IRMA Standard for Responsible Mining (Draft 2.0)
Chapter 2.8 Community and Stakeholder Engagement

Background

Large-scale mining developments have the potential to last for decades over their life cycle. Often mines are built in locations near existing communities; in other cases new communities emerge because of mining activities. Mining projects have the potential to significantly impact the lives of people in those communities. Some changes may be beneficial to some community members, for example, through the provision of jobs, or through mining company investment in community development projects. But mining projects also have the potential to create negative impacts, and even be a source of social conflict, within communities.

Increasingly, mining companies, host governments, and financial institutions are recognizing that building strong, lasting relationships with those affected by mining activities can improve the identification and management of risks, as well as the long-term viability of operations.[1]  Meaningful engagement that is proactive, inclusive, accountable, and transparent is more likely to result in optimal outcomes for both communities and mining companies.[2]

Objectives/Intent of this Chapter

To enable communities and stakeholders to participate in mining-related decisions that affect their health, wellbeing, safety, livelihoods, futures and the environment.

Scope of Application

Chapter Relevance:  This chapter is relevant for all mines applying for IRMA certification.

New vs. Existing Mines:  New mines shall meet all requirements in this chapter.  Existing mines seeking certification will be required to meet all requirements in Chapter 2.8, with the exception of the requirement in 2.8.2.1 that engagement begin prior to or early in the development phase of the mining project. For some existing mines, this may not have occurred. Those mines will have to demonstrate that they currently engage with stakeholders on an ongoing basis.

NOTES TO READERS ON MAJOR CHANGES TO THIS CHAPTER:

  • Minor changes have been made to wording to improve clarity in other requirements.
  • Have added a new requirement (2.8.2.3) for a permanent stakeholder advisory committee (or its equivalent), which could serve different roles depending on community needs.
  • Criterion 2.8.4. Communications and Access to Information has been revised, and additional information provided to define terms.
  • The means of verification (MOV) have been removed from this version of the draft IRMA Standard. If you would prefer to review and comment on a version of the draft Standard that has the means of verification, you can download a pdf version of the Standard with MOV.
     

Community and Stakeholder Engagement Requirements

2.8.1.  Planning and Designing Stakeholder Engagement Processes

2.8.1.1.  The operating company shall undertake identification and analysis of the range of groups and individuals, including community members, rights holders and others (hereafter referred to collectively as “stakeholders”) who may be affected by or interested in the company’s mining-related activities

2.8.1.2.  A stakeholder engagement plan scaled to the project risks and impacts and stage of development shall be developed, implemented and updated as necessary.

2.8.1.3.  The operating company shall consult with stakeholders to design engagement processes that are accessible, inclusive and culturally appropriate,[3] and shall demonstrate that continuous efforts are taken to understand and remove barriers to inclusive, meaningful participation by affected stakeholders (especially women, marginalized and vulnerable groups).

2.8.1.4.  The operating company shall demonstrate that efforts have been made to understand community dynamics in order to prevent or mitigate community conflicts that might otherwise occur as a result of company engagement processes.

2.8.2.  Engagement Processes

2.8.2.1.  Stakeholder engagement shall begin prior to or during mine planning, and be ongoing, throughout the life of the mine.

2.8.2.2.  The operating company shall foster two-way dialogue and engagement with stakeholders by:

a.   Providing relevant information to stakeholders in a timely manner;

b.   Including participation by site management and subject-matter experts when addressing concerns of significance to stakeholders;

c.   Engaging in a manner that is respectful, and free from manipulation, interference, coercion or intimidation;

d.   Soliciting feedback from stakeholders on issues relevant to them; and

e.   Providing stakeholders with feedback on how the company has taken their input into account.

2.8.2.3. The operating company shall collaborate with stakeholders, including representatives from affected communities, to design and form a permanent stakeholder advisory committee (or its equivalent), to provide oversight of the mining project’s environmental and social performance, and/or input to the company on issues of concern to stakeholders.[4]

2.8.2.4.  Engagement processes shall be accessible and culturally appropriate,[5] and the operating company shall demonstrate that efforts have been made to include participation by women, men, and marginalized and vulnerable groups.

2.8.2.5.  When stakeholder engagement processes depend substantially on community representatives, the operating company shall demonstrate that efforts have been made to confirm whether or not such persons represent the views and interests of affected community members and can be relied upon to faithfully communicate relevant information to them. If this is not the case, the operating company shall undertake additional engagement processes to enable more meaningful participation by and information sharing with the broader community.

2.8.2.6.  The operating company shall document engagement processes, including, at minimum, names of participants, and input received from and company feedback provided to stakeholders. 

2.8.2.7.  The operating company shall report back to affected communities and stakeholders on issues raised during engagement processes.

2.8.3.  Strengthening Capacity

2.8.3.1.  The operating company shall offer to collaborate with stakeholders from affected communities to assess their capacity to effectively engage in consultations, studies, assessments, and the development of mitigation, monitoring and community development strategies.[6] Where capacity gaps are identified, the operating company shall offer appropriate assistance to facilitate effective stakeholder engagement.[7]

2.8.4.  Communications and Access to Information

2.8.4.1.  Unless otherwise indicated in IRMA requirements, the operating company shall provide free, timely access to its policies, assessments, mitigation and monitoring plans and reports, and other information reasonably requested by stakeholders.[8] If the company refuses a stakeholder request, it shall provide the stakeholder with a written justification for why it is withholding the information.

2.8.4.2.  Communications with and information provided to stakeholders shall be in formats and languages that are culturally appropriate, accessible and understandable to affected communities and stakeholders.[9]

Cross Reference to Other Chapters

 Chapter

 Issues

2.1—Fair Labor and Terms of Work Workers and workers’ representatives are stakeholders of the mine. Engagement with workers and/or workers’ representatives occurs during the negotiation of collective bargaining agreements, retrenchment plans and in the calculation of living wage.
2.2—Occupational Health and Safety Engagement with workers/workers’ representatives occurs during health and safety risk assessment; design of workplace monitoring and worker health surveillance; development of strategies to prevent or mitigate risks to workers; design of programs to support worker health and safety; and in inspections, monitoring and investigation of safety and health matters.
2.3—Emergency Preparedness/Response Stakeholders are involved in the development of the Emergency Response Plan and participate in emergency response planning exercises.
2.4—Human Rights Due Diligence and Compliance Stakeholders are consulted in the human rights impact assessment process, including providing input and reviewing drafts; and affected rights-holders collaborate with companies in the development of mitigation plans when their human rights have been infringed upon; and provide input on the company’s monitoring of its human rights due diligence.
2.5—Mining and Conflict Affected Areas Stakeholders are consulted during the conflict-affected areas screening process and conflict risk assessment; and affected stakeholders collaborate in the development of mitigation strategies to address risks that are relevant to them.
2.6—Security Arrangements Stakeholders are consulted in the security risk assessment; and if there are risks specific to conflicts between communities/workers and mine security providers, community and worker stakeholders collaborate with the company to develop strategies to prevent or mitigate those risks. Stakeholders may also receive training on security and human rights issues.
2.7—Community Health and Safety Companies collaborate with relevant community members and other stakeholders, including workers who live in affected communities, in the scoping of community health and safety risks and impacts; the development of prevention or mitigation strategies; the collection of any data needed to inform the health risk and impact assessment process; and the design and implementation of community health and safety monitoring programs.
2.9—Obtaining Community Support and Delivering Benefits Companies collaborate with affected community members and other relevant stakeholders in the development of a participatory community development planning process to guide a company’s contributions to community benefits; and to monitor any mechanisms developed to deliver benefits.
2.10—Free, Prior and Informed Consent Companies collaborate with indigenous peoples to identify indigenous peoples’ rights and interests such as lands or resources that may be affected by the mining project; identify studies or assessments needed to determine potential impacts from the mine on these rights and interests; and design and implement plans to address information gaps. Engagement continues throughout the FPIC process, and if consent is given, throughout the life of the mine.
2.11—Cultural Heritage Stakeholders are consulted during cultural heritage screening, assessment and development of mitigation measures. If indigenous peoples’ cultural heritage is affected, they are engaged in and FPIC process before any critical cultural heritage is disturbed or used for commercial purposes.
2.12—Resettlement Individuals and communities potentially affected by resettlement are consulted during the assessment of risks and impacts; the development of Resettlement Action Plan and resettlement options; and resettlement implementation, including the monitoring of that implementation.
2.13—Grievance Mechanism and Access to Other Remedies Stakeholder are engaged in the development of a operational-level grievance mechanism, which will provide stakeholders and communities with culturally appropriate means of filing complaints and suggestions, and having their concerns addressed.
3.1—Water Quality Stakeholders are consulted in the assessment of mixing zones.
3.5—Noise Stakeholders are consulted in the development of mitigation plans for noise-impacted wildlife.
3.7—Protected Areas Stakeholders are consulted in the assessment of potential effects of mining on protected areas.
3.8—Biodiversity  Stakeholders are consulted in the assessment of potential effects of mining on biodiversity.
4.1—Environmental and Social Impact Assessment Stakeholders are consulted throughout the environmental and social impact assessment process, including scoping, the collection of data, the development of mitigation plans, and in the monitoring program. 
4.2—Reclamation and Closure Stakeholders can comment on reclamation and closure plan, and the mine’s financial surety; and if long-term water treatment may occur, stakeholders are consulted during the risk assessment and subsequent community/company discussions.

 

Endnotes

1. Herbertson, K., Ballestaeros, A., Goodland, R. and Munilla, I. 2009. Breaking Ground: Engaging Communities In Extractive And Infrastructure Projects. (World Resources Institute).

2. For example, Principle 10 of the Rio Declaration of 1992 states that, “Environmental issues are best handled with the participation of all concerned citizens.” See United Nations. 1992. Report of the United Nations Conference on Environment and Development. Annex I. “Rio Declaration on Environment and Development.” IRMA Guidance for this chapter will provide more information.

3. See 2.8.4. for explanation of accessible and culturally appropriate.

4. Guidance will provide examples of stakeholder advisory committees or their equivalent. The role that such a committee serves will be different in different communities. Some communities may be more concerned with environmental impacts, and want to play more of a role in reviewing monitoring data, while other communities may be more interested in development opportunities or community health impacts. Also, the interests, and therefore role of the committee may shift over time.

5. See 2.8.4. for explanation of accessible and culturally appropriate.

6. Capacity needs may be legal, technical, process-oriented (e.g., negotiation skills), logistical, or other.

7. Depending on the circumstances, appropriate assistance may be providing access to training, independent experts, etc. More information will be provided in IRMA Guidance.

8. Companies are not expected to release information that is culturally inappropriate, compromises the safety of any individual, is confidential employee information, or legitimate confidential business information. Culturally inappropriate information may include information that is sensitive to particular communities, and therefore should not be freely released to all requesting parties (e.g., information on locations of indigenous peoples’ sacred sites). Stakeholders can help to define for the company what is considered culturally appropriate.

9. Culturally appropriate communication includes interactions and conveyance of information using methods, languages, terminology and formats that are respectful of cultural differences (e.g., in some cultures, it is disrespectful to look directly into a person’s eyes); and can be easily understood by the affected communities and stakeholders.  As per requirement 2.8.1.3., stakeholders can help to define for the company what is considered culturally appropriate. Accessible:  there may be communities or groups within communities that are not literate, and therefore, need information conveyed in a form other than written (e.g., face-to-face meetings; video; audio). Some communities may prefer to receive information verbally. Some communities or groups within communities may not have reliable access to the internet or computers, and therefore would need written information in hard copy, available at a nearby locations during hours that enable access to individuals who work during the day.

 

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