabilitation and/or
report on. reclamation† where feasible, and commencing with offsets for
residual adverse impacts as early as possible, and

— Transparently disclosing the relevant methodology used to

calculate no net loss or net gain, objectives and site-level
performance in 2030, 2040 and 2050, or more frequently.

For all new operations and significant expansions, no net loss or net
gain should be measured against a pre-operation or pre-expansion
baseline respectively. For existing operations, this should be
measured against a 2020 or earlier baseline. For future acquisitions,
the baseline should be the date of takeover or earlier.

Where no net loss is not feasible at existing operations, disclose

how the mitigation hierarchy and additional conservation actions
are applied to appropriately address negative impacts on
biodiversity.

2. V
 alue chain
Partnering with suppliers, customers and key stakeholders to support value chain action for nature by 2030 through
commitments to:

2.1. Either individually or collectively, identify: (a) key supplier sourcing Individually or n/a Validation at
locations and product distribution routes with significant† nature- collectively discretion of
related risk and (b) opportunities for collaborative action. member.

ICMM Annex B 45
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2.2. Based on the opportunities identified, engage in or support Individually or n/a Validation at
initiatives or partnerships to help halt and reverse nature loss in the collectively discretion of
company’s upstream, and/or downstream value chain. member.

2.3. Roll-out requirements for all highest risk tier 1 (direct) suppliers to Individual n/a
conduct and disclose the outcomes of nature-related impact, members
dependency, risk and opportunity assessments for activities in
priority locations .

3. Landscapes
Collaborating and building capacity with local and regional partners, including Indigenous Peoples, land-connected
peoples and local communities, to support and enhance healthy, resilient ecosystems and the livelihoods and
wellbeing of people that depend on them. By 2030, ICMM company members commit to working with key
stakeholders to identify shared landscape scale material risks and opportunities and to address these through
enhancing or implementing one or more of the following options in priority landscapes.

3.1. Restore, Conserve and Regenerate: Contribute towards the GBF Individual n/a
targets of (a) placing 30 per cent of terrestrial, inland water area, members
and marine and coastal areas under conservation globally or (b)
placing 30 per cent of degraded areas under restoration globally;
for example through funding, building capacity or executing
conservation or restoration initiatives.

3.2. Collaborative Landscape-scale Action: Support and proactively Individual n/a

engage in halting and reversing nature loss in partnership with key members
stakeholders, through capacity building and co-developing
initiatives that address cumulative impacts and/or enhance the
conservation, restoration and climate resilience of nature.

3.3. R
 epurpose and Regenerate: Participate in collaborative initiatives Individual n/a
repurposing and harnessing value from abandoned or legacy mine members
sites and mining waste streams to halt and reverse the loss of
nature.

4. S
 ystems transformation
Creating the enabling conditions to catalyse broader nature positive change and transformation within and beyond
our industry by 2030. ICMM company members commit to implementing one or more of the following options, either
individually or as coalitions of members:

4.1. C
 ollaborative Research and Development: Contribute to research Individually or n/a Validation at
initiatives to develop and share solutions to industry-wide nature collectively discretion of
challenges, specifically relating to footprint reduction, minimising member.
legacy impacts and transforming consumption and production
patterns towards a circular economy.

4.2. A
 dvancing Data Sharing: Collaborate with local, national and/or Individually or n/a Validation at
global data sharing platforms and initiatives to progressively collectively discretion of
increase and responsibly share relevant biodiversity and ecosystem member.
monitoring data to support enhanced decision-making, capacity
building and action for nature.

Validation Guidance Annex B 46

 Applicability for PE
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4.3. S
 ustainable Finance: Engage and partner with investors, financial Individually or n/a Validation at
institutions and other key stakeholders to support the development collectively discretion of
of sustainable financing mechanisms to increase and mobilise member.
private sector funding for action on nature.

5. G
 overnance and transparency
Enabling business transformation and embedding nature positive approaches through commitments to:

5.1. Integrate nature considerations into business decision-making tools Individual n/a
and processes, including those relating to governance, strategy, risk members
and impact management by 2026.

5.2. D
 isclose material nature-related impacts, dependencies, risks and Individual n/a
opportunities for operations in priority locations by 2026 and the members
most material value chain categories or issues by 2030, following
globally recognised reporting practices. Develop and disclose
performance targets and/or objectives and subsequent progress
against these for identified material aspects.

5.3. Collectively and in consultation with stakeholders, develop Collectively n/a n/a n/a n/a
consistent and robust metrics for reporting progress towards
nature positive outcomes from 2026.

3. Accelerate Action: In addition to our existing individual and collective Collectively 3.9 Validation at
Diversity, actions, we will develop a roadmap for diversity, equity and inclusion discretion of
Equity and that accelerates efforts to eliminate harmful behaviours from our member.
Inclusion workplaces and communities. The roadmap will outline the proximity
(Jun 2023) and direction of our ambition, setting out key milestones to achieving
our goals (see below). It will support the development and execution of
actions that will contribute to positive social change. The roadmap will
include the development of tools and resources and expand the scope
of our already strong physical health and safety practices to address
psychological wellbeing.

Set Goals: We will set company goals, relevant to our operating Collectivley or 3.9 Validation at
contexts, to eliminate all forms of harassment and discriminatory individually discretion of
behaviours, and improve diversity, equity and inclusion. Further, we will member.
agree on a collective goal or goals aimed at creating workplaces and
communities that better reflect the aspirations of society for diversity
and inclusion. Recognising the many contextual and operating
differences of our membership, these goals will focus on the systematic
barriers to diversity, equity and inclusion that exist across the mining
and metals industry. They will help drive and demonstrate progress.
Further, we commit to revising the goals as they are met in order to not
only to sustain, but to drive ongoing progress

ICMM Annex B 47
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Increase Transparency: We will disclose our aggregated performance Collectivley 3.9 Validation at
against our goals, such that it contributes to an appropriate depiction of discretion of
mining’s impact, in accordance with the ICMM Social and Economic member.
Reporting Framework, disaggregating data by gender and ethnicity
where possible. In doing so, we will identify and report on areas in which
we are not sufficiently progressing and ensure there is continued focus
on them until we fulfil our commitment. This includes embedding
objectives for diversity, equity, and inclusion into employee
engagement, stakeholder consultation, reporting frameworks, and
monitoring and evaluating our progress.

Collaborate for Greater Effect: We will seek the participation of people Collectively 3.9 Validation at
from underrepresented groups in the design of the actions set out discretion of
above, as well as engaging majority groups as advocates. By working member.
together as members and with industry associations, governments,
communities, investors and others we will help find solutions to these
pervasive challenges and contribute to broader industry and social
cultural change.(Collectively)

4. 1. Include a clear endorsement of efforts at the international level to Individual 10.2

Transparency enhance the transparency of mineral revenues, including EITI, on members
of Mineral their website and/or in their sustainable development reports. To
Revenues submit a completed international-level self-assessment form to the
(Dec 2021) EITI Secretariat for posting on the EITI website.

2. Engage constructively in countries that are committed to Individual 10.2

implementing EITI, consistent with the multi-stakeholder process members
adopted in each country.

3. Compile information on all material payments by country and by Individual 10.2

project at the appropriate levels of government. In the case of EITI members
implementing countries, this should be provided to the body
assigned responsibility for reconciling details of payments by
companies and revenue data provided by government according to
the agreed national template. Material payments by companies are
expected to have been independently audited, applying
international standard accounting practices.

4. S
 upport the public disclosure (ie publication) of material payments Individual 10.2
by country and by project. For EITI, this should be in line with the members
implementation approach adopted in-country.

5. E
 ngage constructively in appropriate forums to improve the Individually or 10.2 Validation at
transparency of mineral revenues – including their management, collectively discretion of
distribution or spending either individually or collectively through member.
ICMM.

Validation Guidance Annex B 48

 Applicability for PE
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6.  isclose all mineral development contracts granted or entered into
D Individual 10.2
from 1 January 2021 that they have signed with host governments, members
where such disclosure is not prohibited by law or regulation.

5. 1. Setting Scope 1 and 2 targets: We will build clear pathways to Individual 6.5
Climate achieving net zero1 Scope 1 and 2 GHG emissions by 2050 or members
Change sooner, through meaningful short and/or medium-term targets.
(Oct 2021)
2. Accelerating action on Scope 3 GHG emissions: We recognise that Individual 6.5
Scope 3 is critical to minimising our overall impact and we will set members
Scope 3 targets, if not by the end of 2023, as soon as possible.
Although all Scope 3 action depends on the combined efforts of
producers, suppliers and customers, some commodities face
greater technological and collaborative barriers than others. We will
play a leading role in overcoming these barriers and advancing
partnerships that enable credible target setting and emission
reductions across value chains.

3. Covering all material sources: Our targets will cover all material Individual 6.5
sources of emissions, aligning to the GHG Protocol definition of members
organisational boundaries and materiality.

4. F
 ocussing on absolute reductions: For some operations, intensity Individual 6.5
rather than absolute targets may be more appropriate in the short members
and medium term. Where intensity targets are used, we will disclose
the corresponding absolute increase or decrease in GHG emissions.

5. A
 pplying robust methodologies: We will use target-setting Individual 6.5
methodologies that are aligned with the ambitions of the Paris members
Agreement and disclose in detail the assumptions we use.

6. Integrating climate change in decision-making: Implement Individual 6.5

governance, engagement and disclosure processes to ensure members
climate change risks and opportunities are considered in business
decision-making.

7. A
 daptation and mitigation: Advance operational level adaptation Individual 6.5
and mitigation solutions that can support the net zero goal, taking members
in consideration local opportunities and challenges.

8. S
 upporting community resilience: Engage with host communities Individual 6.5
on our shared climate change risks and opportunities and help host members
communities understand how they can adapt to the physical impact
of climate change.

ICMM Annex B 49
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9. D
 isclosing openly and transparently: We will report our progress on Individual 6.5
Scopes 1, 2 and 3 annually, obtain external verification over our members
performance, and report in alignment with the recommendations of
the Task Force on Climate-related Financial Disclosures.

10. Engage with governments, peers, and others to support the Individually or 6.5 Validation at
development of effective climate change policies. collectively discretion of
member.

11. S
 upport efforts to mitigate greenhouse gas emissions, in Individually or 6.5 Validation at
collaboration with our peers by promoting innovation, developing collectively discretion of
and deploying low emissions technology, and implementing member.
projects that improve energy efficiency and incorporate renewable
energy supply in our energy mix.

12. Support carbon pricing and other market mechanisms, that drive Individually or 6.5 Validation at
the reduction of greenhouse gas emissions, deliver the least cost collectively discretion of
pathway to emissions reductions and support predictable long- member.
term pricing that incentivise innovation.

6. 1. Apply strong and transparent corporate water governance: Individual 6.2

Water members
– Publicly disclose the company’s approach to water stewardship.
Stewardship
(Jan 2017) –A
 llocate clear responsibilities and accountabilities for water –
from board and corporate to site levels.

– Integrate water considerations in business planning – including

company strategy, life of asset and investment planning.

–P
 ublicly report company water performance, material
risks, opportunities and management response using consistent
industry metrics and recognised approaches

2. Manage water at operations effectively: Individual 6.2

members
– Maintain a water balance and understand how it relates to the
cumulative impact of other users.

–S
 et context-relevant water targets or objectives for sites with
material water-related risks.

–P
 roactively manage water quantity and quality to reduce potential
socio-environmental impacts and realise opportunities.

–E
 nsure all employees have access to clean drinking water,
gender-appropriate sanitation facilities and hygiene at their
workplace.

Validation Guidance Annex B 50

 Applicability for PE
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3. Collaborate to achieve responsible and sustainable water use: Individual 6.2
members
– Identify, evaluate, and respond to catchment-level water-related
risks and opportunities.

– Identify and engage proactively and inclusively with stakeholders

that may influence or be affected by a site’s water use and
discharge.

– Actively engage on external water governance issues, with

governments, local authorities and other stakeholders, to support
predictable, consistent and effective regulation that underpins
integrated water resource management.

–S
 upport water stewardship initiatives that promote better water
use, effective catchment management and contribute to
improved water security and sanitation.

– Actively engage on external water governance issues, with Individually or 6.2 Validation at
governments, local authorities and other stakeholders, to support collectively discretion of
predictable, consistent and effective regulation that underpins member.
integrated water resource management.

– Support water stewardship initiatives that promote better water

use, effective catchment management and contribute to
improved water security and sanitation.

ICMM 51
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7. 1. Accountability, responsibility and competency: Accountabilities, Individual 6.3
Tailings responsibilities and associated competencies are defined to members
Governance support appropriate identification and management of TSF risks.
(Dec 2016)
–A
 ccountability for the overall governance of tailings facilities
resides with the owners and operators.

–O
 rganisational structures and roles are established to support
management of TSF risks and governance accountability.

–C
 ommunication processes are maintained to ensure that
personnel understand their responsibilities. Training is conducted
to maintain currency of knowledge and skills.

– Role
 competency and experience requirements are defined for
critical roles within the established organisational structures.

2. Planning and resourcing: The financial and human resources Individual 6.3
needed to support continued TSF management and governance members
are maintained throughout a facility’s life cycle.

–T
 SF operating and capital costs, and human resource needs, are
included in relevant business planning processes.

–R
 esources necessary to implement and maintain activities within
this governance framework are provided.

3. Risk management: Risk management associated with TSFs includes Individual 6.3
risk identification, an appropriate control regime and the verification members
of control performance.

–R
 isk controls and their associated verification activities are
identified based on failure modes and their associated
consequences, and evaluated on a TSF-specific basis considering
all phases of the TSF life cycle.

–S
 uitably qualified and experienced experts are involved in TSF risk
identification and analysis, as well as in the development and
review of effectiveness of the associated controls.

– Performance
 criteria are established for risk controls and their
associated monitoring, internal reporting and verification activities.

4. C
 hange management: Risks associated with potential changes are  6.3
assessed, controlled and communicated to avoid inadvertently
compromising TSF integrity.

–P
 rocesses are applied that involve the identification, assessment,
control and communication of risks to TSF integrity arising from
both internally driven and externally driven change, to avoid
introducing uncertain, unacceptable, and/ or unmanaged risks.

– Documents
 and records that support TSF planning, design,
construction, operation, surveillance, management and
governance are maintained and kept suitably current and
accessible

Validation Guidance 52
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5. Emergency
 preparedness & response: Processes are in place to Individual 6.3
recognise and respond to impending failure of TSFs and mitigate members
the potential impacts arising from a potentially catastrophic failure.

– Action
 thresholds and their corresponding response to early
warning signs of potential catastrophic failure are established.

– Emergency
 preparedness and response plans are established
commensurate with potential failure consequences. Such plans
specify roles, responsibilities and communication procedures.

–E
 mergency preparedness and response plans are periodically
tested.

6. Review & assurance: Internal and external review and assurance Individual 6.3
processes are in place so that controls for TSF risks can be members
comprehensively assessed and continually improved.

– Internal
 performance monitoring and inspections and internal and
external reviews and assurance are conducted commensurate
with consequences of TSF failure to evaluate and to continually
improve the effectiveness of risk controls.

– Outcomes
 and actions arising from TSF review and assurance
processes are recorded, reviewed, closed-out and
communicated.

– Performance
 of risk management programs for TSFs is reported
to executive management on a regular basis.

8. 1.  ither individually or collectively through ICMM publicly express their

E Individually or 9.1 Validation at
Mining: willingness to work in partnership with development agencies, host collectively discretion of
Partnerships governments, civil society organisations, and local communities to member.
for enhance mining and metals’ contribution to social and economic
Development development.
(Jan 2010)
2. For major investments in regions where socio-economic outcomes Individual 9.1
are highly uncertain or where there are significant opportunities to members
enhance such outcomes: (i) develop an understanding of the social
and economic contribution of the project, including an analysis of
the barriers that might weaken this contribution; and (ii) actively
support or help develop partnerships or collaborations with other
stakeholder groups with the aim of ensuring the project’s potential
socio-economic contribution is realised.

ICMM 53
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3. Review the relative success of their development partnerships and Individual 9.1
collaborations at suitable intervals and adapt these over time to members
ensure they continue to contribute to the overall goal of enhancing
the social and economic contribution of mining.

4. P
 rovide an overview of their work on such partnerships, as Individual 10.3
appropriate, in their annual external reporting and communications. members

9. 1. Not open any mines designed to produce mercury as the primary Individual 6.4
Mercury Risk product. members
Management
2. Apply materials stewardship to promote the responsible Individual 6.4
(Feb 2009)
management of the mercury produced from ICMM members’ members
operations including that which naturally occurs in our products.

3.  Identify and quantify point source mercury air emissions from our Individual 6.4
operations and minimise them through the application of cost members
effective best available technology, using a risk based approach.

4.  eport significant point source mercury emissions from our

R Individual 6.4
operations consistent with our commitment to report in accordance members
with the GRI framework. Members who report against the European
Sustainability Reporting Standards (ESRS) can report ‘with
reference to’ GRI.

5. T
 o participate in government-led partnerships to transfer low- to Individual 9.4
no-mercury technologies into the ASM sector in locations where members
ICMM member companies have operations in close proximity to
ASM activity such that livelihoods are enhanced through increased
productivity and reduced impacts to human health.

6.  hrough ICMM, to encourage the development of sound science on

T Collectively n/a n/a n/a n/a
the fate and transport of mercury as well as natural sources of
mercury in the environment.

7.  T
 o work on an integrated multi-stakeholder strategy through ICMM Collectively n/a n/a n/a n/a
to reduce and eventually cease supplying mercury into the global
market once policy and economically viable long-term
technological solutions for the retirement of mercury are developed.

Validation Guidance 54
ICMM 55
Annex C: 04
Glossary of Terms
and List of Abbreviations

Validation Guidance Annex C 56

Glossary of Terms
First party Asset
An activity related to a given party that is carried Operations involved in the production or refining of
out by that party itself. minerals and metals for sale or further processing.
An asset may comprise several sites in different
Third party locations (eg port, pipeline desal facility), under the
An activity carried out by someone independent or same management control which ‘support the
at arm’s-length from the party that is the subject of production and sale’.
the activity.
Assets included in scope of assurance framework
AA1000APS Operations involved in the production or refining of
Accountability Principles Standard (2018): Standard minerals and metals over which the member exercises
with a set of principles and criteria for the control with regard to financial and operating policies
implementation of sustainability within organisations and practices.
published by AccountAbility.
This excludes activities in a company’s portfolio that are
not producing saleable products, such as exploration
AA1000AS
sites, non-managed operations and projects.
Assurance Standard (2008 or 2008 with 2018
Addendum) covering compliance of organisations with This excludes non-managed joint ventures. However,
AA1000APS and the reliability of reported performance JV companies that are majority owned by ICMM
in public reporting. members (either singly or jointly) are encouraged to
implement ICMM’s membership requirements.
Note that is not possible to limit an AA1000AS
engagement to assurance on the ICMM subject
Assurance
matters. Adoption and embedding of the AccountAbility
The act of obtaining and considering evidence in
Principles (AA1000APS) in the company is mandatory
order to enhance the degree of confidence regarding
for AA1000AS assurance. Use of AA1000AS would be
a particular topic.
practicable if the assurance provider for the
sustainability report was also undertaking the PE
Assurance engagement
validation activities.
‘An engagement in which a practitioner aims to obtain
sufficient appropriate evidence in order to express a
AccountAbility
conclusion designed to enhance the degree of
The organisation that publishes AA1000APS
confidence of the intended users other than the
and AA1000AS.
responsible party about the subject matter information
(that is, the outcome of the measurement or evaluation
Applicability
of an underlying subject matter against criteria)’
The applicability of individual PEs at an asset is
(ISAE3000).
determined by the pertinence of the PE requirement to
the asset and the local context. If a member determines
Assurance provider
that a PE is not applicable at a given asset, the member
An independent service provider (3rd party) that is
will document the determination as ‘Not Applicable’ and
contracted by a company to conduct the sustainability
will provide comments explaining this determination in
report assurance engagement (see also ‘Validation
the self-assessment.
Service Provider VSP’).
For example, only a minority of assets will be located in
indigenous lands or territories. Similarly, many assets Assurance Standard
will not have artisanal and small-scale mining activity Internationally accepted standard used by independent
in the vicinity. In such cases, it can be cumbersome to assurance providers to assure the information and
provide evidence of non-applicability. An informed disclosures of another party.
conversation between the company and validation
service provider should be sufficient to agree on the
non-applicability of a PE.

ICMM Annex C 57
Assurance Statement/Report Equivalence
The Assurance Statement/Report is the written report Equivalent programmes are defined as having
of the assurance provider which must include a clear standards and validation requirements that are similar in
expression of the assurance provider’s conclusions. scope and intent as the ICMM PE validation programme.
It is normally published together with the assured
ESRS
information. The requirements for the content of the
European Sustainability Reporting Standards (ESRS)
Assurance Statement/Report are set out in the
isued by the European Commission and for use by all
Assurance Standards.
companies subject to the Corporate Sustainability
Reporting Directive (CSRD).
AT Section 101
‘Attest engagements’ standard used in the United
GRI (Global Reporting Initiative)
States by certified public accountant for an examination
Not for profit organisation that publishes Standards for
(reasonable assurance), a review (limited assurance) on
Sustainability Reporting.
a subject matter or assertion about the subject matter.

Attestation GRI Standards

In an attestation (also known as assertion-based) (Global) Standards for Sustainability Reporting issued
engagement the responsible party carries out the by the GRI.
measurement or evaluation of the subject matter and
reports the information, with an inherent assertion that ISAE3000
the information is fairly stated. The assurance provider’s International Standard for Assurance Engagements
work results in an assurance conclusion on this (ISAE) 3000 Revised, Assurance Engagements Other
assertion. than Audits or Reviews of Historical Financial
Information. Published by the International Audit and
Best Available Technology / Techniques Assurance Standards Board (IAASB) of the International
‘The most effective and advanced stage in the Federation of Accountants (IFAC).
development of activities and their methods of
operation, indicating the practical suitability of particular ISAE3410
techniques for providing the basis for emission limit International Standard for assurance on Greenhouse
values and other permit conditions designed to prevent Gas Statements. (Volume 2: Pages 276-369)
and, where this is not practicable, to reduce emissions
and the impact on the environment as a whole’. ISO 14063:3
Techniques are both (i) the technologies used by Part 3 of ISO standard 14064: Specification with
industrial installations; and (ii) the way in which guidance for the validation and verification of
installations are designed, built, maintained, operated greenhouse gas assertions.
and decommissioned. (EU Industrial Emissions Directive
2010). Similar concepts include Best Techno- Management system
Economically Available Techniques, Best Available A management system is the way in which an
Control Technology and Best Practical Options. organisation manages the inter-related parts of its
business in order to achieve its objectives. These
Criteria objectives can relate to a number of different topics.
The benchmarks that are used to measure or evaluate The level of complexity of the system will depend on
the information (subject matter) or management each organisation’s specific context. For some
systems in an assurance or audit process. organisations, especially smaller ones, it may simply
mean having strong leadership from the business
Does not Meet owner, providing a clear definition of what is expected
Systems and/or practices required to support from each individual employee and how they contribute
implementation of the substantive intent of the PE are to the organisation’s overall objectives, without the need
not in place, or are not being implemented, or cannot be for extensive documentation. More complex businesses
evidenced. operating, for example, in highly regulated sectors, may

Validation Guidance Annex C 58

need extensive documentation and controls in order to Qualified validation/ assurance statement
fulfil their legal obligations and meet their organisational Outcome/conclusion of third-party validation or
objectives. assurance where available evidence is insufficient to
confirm that one or more PEs within the scope of the
Materiality determination validation exercise are satisfied.
Determination of material sustainability risks and
opportunities for the company using multiple inputs Stakeholders
from internal and external stakeholders. GRI (GRI 101) Stakeholders are defined as entities or
individuals that can reasonably be expected to be
Material risk significantly affected by the reporting organisation’s
Material risk in sustainability reports is the risk of a activities, products, or services; or whose actions can
material misstatement, whether caused by omission or reasonably be expected to affect the ability of the
error, which would influence the user of the information. organisation to implement its strategies or achieve its
It may be qualitative, for example in relation to the objectives. This includes, but is not limited to, entities or
Sustainability Report as a whole, or quantitative, in individuals whose rights under law or international
relation to individual disclosures. conventions provide them with legitimate claims vis-à-
vis the organisation. Stakeholders can include
Meets employees and other workers, shareholders, suppliers,
Systems and/or practices related to the PE have vulnerable groups, local communities, and NGOs or
been implemented and there is sufficient evidence other civil society organisations, among others.
to demonstrate that the intent of the PE is being met,
however opportunities for improvement may still remain. Subject matter
Subject matter is the topic or subject which is evaluated
Non-applicability or measured by the company against suitable criteria to
See applicability. produce the ‘subject matter information’. For example,
GHG emissions (subject matter) are measured using the
Partially Meets GHG Protocol (suitable criteria) to produce ‘Total GHG
Systems and/or practices related to meeting the intent emissions in CO2e’ (Subject matter information).
of the PE have been only partially implemented. Gaps or
weaknesses persist that may contribute to an inability Subject matter information
to meet the intended outcome of the PE, or insufficient Subject matter information means the outcome of the
verifiable evidence can be provided to demonstrate that evaluation or measurement of a subject matter. It is the
the activity is aligned to the intent of the PE. subject matter information about which the assurance
provider gathers sufficient appropriate evidence to
Performance Expectations provide a reasonable basis for expressing a conclusion
ICMM developed a comprehensive set of requirements in an assurance statement.
that outline the expectations for how members manage
a broad range of sustainability issues, especially at the Suitable Criteria
operational levels. The objective is to set a benchmark Reporting criteria that enable reasonably consistent
for responsible practices that members and other evaluation or measurement of the subject matter.
committed mining and metals companies can publicly See Annex C for more details.
commit to.

ICMM Annex C 59
Sustainability Report
All forms (printed, pdf and web-based) of organisational
reporting on sustainability (non-financial) risks,
opportunities, strategy, management and performance
including Sustainability Reports, ESG Reports,
Integrated Reports (IR), Corporate Responsibility (CR)
Reports, Corporate Social Responsibility (CSR) Reports.

Unqualified validation’ assurance statement

Outcome/conclusion of third-party validation or
assurance where available evidence suggests that PEs
within the scope of the validation exercise are satisfied.

Validation (ie by a third party)

The act of confirming the reasonableness and
authenticity of assertions made in self-assessments.

Validation Service Provider

An independent service provider who is contracted
by a company to conduct those parts of the validation
process designated as ‘3rd party’ (see also
‘Assurance provider’).

Validation Guidance Annex C 60

Abbreviations
ASM Artisanal and Small-Scale Mining NGO Non-governmental organisation

BAT Best available technology OSHA Occupational Safety and Health

Administration
CDP Carbon Disclosure Project
PEs Performance Expectations
CR Corporate Responsibility
QA/QC Quality Assurance/Quality Control
CSR Corporate Social Responsibility
RFPs Request for proposals
EITI Extractive Industries Transparency Initiative
SASB Sustainability Accounting Standards Board
ESG Environmental Social Governance
SD Sustainable Development
ESIAs Environmental and social impact assessments
SM Subject Matter
GHG Greenhouse Gas
TSF Tailings Storage Facility
ICMM International Council on Mining and Metals
UNGP United Nations Guiding Principles on Business
IR Integrated Reports
and Human Rights
IUCN International Union for Conservation of Nature
VSPs Validation Service Providers
JV Joint Venture

KPI Key performance indicator

ICMM Annex C 61
Annex D: 05
Key Resources

Validation Guidance Annex D 62

Key Resources
This table summarises key resources produced by ICMM that are relevant to the
individual PEs, where such resources exist. By exception, a limited number of other
resources are also included (eg IFC Performance Standards, OECD Due Diligence
Guidance, etc.)

PE 3.1 ICMM: Human Rights in the Mining and Metals Industry: Integrating Human Rights Due Diligence Into Corporate Risk
Management Processes (2012)

ICMM: Handling and Resolving Local-Level Concerns and Grievances: Human Rights in the Mining and Metals Sector (2019)

UN: Guiding Principles on Business and Human Rights (2011)

PE 3.2 ICMM: Land Acquisition and Resettlement: Lessons Learned (2015)

IFC: Performance Standard 5 and Guidance Note: Land Acquisition and Involuntary Resettlement (2012)

PE 3.3 ICMM/IFC/IPIECA/ICRC: Voluntary Principles on Security and Human Rights: Implementation and Guidance Tools (2012)

VPSHR: The Voluntary Principles (2000)

PE 3.6 ICMM: Indigenous Peoples and Mining: Good Practice Guide (2015)

IFC: Performance Standard 7 and guidance note: Indigenous Peoples (2012)

ICMM: Human Rights Due Diligence Guidance (2023)

PE 3.7 ICMM: Indigenous Peoples and Mining: Good Practice Guide (2015)

IFC: Performance Standard 7 and guidance note: Indigenous Peoples (2012)

UN Global Compact: The Business Reference Guide to the UN Declaration on the Rights of Indigenous Peoples (2013)

PE 3.8 I FC: Unlocking Opportunities for Women and Business : A Toolkit of Actions and Strategies for Oil, Gas, and Mining
Companies (2021)

PE 4.1 I FC: Performance Standard 1 and guidance note: Assessment and management of environmental and social risks and
impacts (2012)

PE 4.2 OECD: Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016)

PE 4.4 ICMM/UNEP: Good Practice in Emergency Preparedness and Response (2005)

UNEP: APELL for mining: Guidance for the mining industry in raising awareness and preparedness for emergencies at local
level (2001)

PE 5.1 ICMM: Good Practice Guidance on Occupational Health Risk Assessment (2016)

ICMM: Health and Safety Critical Control Management: Good Practice Guide (2015)

ICMM: Critical Control Management: Implementation Guide (2015)

PE 5.2 ICMM: Good Practice Guidance on Occupational Health Risk Assessment (2016)

ICMM: Health and Safety Critical Control Management: Good Practice Guide (2015)

ICMM: Critical Control Management: Implementation Guide (2015)

PE 6.1 ICMM: Integrated Mine Closure: Good Practice Guide (2019)

ICMM: Financial Concepts for Mine Closure (2019)

PE 6.2 ICMM: A Practical Guide to Catchment-Based Water Management for the Mining and Metals Industry (2015)

ICMM: Water Reporting: Good Practice Guide (2021)

ICMM Annex D 63
 PE 6.3 ICMM: Guidance currently under production (to be updated)

MAC: Developing an Operation, Maintenance, and Surveillance Manual for Tailings and Water Management Facilities (2021)

MAC: A Guide to the Management of Tailings Facilities (2021)

PE 6.5 ICMM: Adapting to a Changing Climate: Building Resilience in the Mining and Metals Industry (2019)

TCFD: Final Report: Recommendations of the Task Force on Climate-related Financial Disclosures (2017)

GRI: GRI 305: Emissions (2016)

PE 7.1 I FC: Performance Standard 6 and guidance note: Biodiversity conservation and sustainable management of living natural
resources (2012 and 2019)

PE 7.2 ICMM/IPIECA/Equator Principles Association (CSBI): A Cross-sector Guide for Implementing the Mitigation Hierarchy (2015)

ICMM: Good Practice Guidance for Mining and Biodiversity (2006)

PE 8.1 ICMM: Mining and Metals and the Circular Economy (2016)

PE 8.2 UNECE: Globally Harmonized System of Classification and Labelling of Chemicals (2021)

ICMM/Eurometaux/Arche: Metals Environmental Risk Assessment Guidance (2016)

ICMM: Hazard Assessment of Ores and Concentrates for Marine Transport (2021)

ICMM/Eurometaux/Eurofer/EBRC: Health Risk Assessment Guidance for Metals (2007)

PE 9.1 ICMM: Understanding Company-Community Relations Toolkit (2015)

ICMM: Community Development Toolkit (2012)

PE 9.2 ICMM: Mining Partnerships for Development: Toolkit (2011)

PE 9.3 ICMM: Handling and Resolving Local-Level Concerns and Grievances: Human Rights in the Mining and Metals Sector (2019)

ICMM: Understanding Company-Community Relations Toolkit (2015)

ICMM: Community Development Toolkit (2012)

IFC: Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets (2007)

PE 9.4 IIED: Governments, large- and small-scale mining: Beginning a dialogue (2014)

IGF: Global Trends in Artisanal and Small-Scale Mining (ASM): A Review of Key Numbers and Issues (2017)

PE 10.1 ICMM/IFC/Brunswick: Changing the Game: Communications & Sustainability in the Mining Industry (2013)

PE 10.2 EITI: EITI Business Guide (2013)

PE 10.3 GRI: GRI Standards (various)

PE 10.4 ICMM: Assurance and Validation Procedure (2019)

Validation Guidance Annex D 64

ICMM stands for mining with principles.

We bring together a third of the global metals and

mining industry, along with key partners to drive
leadership, action and innovation for sustainable
development, ultimately delivering a positive
contribution to society.

Through collaboration, ICMM member companies

set the standard for responsibly produced minerals
and metals in a safe, just and sustainable world.

This publication contains general guidance only and should not be relied upon as
a substitute for appropriate technical expertise. Although reasonable precautions
have been taken to verify the information contained in this publication as of the date
of publication, it is being distributed without warranty of any kind, either express
or implied. This document has been prepared with the input of various International
Council on Mining and Metals (‘ICMM’) members and other parties. However, the
responsibility for its adoption and application rests solely with each individual member
company. At no stage does ICMM or any individual company accept responsibility
for the failures or liabilities of any other member company, and expressly disclaims the
same. Each ICMM member company is responsible for determining and implementing
management practices at its facility, and ICMM expressly disclaims any responsibility
related to determination or implementation of any management practice.

Each ICMM member company is responsible for determining and implementing

management practices at its facility, and ICMM expressly disclaims any responsibility
related to determination or implementation of any management practice. Moreover,
although ICMM and its members are committed to an aspirational goal of zero fatalities
at any mine site or facility, mining is an inherently hazardous industry, and this goal
unfortunately has yet to be achieved.

In no event shall ICMM (including its officers, directors, and affiliates, as well
as its contributors, reviewers, or editors to this publication) be liable for damages
or losses of any kind, however arising, from the use of or reliance on this document,
or implementation of any plan, policy, guidance, or decision, or the like, based on this
general guidance. ICMM, its officers, and its directors expressly disclaim any liability
of any nature whatsoever, whether under equity, common law, tort, contract, estoppel,
negligence, strict liability, or any other theory, for any direct, incidental, special, punitive,
consequential, or indirect damages arising from or related to the use of or reliance
on this document.

The responsibility for the interpretation and use of this publication lies with the user
(who should not assume that it is error-free or that it will be suitable for the user’s purpose)
and ICMM. ICMM’s officers and directors assume no responsibility whatsoever for errors
or omissions in this publication or in other source materials that are referenced by this
publication, and expressly disclaim the same.

Except where explicitly stated otherwise, the views expressed do not necessarily represent
the decisions or the stated policy of ICMM, its officers, or its directors, and this document
does not constitute a position statement or other mandatory commitment that members
of ICMM are obliged to adopt.

ICMM, its officers, and its directors are not responsible for, and make no representation(s)
about, the content or reliability of linked websites, and linking should not be taken
as endorsement of any kind. We have no control over the availability of linked pages
and accept no responsibility for them.

The designations employed and the presentation of the material in this publication
do not imply the expression of any opinion whatsoever on the part of ICMM, its officers,
or its directors concerning the legal status of any country, territory, city or area or
of its authorities, or concerning delimitation of any frontiers or boundaries. In addition,
the mention of specific entities, individuals, source materials, trade names, or commercial
processes in this publication does not constitute endorsement by ICMM, its officers,
or its directors.

This disclaimer should be construed in accordance with the laws of England.

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icmm.com Updated February 2025