GROUP STANDARD

Environment
Standard
 Group HSEC and Human Rights
Standard

ENVIRONMENT STANDARD
Contents
1 Purpose ............................................................................................................................................... 3
2 Scope ................................................................................................................................................... 3
3 Key terms ............................................................................................................................................ 4
4 Requirements...................................................................................................................................... 5
4.1 Environmental management ................................................................................................... 5
4.2 Boundaries, baseline data collection and assessments .......................................................... 6
4.3 Environmental impact, risks and opportunities ...................................................................... 6
4.4 Environmental management plans ......................................................................................... 7
4.5 Targets ..................................................................................................................................... 7
4.6 Specific requirements for environmental aspects .................................................................. 8
4.6.1 Air quality ................................................................................................................................ 8
4.6.2 Biodiversity .............................................................................................................................. 9
4.6.3 Land stewardship..................................................................................................................... 9
4.6.4 Water ....................................................................................................................................... 9
4.7 Environmental incidents ........................................................................................................ 10
4.8 Monitoring ............................................................................................................................. 11
4.9 Reporting ............................................................................................................................... 11
4.10 Review ................................................................................................................................... 11
5 Additional resources ......................................................................................................................... 12
5.1 Internal references ................................................................................................................ 12
5.2 External references................................................................................................................ 12

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1 Purpose
Glencore is committed to minimising harm to the environment, through environmental stewardship and
responsible resource management across our global operations. We identify and address potential
impacts of our business on the environment by applying the mitigation hierarchy (avoid, minimise,
restore/mitigate, offset), and address potential impacts on biodiversity with the ambition of achieving
no net loss.
The purpose of this standard is to set a mandatory requirement for all Glencore operations to
consistently identify and review environmental risks and opportunities related to air, water, land
stewardship, biodiversity and ecosystems services, integrating them into our business decision-making
and managing them effectively.
This Environment Standard has been developed to align with the requirements of our Environmental
Policy and to meet Glencore’s internal and external commitments.

2 Scope
This standard applies to all industrial assets controlled or operated by Glencore, that conduct or manage
activities with the potential to impact the environment. Within the industrial assets, it is particularly
relevant to those responsible for water, air quality, biodiversity, and land stewardship, such as HSEC
Leads, General Managers, Environmental Managers, Closure Managers and Land Managers.

Using a risk-based approach, in accordance with the HSEC & HR Management Standard, the
Environment Standard requirements apply to the following:
a) Air quality, including relevant airsheds and considering impacts on people, ecosystems and
operations
b) Biodiversity, including terrestrial, freshwater, coastal and marine, and considering ecosystem
services
c) Land stewardship1, land use and management of landholdings, including non-operational,
peripheral or buffer lands
d) Water, potable and non-potable water, marine, freshwater, groundwater, surface water,
precipitation, as well as industrially-affected and waste waters, water entrained in raw
materials, and products/waste.

1Rehabilitation of land where industrial activities have occurred and in which, in whole or part, operations have
been completed, is covered in the Closure Planning Standard. Rehabilitation should not be seen as an end of
asset/closure issue but, rather, progressive rehabilitation should be encouraged throughout Glencore operations.

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3 Key terms
Acid rock drainage (ARD) – occurs when certain types of rock, particularly those containing sulphide, are
exposed to oxygen and water to form atmospheric sulphuric acid. This has the potential to leach heavy
metals (such as lead, zinc and cadmium) from rock. ARD can manifest as either acidic, neutral
metalliferous or saline drainage. Includes acid mine drainage (AMD).
Adaptive management – a systemic process for continually improving management policies and
practices by learning from the outcomes of operational programs (do–monitor–evaluate–revise).
Air quality standards – these are the thresholds of pollutants in air, above which significant risks to
health or ecology are expected. These may be nationally-legislated or derived from global guidelines, as
defined by, for example, the World Health Organisation or United States Environmental Protection
Agency.
Air quality stewardship – this describes the process of protection of the airshed, in line with best
practice and regulation.
Airshed – the ambient air beyond the site boundary. The airshed is defined in terms of discrete
pollutants, for example, particulate matter, sulphur dioxide etc. Where the baseline is elevated above
air quality standards, the airshed is ‘degraded’, as defined by the International Finance Corporation.
Area of influence – the off-site area which may be impacted by emissions from a site or activity.
Baseline – measured, observed, or simulated conditions existing before development or expansion, or
at the beginning of a monitoring period, against which subsequent changes can be referenced.
Biodiversity – the variability among living organisms from all sources including, inter alia, terrestrial,
marine and other aquatic ecosystems and the ecological complexes and communities of which they are
a part. This includes diversity within species, between species and of ecosystems.
Biodiversity offsets – are a core instrument in the context of the no net loss target with respect to
species composition, habitat structure and ecosystem services. Offsets should be considered as the last
option in the mitigation hierarchy (see ‘Carbon offsetting’ below). Biodiversity offsets are often a
regulatory requirement as a component of project approvals but may also be voluntary.
Carbon offsetting – a carbon offset is a reduction in emissions of carbon dioxide or other greenhouse
gases made in order to compensate for emissions made elsewhere.
Ecosystem services – the benefits that people derive from the natural environment and ecosystems,
which are often undervalued. Examples include pollination, timber, erosion prevention, climate
moderation, nutrient cycles and flood alleviation as well as aesthetic and recreational benefits.
Fugitive emissions – emissions arising from a site that are ‘non-channelled’ (i.e. through a stack). Mobile
plant, equipment and on-site vehicles are classed as generating fugitive emissions because they move
around and are not in a fixed position (movement of these plant and equipment can also raise dust,
which is also fugitive).

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Land rehabilitation – set of activities or a process that brings an area of land back to an acceptable and
agreed state after it has suffered from adverse effects from direct or indirect disturbance, harm or
degradation over time, or a target state that will support post-industrial use.
Nature-based solutions – actions to protect, sustainably manage and restore natural or modified
ecosystems, which address societal challenges effectively and adaptively, while simultaneously
providing human well-being and biodiversity benefits.
No net loss – of biodiversity, means biodiversity losses are balanced by a gain elsewhere (Business and
Biodiversity Offsets Programme, 2013), in alignment with our commitments to ICMM Principles and
Performance Expectations.
Stewardship – this term is sometimes used as an alternative to ‘management’, including land,
biodiversity, and heritage resources, as stewardship typically requires collaboration with multiple
parties, and therefore can represent a more holistic approach with consideration of catchment context
approach beyond the traditional operational ‘fence line’.
Water catchment area – in alignment with ICMM, the term is used within this document both in the
technical sense of a watershed and in the broader sense of an area of influence.
Water conditions – collective term for all the water-related metrics measured, observed, or simulated
at the asset, and those which may be relevant to the wider catchment assessment in the asset’s area of
influence.

4 Requirements
The requirements in this standard, alongside those of the HSEC & HR Management Standard, are
mandatory. Inter-linking standards are outlined in section 5, as well as relevant guidance and references
(see ‘Additional Resources’).

In addition, legal compliance with relevant local legislation, planning, regulatory and reporting
requirements in all jurisdictions is mandatory. Where local legal requirements are of a higher standard
than the minimum requirements documented in our HSEC & HR Standards, we will adhere to the higher
requirement(s).

The requirements in this standard apply throughout the entire life cycle from exploration and
development of new projects and expansions to operation, decommissioning, closure, disposal and
relinquishment, as well as mergers and acquisitions.

4.1 Environmental management

All industrial assets must:
4.1.1 incorporate measurement, monitoring, reporting and assurance of environmental data and
performance in a management system, in accordance with the HSEC & HR Management
Standard

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4.1.2 define environmental performance management objectives and targets, aligned with the
asset’s, department’s and Group’s business objectives (see section 4.5), and

4.1.3 allocate business resources (people, time and budget) to deliver the requirements of this
standard, and ensure relevant competent professionals are engaged to support the specific
environmental risk areas (air quality, biodiversity, cultural resources including archaeological,
land stewardship and water).

4.2 Boundaries, baseline data collection and assessments

All industrial assets must:
4.2.1 identify and document the asset’s physical, natural and operational boundaries for
environmental risk areas, including consideration of the specific environmental topics detailed
in section 4.6
4.2.2 conduct comprehensive environmental data collection programmes and document associated
environmental baseline assessments, relative to the defined boundaries, using competent
professionals (internal or external), and
4.2.3 update baseline assessments at a suitable frequency where required, in response to changes in
the asset’s physical and operational boundaries. Identify trends, and update monitoring
programmes and plans accordingly for those risks identified as exceeding the threshold limit
set out in the HSEC & HR Management Standard.

4.3 Environmental impact, risks and opportunities

All industrial assets must:
4.3.1 conduct risk assessments using the baseline data, and consider environmental risks, impacts
and opportunities, as well as the specific requirements of section 4.6, consistent with the
Enterprise Risk Management Standard
4.3.2 consider the cumulative impacts when assessing risks such as industrial, agricultural and
recreational, within the asset catchment(s)
4.3.3 identify the potential for exceedances or non-compliances of local environmental standards
and regulatory requirements when undertaking risk assessments
4.3.4 integrate environmental risks/opportunities into business planning and review annually at
both asset and department levels
4.3.5 review environmental impacts, risks and opportunities at a suitable frequency based on risk,
consistent with the Enterprise Risk Management Standard, and
4.3.6 update monitoring programmes accordingly for those risks identified as exceeding the
threshold limit set out in the HSEC & HR Management Standard.

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4.4 Environmental management plans

All industrial assets must:
4.4.1 develop, implement and monitor relevant management plan(s) based on the specific
requirements in section 4.6, where the identified risks exceed the threshold defined in the
HSEC & HR Management Standard
4.4.2 document in management plans the identified risks, impacts and preventative measures,
following the hierarchy of control. In alignment with the HSEC & HR Management Standard,
management plans must, as a minimum, include:
a) a clear commitment to minimising impacts on the environment
b) a summary of risks, opportunities, preventative actions, and critical controls (including nature-
based solutions, where appropriate)
c) targets
d) defined roles and accountabilities
e) legal and corporate requirements
f) listing of pollutants of interest (specifically for air quality and water)
g) data management systems
h) assurance, and
i) internal and external communication protocols.
4.4.3 undertake stakeholder engagement in the development of management plans, in accordance
with the requirements of the Social Performance Standard, and
4.4.4 review and, if required, update environmental management plan(s) at a suitable frequency
based on risk, consistent with the Enterprise Risk Management Standard, or as directed by
new data, in alignment with the principles of adaptive management and continuous
improvement.

4.5 Targets
All industrial assets must:
4.5.1 develop asset-level targets for performance improvement across the relevant environmental
aspects in consultation with departments, where the identified environmental impacts and
risks exceed the threshold defined in the HSEC & HR Management Standard, and in accordance
with any approved internal and external HSEC & HR targets
4.5.2 develop processes for monitoring and tracking progress and trends against established targets
and include in management plans

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4.5.3 report performance against asset-level targets in line with the HSEC & HR Management
Standard.
All departments must:
4.5.4 develop and implement processes (e.g. biodiversity report cards) for the routine monitoring
and aggregation of asset-level targets’ performance, review biannually, and report annually on
progress against targets across their portfolio, in line with the HSEC & HR Management
Standard.

4.6 Specific requirements for environmental aspects

4.6.1 Air quality
All industrial assets must:
4.6.1.1 define the airshed assessment boundary, and conduct a screening study as part of baseline
assessments, identifying air pollutants of interest 2 and their expected inventory of emissions to
air, to support completion of risk assessments (see section 4.2)
4.6.1.2 establish the baseline conditions (see section 4.2) of the identified air pollutants of interest for
people, ecology and other natural resources, conduct monitoring, and update baseline
assessments at various stages of the life of the operation, where deemed necessary
4.6.1.3 conduct air quality risk assessments for identified air emissions, along with associated impact
assessments, noting that impacts and risks can arise even where approved air quality
thresholds are not exceeded
4.6.1.4 identify sources and emissions of interest (where the identified risks exceed the threshold
defined in the HSEC & HR Management Standard) that require design, abatement and
mitigation measures to eliminate unacceptable impacts
4.6.1.5 prepare an air quality management plan, following the management plan structure in section
4.4, and also:
a) include clear commitments and actions for the minimisation of impacts on the airshed, and
b) identify required ambient air quality monitoring (including calibration and verification) and
abatement measures.

2 Examples of air pollutants of interest are provided in the Environmental Toolkit. The specific list will
depend on the types of activity undertaken, the types and proximity of sensitive receptors and the
condition of the baseline airshed. Greenhouse gases (GHG) such as carbon dioxide, methane and nitric
oxide are not regarded as pollutants of interest for air quality, as they have low toxicity for humans
(refer to the Energy & Climate Change Standard for GHG management).

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4.6.2 Biodiversity
All industrial assets must:
4.6.2.1 define the physical and operational boundaries for biodiversity conservation and ecosystems
services
4.6.2.2 undertake biodiversity and ecosystems services baseline studies, as per section 4.2
4.6.2.3 conduct a risk assessment of biodiversity and ecosystems services, as per section 4.3
4.6.2.4 develop biodiversity management plans, following the structure of section 4.4, covering both
biodiversity and ecosystems services aspects, and considering nature-based3 and emerging
biodiversity solutions, where appropriate.

4.6.3 Land stewardship

All industrial assets must:
4.6.3.1 define the area of potential impacts, and conduct a baseline assessment, as per section 4.2,
including ownership and operational control boundaries, management arrangements, and
classification of land use by type and area
4.6.3.2 undertake a risk assessment of land stewardship issues, in accordance with section 4.3,
including emerging regulatory requirements, land uses employed, and the stage in the
operational/activity life cycle, and
4.6.3.3 develop a land management plan, following the structure of section 4.4, and include processes
to provide for responsible management of landholdings and specific land stewardship
programmes. Where progressive rehabilitation is conducted during the land management
process, these must also comply with the requirements of the Closure Planning Standard.

4.6.4 Water
All industrial assets must:
4.6.4.1 conduct a water baseline assessment, evaluating both the asset and its catchment context,
including those aspects related to sustainable and healthy ecosystem functioning
4.6.4.2 undertake a water risk assessment, including consideration of operational risks and impacts
across the catchment area(s), and establish systems for identifying/tracking key stakeholders
within the catchment(s)

3 In addition to the human well-being and biodiversity benefits, nature-based solutions are also
increasingly being used as a carbon offsetting opportunity. Protection and enhancement of biodiversity
within operational and value chain land holdings can deliver carbon removal.

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4.6.4.3 consider climate-related risks and opportunities when assessing water-related risks (refer to
the Energy & Climate Change Standard), assessing current and future projected climatic
variability within the catchment area and the impact on shared water resources, water quality
and supply, and operational requirements
4.6.4.4 develop a catchment context-based water management plan, following the structure of
section 4.4
4.6.4.5 develop and maintain the following in support of the Water Management Plan, focusing on
identified risks that exceed the threshold defined in the HSEC & HR Management Standard:
a) a catchment-level water balance, where catchment-level risks are identified, which identifies
and manages risk drivers within the operation, taking into consideration key ecological and
stakeholder interests4
b) an asset-level water balance (where asset-level risks are identified) throughout the lifecycle of
the operation and demonstrate processes to define how it relates to the current and long-term
cumulative impact of other users
c) an asset-level surface-groundwater model, where water-related disturbance is possible, and
update annually where material changes have occurred, or in line with operational changes or
regulatory requirements.
4.6.4.6 based on the asset and catchment water risks identified, collect, monitor and maintain
relevant and accurate water-related metrics, allowing for effective analysis/interpretation, and
enabling efficient resolution of queries
4.6.4.7 allocate appropriate financial resources to adequately compensate for any potential liabilities
associated with water, as per the requirements described in the Closure Planning Standard,
and
4.6.4.8 conduct routine reviews of these impacts and financial resources and regularly adjust in
accordance with the HSEC & HR Management Standard, to assess changes in operations or
conditions on meeting long-term liabilities.

4.7 Environmental incidents

All industrial assets must:
4.7.1 identify, record, report and investigate environmental incidents in accordance with the HSEC &
HR Incident Management Procedure and Classification of Incidents with Environmental

4Local relevant jurisdictional requirements regarding engagement with other stakeholders (such as water data
sharing in Australia) would be considered, in whole or part, as contributing towards meeting the catchment
context approach requirement in the standard.

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Consequences Reporting Procedure, considering cross-functional impacts (e.g. community,

reputational, etc.) and assessment of HPRIs
4.7.2 identify and implement remedial actions to avoid repeat environmental incidents
4.7.3 conduct regular reviews of environmental-related incidents (quarterly at minimum) to identify
trends
4.7.4 communicate lessons learned from incident investigations with relevant stakeholders, where
the identified impacts exceed the threshold defined in the HSEC & HR Management Standard,
and
4.7.5 ensure emergency and crisis management and response plans adequately cover and test
environmental incidents identified as part of this standard, in accordance with the Crisis
Management and Emergency Response Standard.

4.8 Monitoring
All industrial assets must:
4.8.1 design and implement processes to monitor environmental performance based upon the
specific management plans and specific requirements in section 4.6
4.8.2 implement data management procedures to undertake verification and validation of
monitoring data, and
4.8.3 update HSEC & HR management systems and actions, as required, to improve environmental
performance.

4.9 Reporting
In accordance with the HSEC & HR Management Standard, all industrial assets must:
4.9.1 implement processes for internal reporting and external public disclosure, where relevant, at a
region and/or jurisdictional level, and
4.9.2 aggregate data and contribute, as required, to overall Group-level data collection and public
disclosure and reporting requirements.
4.10 Review
All industrial assets must:
4.10.1 review their compliance to this standard at least annually, or when there have been material
operational changes, new projects or expansions, or as specified by regulatory requirements,
and
4.10.2 review asset-specific risk assessments at a suitable frequency with the goal of achieving
continuous improvement.

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5 Additional resources
5.1 Internal references
There are strong links between this standard and the following standards and procedures: Cultural
Heritage, Environment, Human Rights, Social Performance, Closure Planning, Tailings Storage Facility
and Dam Management, Energy & Climate Change, HSEC & HR Management Standard, Enterprise Risk
Management Standard, Responsible Sourcing Standard, and Classification of Incidents with
Environmental Consequences Procedure. This standard must therefore be implemented in conjunction
with, and consideration of, these other requirements.

The water aspects of this standard also align with the Glencore Water Management Guideline, which is
included as guidance in the associated Environmental Toolkit.

5.2 External references

International Council on Mining and Metals (ICMM) Mining Principles: Performance Expectations,
February 2020.
IFC Performance Standards
UNGC SDGs
Water:

'A practical guide to catchment-based water management for the mining and metals industry', ICMM,
2015
'Setting Site Water Targets Informed By Catchment Context: A Guide For Companies', UN Global
Compact CEO Water Mandate, Pacific Institute, CDP, The Nature Conservancy, World Resources Institute,
WWF, UNEPDHI
Partnership Centre for Water and Environment, 2019
Mining Association of Canada – Water Stewardship Protocol
Biodiversity:

United Nations Convention on Biological Diversity

International Union for Conservation of Nature (IUCN)
Air Quality:

World Bank Group/International Finance Corporation EHS Guidelines for Air Emissions and Ambient Air
Quality, and Sector Specific Guidelines
European Union Best Available Technique Reference Notes (BREF notes)

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World Health Organisation Air Quality Guidelines (2000 and 2005 update)

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