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RESPONSIBLE MINERALS

ASSURANCE PROCESS
ENVIRONMENTAL, SOCIAL &
GOVERNANCE (ESG) STANDARD
FOR MINERAL SUPPLY CHAINS
June 2021
TABLE OF CONTENTS
I. Introduction ........................................................................................................... 3
II. Limitations ............................................................................................................. 4
III. Conformance Criteria ............................................................................................. 4
IV. Companies/Facilities and Activities Within the Scope of an Assessment .................5
V. Environmental Standards ........................................................................................ 6
VI. Occupational, Health and Safety (OHS) Standards ................................................ 11
VII. Social Standards .................................................................................................. 18
VIII. Governance Standards ......................................................................................... 24
IX. Annexes ............................................................................................................... 27
Annex A: Definition of terms and acronyms 27
Annex B: Effective date & revision history 29

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 2
I. INTRODUCTION
adapted, depending on the geographical and legal
context of the assessed processor. Where this stan-
NOTE dard conflicts or is not consistent with permitting
Terms that are bold and italicized have specific and regulatory requirements at the multi-national,
definitions set forth in Annex A. national, regional, state and local levels, the proces-
sor is expected to comply with those legal require-
ments.

The Responsible Minerals Initiative (RMI) encour- The Responsible Minerals Assurance Process
ages the responsible sourcing of minerals globally. (RMAP) utilizes independent third-party assess-
To incentivize and improve on-site practices in the ments of processor management systems and
mineral value chain, the RMI issues this volun- sourcing practices to validate conformance with
tary Environmental, Social and Governance (ESG) RMAP requirements. The criteria in this standard
standard for mineral supply chains. This standard form the basis of the independent third-party
assessments to determine a processor’s confor-
sets forth the criteria for determining conformance
mance in accordance with the ISO 19011:2018 audit
with the RMI program requirements for environ-
standard. Companies can choose to use the assess-
mental, social, health & safety, governance at
ment results to support customer requests, meet
mineral processing companies. The standard was
regulatory requirements, and continually improve
benchmarked against and are consistent with the
ESG management systems.
RMI’s Risk Readiness Assessment and the RBA’s
Validated Assessment Process (VAP), and nineteen RMAP follows the International Organization for
other existing international credible ESG standards Standardization (ISO) 19011:2018 auditing standard
(twelve of which are specific to and/or sponsored in conducting an independent third-party assess-
by metals processing industries). ment. ISO 19011:2018 is issued by the International
This standard is aligned and consistent with Organization for Standardization and provides
ISO14001, ISO45001 and similar international guidance on auditing management systems, includ-
ing the principles of auditing, managing an audit
standards. ISO and similar frameworks may not
cover all elements of this RMI standard or offer the program and conducting management system
audits, as well as guidance on the evaluation of
detail and specificity required for the RMI confor-
competence of individual auditors involved in the
mance. ISO certifications may be in-part instructive
audit process.
in determining conformance to this standard, but it
is not wholly determinative. In establishing man- Auditors must apply professional judgment and
agement systems elements in alignment with ISO obtain reasonable assurance that evidence is
standards, processors shall incorporate the require- sufficient and appropriate when conducting the
ments set forth in this document. assessment. In this standard, the word ‘must’ is
The criteria in this standard are used by an audit used where a matter is a requirement for achieving
firm and their individual auditors to assess respon- conformance to the standard. The word ‘must’
sible workplace and other ESG matters at mineral is also used to indicate activities or tasks that are
processors, including those integrated with mine mandatory for an auditor to conduct as part of an
sites, in all countries. For the purposes of this assessment that meets the quality
standard, processor definition includes, but is not assurance requirements.
limited to, smelters, refiners (fine and crude), pro-
cessors, treatment units, transformation operations,
toll millers, aggregators and recyclers operating in
the mineral/metal supply chains. Not every issue
will apply to each processor. Each processor is
expected to make and document applicability,
which will be reviewed and assessed by an RMAP
auditor. This standard can be further specified or

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 3
II. LIMITATIONS III. CONFORMANCE
The standard criteria cover certain ESG matters
that companies may be faced with as part of their
CRITERIA
operations. However, these criteria are not exhaus-
These standards apply to operating conditions and
tive. A successful assessment must not be used
procedures of the processor’s own facility, equip-
to imply operating performance beyond the strict
ment, systems and employees. The ESG standards
scope of this standard, and does not determine that
reflect legal requirements and operating standards
minerals, materials or products are free from ESG
for mineral processors. These standards are not
risks such. Assessment results provide the pro-
exhaustive; applicable legal standards and specific
cessor with a status of how aligned the processor
technical, operating and documentation require-
is with RMI’s ESG standard, and where gaps may
ments must be identified by the processor and
exist needing attention. Processors can also use
assessor using these standards.
this information and assessment results to inform
or support other needs such as responding to cus-
tomer and investor inquiries, regulatory and market
requirements (including London Metals Exchange) VOLUNTARY ESG STANDARD
or ISO certifications. Assessment of information
disclosed among supply chain actors, to auditors, Applying RMI’s ESG standard is a voluntary
other stakeholders and the public will take into component that companies may elect to com-
account the protection of business confidentiality. plete in addition to the relevant mineral RMAP
Standard due diligence assessment. The ESG
criteria are not a requirement for RMAP
smelter/refiner conformance.

An assessment may combine this RMAP ESG stan-


dard and RMAP mineral supply chain due diligence
standards applicable to the facility or may be con-
ducted separately. In either case, these cases, sepa-
rate audit reports will be issued for each standard.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 4
IV. COMPANIES/
FACILITIES AND
ACTIVITIES WITHIN
THE SCOPE OF AN
ASSESSMENT
Companies with facilities that meet the
definition of a processor are eligible to use this
standard. All processor activities, processes and
systems used to implement ESG requirements
and manage operations regarding mineral
processing, including the management system,
risk management, and disclosure of information
are in scope for the assessment.

Operations associated with all minerals and


materials, physically received, held, and/or
processed at an in-scope processor during the
assessment period, regardless of origin, storage
location and type, are included. Materials sent
to or received from a third party for processing
under a tolling agreement during the assessment
period are also included. This standard includes
limited obligations on the part of processors to
evaluate basic environmental, OHS, social and
governance risks at mine sites in its supply chain.
This can be accomplished through review of
mine-level assessment reports, where available,
or on-site visits and other assessments. The pro-
cessor shall also demonstrate understanding and
supporting the context of artisanal and small-
scale mining (ASM) mineral suppliers,
where relevant.
Where a processor makes claims that operations
are not covered by the assessment or out-of-
scope for any element of this standard, those
claims must be verified.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 5
V. ENVIRONMENTAL STANDARDS
1. Organizational Context and Interested 3. Environmental Management. To achieve the
Party Concerns intended outcomes, including enhancing its
The processor maintains a process to determine environmental performance the processor has:
external and internal issues that are relevant to • Documented and implemented system for
its purpose and that affect its ability to achieve identifying and managing environmental
the intended outcomes of its environmental issues at the operating site relevant to its
management system. Such issues shall include activities, services and processes;
environmental conditions being affected by or ◦ The processor should ensure that per-
capable of affecting the organization. sonnel with environmental management
The processor maintains a process to evaluate responsibilities have/maintain relevant
of the Needs and Expectations of Interested training and education related to their
Parties that are relevant to its purpose and duties and has assigned environmental
that can impact the desirable outcomes of management responsibility to a member
the Environmental Management System. of senior management at the site;
Additionally, this process will link with the Legal ◦ The processor should maintain correc-
Compliance and Other Requirements process. tive and preventive action processes that
address environmental related incidents
2. Legal Compliance. The processor has as well as evaluation of effectiveness;

• Identified all applicable environmental per- • Where mining operations are co-located
mitting and regulatory requirements at the with, and under the control of, the company
national, regional, state and local levels; the mining operations should implement
mining industry environmental standards in
• Obtained all applicable environmental per- addition to legal compliance requirements;
mits and authorizations;
• Where the mining operations are not part of
• Maintained adequate documentation to the company operations, processors sourc-
demonstrate on-going compliance with all ing mined materials should make best efforts
applicable environmental permitting and reg- to verify that the mine is independently
ulatory requirements at the operating site; assessed under internationally accepted LSM
• Maintained documentation concerning any or ASM standard, including evaluation of
legal enforcement actions/lawsuits involving environmental impacts;
the processors and corrective actions/resolu- ◦ Where such assessments are not avail-
tion of such actions; able, the processors should make best
efforts to conduct site-visits or review
other assessments and data, as relevant.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 6
4. Environmental Policy tion of aspects, processor should determine the
Processor’s Top Management should define significant aspects that have an impact on the
document and endorse an environmental policy environment (both threats and opportunities).
which is appropriate to the nature, and scale of Criteria used to identify and determine aspects
environmental impacts of its activities, products and significant aspects should be determined
and services. The policy should consider includ- based on several factors including scale, sever-
ing a commitment to continual improvement, ity and frequency, and be documented.
prevention of pollution, and commitment to An evaluation to determine which of the iden-
comply with legal and other requirements. The tified environmental aspects and have or can
policy should also set a framework for the set- have a significant environmental impact or
ting of- and reviewing of environmental objec- health and safety risk before:
tives and targets. It’s expected that the policy • Start-up of a new activity, process or service;
be available and accessible to all processing
company employees and to the public. • Modification of an existing activity, product
or service which creates new environmental
aspects or increases the significance of exist-
5. Identification of Risks and Opportunities ing environmental impacts; or
Processor is expected to acknowledge that risk • Whenever there are changes to applicable
management is an essential element in the environmental rules and regulations.
framework of good corporate governance and
is an integral part of good management prac-
tice. To that end, processor should develop and 7. Environmental Objectives and Targets
establish a methodical and structured approach
When establishing its environmental objec-
to managing risks throughout the organiza-
tives, processor should ensure that each goal
tion. A formal Risk Management program can
is established at the proper level within the
be implemented wherein each processor can
organization and is consistent with its overall
effectively determine its potential risks and
policies and requirements to ensure confor-
opportunities that will have an impact on the
mity and continual improvement. Objectives
achievement of organizational goals and objec-
are set based on the Significant Aspects, cor-
tives, the needs of its stakeholders and risks
porate initiatives, and continual improvement
that would affect the conformity of its pro-
opportunities, several of which are noted in
cesses and final product. The intent is to embed
the media-specific environmental controls
risk management in a very practical way into
described in the following sections.
normal day-to day business and operational
processes/functions via reviewing processes
and controls to add significant value to 8. Resources and Competence
the company. Processor must determine the level of training,
awareness and competence for employees
or others working on behalf of the company,
6. Significant Environmental Aspects and Impacts
whose work may create a significant impact
Processor must plan actions to address risks on the environment. Processor must ensure
and opportunities as they pertain to their envi- employees are trained or otherwise qualified,
ronmental management system, inclusive of its and require contractors or others working on
significant environmental aspects and environ- behalf of the organization to demonstrate that
mental obligations. they are qualified to perform environmental
Processor should establish a process to identify management and support functions.
and document the environmental aspects of its All employees and contractors/suppliers whose
activities and services that it can control and work or activities/services could create a sig-
influence. Some of the key considerations when nificant environmental impact are required to
assessing environmental aspects are changes to have appropriate training for their specialized
the business, process development, continual function(s).
improvement, foreseeable risks and opportuni-
ties due to emergencies. During the identifica-

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 7
Processor must ensure that all employees and For mobile emissions sources owned or oper-
contractors/suppliers performing unescorted ated by the processor, the processor has:
work at sites are provided with environmental • Determined and uses the fuel type for each
management system awareness training to source in accordance with manufacturer
ensure (at a minimum) the employee/contractor specifications;
understands the importance of conformance
with the environmental policy and processes • Established a mobile emissions baseline
and with the requirements of the EMS. against which it measures reductions;
• Operates and maintains the equipment in
accordance with manufacturer specifications
9. Technical Environmental Data and Supporting and has not bypassed emissions control
Information. equipment;
Technical environmental information relied • Developed a documented emissions reduc-
on by a processor must be produced through tion plan in relation to the baseline.
means that are credible, reliable and valid for
the specific purpose. For example, engineering
calculations must be performed by qualified 11. Greenhouse Gas (GHG) Emissions.
engineers and laboratory analyses must be The processor has:
done by qualified labs. Processor must assure
• Determined GHG Emissions Scope (1 – direct
that calibration of critical environmental control
emissions, 2 – emissions from purchased
equipment occurs and records kept. A proces-
energy, and/or 3 – emissions from suppliers)
sor’s in-house laboratory may be acceptable if
of its program;
properly accredited by regulatory authorities
and/or follows relevant analytical, QA/QC and • Quantified and documented a CO2
equipment calibration procedures. emissions baseline;
• Established reduction targets and a doc-
umented reduction plan for the
10. Air Emissions (other than GHG)
identified Scope(s);
For fixed (stationary) emissions sources, the
• Analyzed and publicly reported CO2 or CO2
processor has:
equivalent emissions in line with estab-
• Developed and documented an inventory of lished international reporting protocols (e.g.,
the emissions sources and types, including Intergovernmental Panel on Climate Change
a baseline against which it measures reduc- or GHG Protocol), and has established reduc-
tions; tion targets on either an absolute or intensity
• Determined permitting and emissions con- basis and monitor progress over time.
trols requirements;
• Properly installed, operates and maintains 12. Noise. The processor has:
emissions control equipment, and prohibits
• Assessed/measured noise levels at the prop-
bypassing emissions control equipment in
erty boundary to determine potential impact
accordance with manufacturer specifications;
to neighboring land uses, including a baseline
• Conducted and documented inspections against which it measures reductions;
and maintenance of the control equipment,
• Implemented noise abatement controls in
including monitoring equipment calibration
accordance with applicable requirements or
in accordance with manufacturer specifica-
where none exist, relevant
tions;
international standards;
• Developed a documented emissions reduc-
• Means in place to ensure noise standards are
tion plan in relation to the baseline.
not exceeded as appliable to the appropriate
area classification/type;
• Developed a documented noise reduction
plan in relation to the baseline.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 8
13. Energy Consumption. The processor has: • Conducted and documented inspections and
• Means in place to measure its energy con- maintenance of the control/treatment equip-
sumption, including a baseline against which ment in accordance with manufacturer speci-
it measures reductions; fications including monitoring and laboratory
measurement equipment calibration;
• Identified, implemented and quantified
energy efficiency improvements; • Developed a documented discharge reduc-
tion plan in relation to the baseline.
• Investigated opportunities for non-fossil fuel
energy sources;
• Where possible, increased use of/continual 16. Soil Erosion Management. The processor has:
improvement concerning renewable energy. • Conducted a site erosion evaluation
and baseline;

14. Freshwater Management and Conservation. • Periodically evaluates erosion areas for its
The processor has: operations, especially when evaluating new
construction or soil-disturbing work;
• Conducted and documented an assess-
ment of water use impacts, including those • Implements soil erosion controls where
associated with possible cyanide use in needed based on the site assessment
processing applications; and inspections.

• Obtained freshwater use or withdrawal


authorization where necessary; 17. Waste Management. The processor has:
• Evaluated measures to ensure that water • Developed and documented an inventory of
consumption does not restrict availability/ waste sources, types and current disposal/
access for other water users or reduce the treatment locations and methods, including
range and populations of fauna and flora in a baseline against which it measures reduc-
the area of the site / facility; tions;
• Evaluated opportunities to reduce freshwater • Obtained waste management authorization
use, including increasing water reuse/recy- or registrations where necessary;
cling where practical; • Implemented a waste management system
• Developed a documented water use reduc- that includes a commitment to the waste
tion plan in relation to the baseline. hierarchy and is applicable to all waste types
(hazardous, non-hazardous and inert);

15. Wastewater Discharges. The processor has: • Used authorized waste management ven-
dors for waste transportation, treatment and
• Developed a documented inventory of waste- disposal and prevents unauthorized disposal
water sources and types, including a base- of all wastes (on-site on the processor’s
line against which it measures reductions; property and off-site by employees or waste
• Determined permitting, authorization and management vendors);
wastewater discharge controls/treatment • Maintained documentation of all off-site
requirements, including those associated waste management activities;
with possible cyanide use in
processing application; • Separated waste types during on-site accu-
mulation, especially wastes that are incom-
• Installed, operates and maintains wastewater patible (i.e., create a chemical reaction when
discharge control/treatment equipment, in mixed that results in heat, flame, vapors
accordance with manufacturer specifications; or gas);
• Prohibited bypassing • Stored wastes in containers that are in good
control/treatment equipment; condition, compatible with the wastes stored
and labeled in the appropriate language(s)
for the work force;

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 9
• Conducted and documented regular inspec- • Has procedures and/or engineering controls
tions of waste generation, accumulation and to prevent the overfill of tanks;
management areas; • Has procedures and/or engineering controls
• Minimized the amount of time waste is to capture and minimize the spread of any
accumulated on-site before it is shipped to spills including from
off-site treatment/disposal; loading/unloading areas;
• Developed a documented waste reduction • Conducts routine formal and informal
plan in relation to the baseline; inspections of all tanks, associated piping,
• A documented waste spill/response plan in valves and flanges and alarms;
place, including appropriate spill response • Permanently disconnects and removes from
equipment available. service tanks that are no longer needed or
intended to be used;

18. Biodiversity, Forests and Protected Areas. • Tanks that are temporarily out of service
The processor: are blind-flanged or disconnected from
service piping.
• Has documented the location(s) of nearby
protected areas such as forests, wildlife pre-
serves/management areas, areas of cultural 20. Emergency and Spill Response.
or historical significance; The processor should maintain a process for
• Does not use, operate or encroach on pro- responding to ALL potential accidents and
tected areas such as forests, wildlife pre- emergency situations as well as an emergency
serves/management areas, areas of cultural contingency plan. These procedures identify
or historical significance (i.e., World Heritage the potential for accidents/incidents and the
sites); response actions to be taken during emergency
• Avoids adverse impacts on Critical Habitats situations (e.g., fires, chemical spills, evacua-
and Endangered Species; tions, etc.) in order to prevent and/or mitigate
the associated environmental impacts which
• Maintains a buffer area between its opera- may be associated with them.
tions and any protected areas/land to which
it may be adjacent; The processor has a written spill response plan
that includes:
• Includes consultations and provision of rel-
evant information (if requested) with stake- • An updated inventory (including amounts)
holders, including, where relevant, affected of chemicals/fuels that have the possibility of
communities and external experts. being spilled/released and spill prevention/
containment controls that are in place;
• Specific procedures employees are expected
19. Chemical/Fuel Storage Tanks/Containers. to take in the event of a spill;
The processor:
• This may include prohibiting employees
• Has an updated written inventory of all abo- from responding and leaving that to emer-
veground and underground storage tanks on gency authorities or spill response contrac-
site, including the operational status, chemi- tors;
cal stored and indication of spill
prevention mechanisms; • Any specified emergency equipment must
be available on-site in sufficient quantities to
• Has an updated written inventory of all respond as expected;
aboveground and underground storage
containers (such as drums, totes, etc.) on • How the processor will manage spills/
site, including the operational status, chemi- releases after immediate response (e.g., spill
cal stored and indication of spill residue disposal);
prevention mechanisms; • Periodic inspections and replenishment of
• Has labeled or marked tanks and containers emergency response equipment;
with the contents, hazards and operational
status (if out of service, empty or unused);

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 10
VI. OCCUPATIONAL, HEALTH AND
SAFETY (OHS) STANDARDS
1. Organizational Context and Interested Party 3. Occupational Health and Safety Management.
Concerns The processor has:
The processor maintains a process to determine • Formal and documented system for identify-
external and internal issues that are relevant to ing, managing and reducing OHS hazards at
its purpose and that affect its ability to achieve the operating site; and
the intended outcomes of its OHS management • Health and Safety Committee, comprised of
system. Such issues shall include safety hazards management representatives and workers.
and risk conditions being affected by or capable Unless otherwise specified by law, at least
of affecting the personnel working for or on one worker member(s) on the Committee
behalf of the organization. shall be by recognized trade union(s) repre-
The processor maintains a process to evaluate sentative(s), if they choose to serve;
of the Needs and Expectations of Interested ◦ In cases where the union(s) does not
Parties that are relevant to its purpose and that appoint a representative or the organi-
can impact the desirable outcomes of the OHS zation is not unionized, workers shall
Management System. Additionally, this process appoint a representative(s) as they deem
will link with the Legal Compliance and Other appropriate; its decisions shall be effec-
Requirements process tively communicated to all personnel;
◦ The Committee shall be trained and
2. Legal Compliance. The processor has retrained periodically to be competent and
• Identified all applicable OHS requirements at committed to continually improving the
the national, regional, state and local levels health and safety conditions in
based on the number of workers at the site; the workplace;

• Obtained all applicable OHS permits ◦ It shall conduct formal, periodic occupa-
and authorizations; tional health and safety risk assessments
to identify and then address current and
• Maintained adequate OHS documentation potential health and safety hazards;
to demonstrate ongoing compliance with all
applicable permitting and regulatory require- ◦ Records of these assessments and correc-
ments; tive and preventive actions taken shall
be kept;
• Process to ensure personnel with OHS
management responsibilities have/maintain
relevant training and education related to
their duties;
• Where mining operations are co-located
with, and under the control of, the company
the mining operations should implement
mining industry OHS standards in addition to
legal compliance requirements;

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 11
• Where the mining operations are not part of to managing risks throughout the organiza-
the company operations, processors sourc- tion. A formal Risk Management program can
ing mined materials should make best efforts be implemented wherein each processor can
to verify that the mine is independently effectively determine its potential risks and
assessed under internationally accepted LSM opportunities that will have an impact on the
or ASM standard, including evaluation of achievement of organizational goals and objec-
OHS risks. Where such assessments are not tives, the needs of its stakeholders and risks
available, the processors should make best that would affect the conformity of its pro-
efforts to conduct site-visits or review other cesses and final product. The intent is to embed
assessments and data, as relevant; risk management in a very practical way into
• The company shall evaluate occupational normal day-to day business and operational
health and safety (OHS) conditions are processes/functions via reviewing processes
adequate to maintain the miners’, direct and and controls to add significant value to
indirect employee’s physical and mental the company.
health. For ASM, at a minimum,
this includes: 6. OHS Objectives and Targets
◦ Basic mine safety rules are defined and When establishing its OHS objectives, proces-
followed by the artisanal miners; sors should ensure that each goal is established
◦ Appropriate personal and well-maintained at the proper level within the organization
protective equipment is provided to and and is consistent with its overall policies and
used by the artisanal miners. requirements to ensure conformity and contin-
ual improvement. Objectives are set based on
the Significant OHS hazards and risks, corpo-
4. OHS Policy rate initiatives, and continual improvement
Processor’s Top Management should define opportunities, several of which are noted in
document and endorse an environmental policy hazard specific technical areas described in the
which is appropriate to the nature, and scale following sections.
of OHS hazards and risks of its activities, prod-
ucts and services. The policy should consider
including a commitment to provide safe and 7. Resources and Competence
healthy working conditions for the prevention of Processors must determine the level of train-
work-related injury and ill health, commitment ing, awareness and competence for employees
to continual improvement, and commitment to or others working on behalf of the company,
comply with legal and other requirements, and whose work may create a significant OHS risk.
a commitment to participation, i.e., the involve- Processors must ensure employees are trained
ment of workers’, and where they exist, work- or otherwise qualified, and require contractors
ers’ representatives, in the decision-making or others working on behalf of the organiza-
processes in the OH&S management system. tion to demonstrate that they are qualified to
The policy should also set a framework for the perform support functions, especially high
setting of- and reviewing of OHS objectives and hazard activities.
targets. It’s expected that the policy be avail- All employees and contractors/suppliers whose
able and accessible to all processing company work or activities/services could create a signif-
employees and to the public. icant OHS hazard are required to have appro-
priate training for their specialized function(s).
5. Identification of Risks and Opportunities Processors must ensure that all employees and
contractors/suppliers performing unescorted
Processors are expected to acknowledge that work at sites are provided with OHS manage-
risk management is an essential element in the ment system awareness training to ensure (at
framework of good corporate governance, and a minimum) the employee/contractor under-
is an integral part of good management prac- stands the importance of conformance with the
tice. To that end, processors should develop and OHS policy and processes and with the require-
establish a methodical and structured approach ments of the OHSMS.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 12
8. Hazard Identification. 10. Personal Protection Equipment (PPE). Based on
The processor has identified and documented the job safety assessments and hazard identifi-
the OHS exposures – including industrial cation, the processor:
hygiene - to employees, contractors and visitors • Makes appropriate PPE available to employ-
appropriate for the task, activities or purpose of ees, contractors and visitors at no cost, and
the individual. Hazards may include: ensures employees, contractors and visitors
• Chemical; are aware that replacement PPE is available
if needed;
• Biological;
• Ensures inventories of PPE are adequate;
• Physical;
• Ensures PPE is stored in sanitary conditions;
• Electrical;
• Trains employees, contractors and visitors
• Fire; on proper use and fit of PPE as appropriate
• Environmental (temperature, lighting, to their function in the workplace. Training
ventilation). includes new employee onboarding, periodic
refresher training, and when an employee’s
An evaluation to determine which of the iden-
job function changes requiring new types
tified OHS hazards and risks and have or can
of PPE;
have a significant health and safety risk before:
• Monitors and enforces proper use of PPE by
• A start of a new activity, process or service;
employees, contractors and visitors.
• Modification of an existing activity, product
or service that creates new OHS hazards or
increases the significance of existing OHS 11. Emergency Response/Egress. The processor:
impacts; or • Has a documented evaluation of the site/
• Whenever there are changes to applicable operations for emergency
OHS rules and regulations. response/egress needs;
Processors should consider a life cycle • Has emergency exits that are appropriate in
approach in establishing a hierarchy of con- number, location, adequacy;
trols, including administrative and engineering • Ensures emergency exists are maintained in
controls to eliminate hazards, and the use of an unlocked, operating and
personal protective equipment (see below). unobstructed condition;
• Ensures emergency pathway lighting and
9. Technical OHS Data and Supporting signage are adequate, regularly tested, oper-
Information. ating and in the appropriate language(s) for
the work force;
Technical OHS information relied on by a pro-
cessor must be produced through means that • Trains employees, contractors and visitors
are credible, reliable and valid for the specific on emergency response and egress require-
purpose. For example, engineering calculations ments, including conducting drills. Training
must be performed by qualified engineers, lab- includes new employee onboarding, periodic
oratory analyses must be done by qualified labs refresher training, and when an employee’s
and medical assessments must be performed job function changes requiring new emer-
by qualified medical professionals. gency response duties or egress paths;
• Has established and documented arrange-
ments in place with emergency response
authorities such as fire responders, law
enforcement and hospitals/doctors.

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12. Fire safety. The processor has: • No informal or unauthorized electrical con-
• Established and maintains a fire safety com- nections are allowed or exist;
mittee; • Extension cords are not used for
• Conducted and documented a fire and permanent service;
safety evaluation; • Electricians are properly trained and pro-
• Installed sprinklers and fire extinguishers vided with proper electrical safety and test-
with signage in the appropriate language(s) ing gear;
for the workforce; • Wiring/equipment in wet areas suitable for
• Implemented an inspection, testing and that service;
maintenance program for fire safety equip- • Signage and other warning methods are in
ment; place for overhead electrical service, espe-
• Repaired or replaced fire safety equipment in cially in areas of vehicular traffic;
a timely manner; • Electrical safety inspections are conducted
• Correctly installed all fire safety equipment, and documented on a regular basis.
including sprinklers and fire extinguish-
ers, hose reels, extraction fans, 14. Equipment Safety (Lock Out-Tag Out, Machine
alarms/detectors, etc.; Guarding, etc.). The processor has developed,
• Ensures that firefighting equipment is documented and implemented an energy con-
unlocked and access is not blocked; trol (lock-out/tag-out) program that includes:
• Implemented a hot work management pro- • Documented evaluation and consideration of
gram including properly identifying hot work all applicable forms of energy on-site – elec-
activities, separation of hot work areas and trical, pneumatic, hydraulic, kinetic, etc.;
conducting fire watches; • Proper lock-out/tag-out tools, equipment,
• Maintains specifically designated smoking locks and tags in the appropriate language(s)
areas at least 50 feet from areas where flam- for the work force;
mable/combustible materials are emitted, • Employee, contractor and visitor training
used, loaded/unloaded, transferred or stored; as appropriate to their function in the work-
• Segregates combustible, flammable and place;
explosive materials from sources of potential • Evaluation and documentation of machine
heat, sparks, ignition or chemical reaction; guarding needs and types;
• Trained employees, contractors and visitors • Deployment of machine guarding equipment
on fire safety as appropriate to their function and signage in the appropriate language(s)
in the workplace; for the work force;
◦ Training includes new employee onboard- • Ongoing documented inspections and mon-
ing, periodic refresher training, and when itoring of lock out-tag out activities/equip-
an employee’s job function changes ment/procedures and machine guarding
requiring new fire safety duties. condition and effectiveness.

13. Electrical Safety. The processor ensures:


• All electrical junctions, boxes and breakers
are closed and labeled in the appropriate
language(s) for the work force;
• Electrical cords are in good condition without
temporary repairs;
• No exposed/bare wiring or other electrical
conductors are allowed or exist;

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 14
15. Vehicle/Powered Equipment Safety. The pro- 18. Structural Safety (pits, shafts, buildings, struc-
cessor has developed a vehicle/powered equip- tures, walkways, etc.). The processor has:
ment safety program for all powered vehicles/ • Documented an evaluation of structural
equipment used on-site. This includes: safety of roads, bridges, operating locations
• Documented pre-use inspections and proce- and support locations, buildings, dormito-
dure to remove vehicles/powered equipment ries, etc. owned or operated by the proces-
from service that need repairs identified in sor;
the pre-use inspections; • Implemented a program for documented
• Requirement to use seat belts; on-going inspections of conditions or events
• Prohibition on use of cell phones while oper- that may impact structural integrity or safety
ating vehicles/powered equipment; of the operations/site;

• Presence of backup alarms, fire extinguisher • Taken corrective actions for identified defi-
and other warning systems (e.g., forward/ ciencies.
rear projecting lights);
• Protection of drivers from overhead 19. Walking/Working Surfaces: The processor:
falling objects; • Implements an inspection and corrective
• A requirement that only employees and action program for ladders, stairs, railings,
contractors specifically trained in a particular platforms and walkways;
vehicle/powered equipment use/operation • Removes damaged equipment from service
are allowed to operate such vehicles/pow- until repairs are complete or replacements
ered equipment. are placed into service;
• Evaluates and marks working surface load
16. Hand Tool Safety. The processor: capacities especially for elevated/suspended
• Maintains hand tools in good condition (han- surfaces like mezzanines, attics, platforms
dles stable, no damage or cracks, etc.); and catwalks;

• Maintains electrical tools in good condition • Maintains walkways and work areas free of
(cords, guards in place, etc. not damaged); slip and trip hazards and obstacles.

• Maintains electrical tool accessories in good


condition (blades, wheels, disks, bits, etc., 20. Materials Handling Safety. The processor has
not damaged); implemented a program for material handling
• Conducts ongoing documented inspections safety that includes operation, documented
and monitoring of hand tool condition. inspections and maintenance of:
• Hoists/cranes;

17. Confined Space Safety. The processor has: • Slings/straps;

• Identified and maintains a documented • Storage racks.


inventory of confined spaces and
related hazards;
• Labeled confined spaces in the appropriate
language(s) for the work force;
• Formally developed and documented con-
fined space entry requirements;
• PPE available appropriate for confined space
entry and rescue;
• Implements monitoring and rescue provi-
sions;
• Conducts periodic inspection of signage and
changes in confined spaces.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 15
21. Chemical Safety. The processor has imple- 23. First aid. The processor:
mented a documented program for chemical • Has basic first aid capabilities, equipment
safety that includes: and supplies;
• Maintaining an updated inventory of chem- • Documents regular inspections, tests and
icals used in all buildings and areas of the refills of first aid equipment and supplies;
operation, including a baseline against which
it measures reductions; • Provides basic first aid training for employ-
ees.
• Availability of chemical safety information in
the language(s) of the workers;
• Employee training as appropriate to their 24. Employee Safety Training. The processor has
function in the workplace; developed and implemented a documented
safety training program that:
• Identification and separation of incompatible
chemicals in the language(s) of the workers; • Includes general site safety and job-specific
requirements as appropriate to worker func-
• Container labeling in the appropriate lan- tion in the workplace;
guage(s) for the work force;
• Is given in the language(s) of the workers;
• Safe chemical dispensing/transfer/mixing
systems and procedures; • Requires periodic refresher training in the
appropriate language(s) for the workforce;
• Immediate safety response equipment as
appropriate to the risk (e.g., eye wash sta- • Ensures new employees are trained before
tions located in areas where chemical han- being allowed to undertake any activities
dling could result in exposure to the face requiring training;
or skin); • Ensures that employees changing jobs are
• A documented chemical use reduction plan trained before being allowed to undertake
in relation to the baseline. any activities requiring training;
• Monitors or confirms the effectiveness of the
training with employee input as appropriate.
22. Working at Heights. The processor has imple-
mented a documented program for working
safely at heights that includes: 25. Worker Consultation and Participation. The
• Minimizing the distance and consequences processor has:
of a fall by using the right type of equipment • Established, implemented and maintained
where the hazard cannot be eliminated; processes for the consultation and partici-
• Ensuring equipment is suitable, stable and pation of non-managerial employees in the
appropriate for the job; development, implementation, performance,
evaluation and improvement of the OHS
• Conducted and documented engineering management system.
analyses for fall protection/prevention equip-
ment tie-off points;
• Periodic documented inspections of fall pro- 26. Safety/Warning Signs (equipment, electrical,
tection/prevention equipment for damage, pedestrian walkways, vehicular traffic, chemi-
correct use and expiration; cal storage/use, PPE requirements, emergency
egress, safety/emergency equipment, etc.).
• Providing protection from falling objects;
The processor has safety and warning signage/
• Preventing the storage of hazardous materi- labels throughout the site. The signs/labels are:
als on rooftops. • In the language(s) of the workers;
• Legible;
• Maintained in good condition;
• Up to date.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 16
27. Lighting. The processor maintains adequate 31. Sanitary living and Working Conditions. The
lighting in work areas and ensures that lighting processor maintains:
changes are made in conjunction with changes • Sanitary housekeeping and provides clean
in uses of work areas where appropriate. drinking water and restroom facilities;
• Sanitary conditions for canteens, cafeterias,
28. Temperature Exposure. The processor: creche facilities, dormitories or any other
• Has documented temperature exposure relevant worker support facilities;
hazards to workers appropriate to their jobs • Separate restroom facilities for men and
(heat and cold); women. Gender neutral facilities are accept-
• Makes appropriate PPE, coats, gloves, drink- able as well;
ing water and/or shade readily available at • Adequate ventilation in all processing areas,
no cost to the employee; offices, canteens, restrooms, dormitories and
• Developed and implements work instructions other enclosed areas;
to manage employee temperature exposure. • Dormitories/accommodation areas separate
from areas used for operations, production
and materials/chemical storage;
29. Incident Reporting and Management. The pro-
cessor: • Inspections of these areas to ensure sanitary/
hygienic conditions are maintained.
• Has a documented formal incident reporting
procedure that includes actual incidents and
near misses; 32. Disease Prevention and Management. The pro-
• Supports interdepartmental communications cessor has developed and implemented a pro-
to further identify and understand incidents cedure to prevent the introduction and spread
and near misses; of transmissible diseases, including HIV/AIDS,
tuberculosis, malaria, and emerging infectious
• Encourages employees to report all incidents diseases in the workplace that includes:
and does not create an environment where
employees are disincentivized to report inci- • Employee, contractor and visitor training
dents or near misses; as appropriate to their function in the work-
place;
• Conducts formal reviews and investigations
on reported incidents; • Providing appropriate PPE and washing/dis-
infection facilities to workers and visitors to
• Has a return-to-work program for injured prevent introduction and spread of transmis-
employees that may include restricted duty sible diseases in the workplace.
until recovery is complete and the employee
receives medical clearance to return to their
original duties;
• Allows personnel to remove themselves
from imminent serious danger without seek-
ing permission from the organization.

30. Ergonomics. The processor has:


• Conducted an ergonomic assessment of
workplace jobs, tasks and activities;
• Implemented improvements/corrective
actions identified in the ergonomic assess-
ment.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 17
VII. SOCIAL STANDARDS
1. Legal Compliance. The processor has identified • Established, documented, maintained and
the legal compliance requirements related to effectively communicated to personnel and
labor, worker and human rights, and operates in other interested parties, written policies and
accordance with those requirements, such as: procedures for remediation of child laborers,
• Identified all applicable worker registration and provides adequate financial and other
requirements at the national, regional, state support to enable such children to attend and
and local levels; remain in school;

• Obtained all applicable authorizations; • Procedures in place where young workers


are subject to compulsory education laws,
• Maintained adequate documentation to they work only outside of school hours;
demonstrate on-going compliance with
all applicable authorizations and ◦ Under no circumstances shall any young
regulatory requirements; worker’s school, work and transportation
time exceed a combined total of 10 hours
• Maintained documentation concerning any per day, and in no case shall young work-
legal enforcement actions/lawsuits involving ers work more than 8 hours a day;
the processors and corrective actions/resolu-
tion of such actions; ◦ Young workers may not work during
night hours.

2. Stakeholder Engagement.
4. Forced/Bonded labor. The processor has imple-
The processor has carried out stakeholder map- mented a management system that prevents
ping that is regularly updated, implemented an the use of any forms of forced labor and partic-
engagement plan, and established a grievance ipation in acts of human trafficking in line with
mechanism stakeholders have access to. ILO Conventions No. 29 and No. 105, including:
• Putting into place a documented policy
3. Child Labor. The processor has: prohibiting forced, bonded (including debt
bondage) or indentured labor; involuntary or
• A documented policy banning the use of
exploitative prison labor; slavery or human
child labor, including the Worst Forms of
trafficking of persons in recruiting and
Child Labor;
employment practices and implemented a
• Implemented the more stringent of either: management system to this effect;
(a) national, subnational or local legal • Workers must not be required to pay
requirements for child and juvenile/adoles- employers’, agents’ or sub-agents’ recruit-
cent labor;or ment fees or other related fees for their
(b) a management system that prevents the employment. If any such fees are found to
employment of children under the age of have been paid by workers, such fees must
15, unless the exceptions recognized by be repaid to the worker;
the ILO apply, prevents the worst forms of • Contract terms related to employment are
child labor, and prevents the exposure of provided in writing in the employee’s
employees under the age of 18 to native language;
hazardous work in line with ILO
• Workers must be provided a copy of their
Conventions No. 138 and No. 182;
contract prior to leaving their country
of origin;
• No substitution or change(s) shall be
allowed in the employment agreement upon
arrival in the receiving country unless these
changes are made to meet local law and pro-
vide equal or better terms;

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 18
• All work must be voluntary, and workers • Ensures that workers are not charged fees for
must be free to leave work at any time or food, clothing, transportation, health checks,
terminate their employment without penalty work documentation and/or supplies as part
if reasonable notice is given as per of their recruitment.
worker’s contract;
• Government issued identification and per- 8. Subcontracting. The processor:
sonal documentation originals are not held
by the employer/labor agent/contractor; • Has developed and implements a policy to
monitor subcontractors where it is a
• Employers can only hold documentation if client requirement;
such holdings are required by law. In this
case, at no time should workers be denied • Has informed its client when manufacturing is
access to their documents; not taking place at his own site;
• There are no unreasonable restrictions on • Ensures his subcontractors have the legal
the movement of workers and the access to right to work;
basic liberties. • Ensures there is no substantial evidence of
forced / bonded / trafficked / prison labor at
subcontractor level;
5. Entitlement to work. The processor:
• Ensures there is no substantial evidence of
• Ensures all workers have the right to work; child / underage labor at subcontractor level.
• Has developed and implements policies to
monitor if all workers have the right to work;
9. Freedom of Association and Collective
• Keeps a record of documentation on legal Bargaining. The processor:
right to work.
• Has a documented policy concerning
employees’ rights to freedom of association
6. Hiring. The processor: and to collective bargaining;
• Ensures that all workers are provided with • Respects employees’ rights to freedom of
a written employment agreement in their association and to collective bargaining in
native language that contains a description line with ILO Conventions No. 87 and No. 98,
of terms and conditions of employment. participates in collective bargaining pro-
Foreign migrant workers must receive the cesses in good faith and does not obstruct
employment agreement prior to the worker alternative means of association where there
departing from his or her country of ori- are legal restrictions;
gin and there shall be no substitution or • In the absence of formal collective bargain-
change(s) allowed in the employment agree- ing, worker committees must be permitted to
ment upon arrival in the receiving country discuss workplace issues;
unless these changes are made to meet local
law and provide equal or better terms. ◦ Where national law restricts workers’
organizations, we do not obstruct workers
from developing alternative mechanisms
7. Use of Labor Providers/Agencies. The proces- that are allowed under applicable law;
sor: • Ensures union members, representatives
• Uses only registered/authorized labor provid- of workers and any personnel engaged in
ers/agencies; organizing workers are not subjected to
• Has systems to monitor labor providers/agen- discrimination, harassment, intimidation or
cies; retaliation for being union members, repre-
sentative(s) of workers or engaged in orga-
• Ensures no fees charged to workers by the nizing workers, and that such representatives
providers/agencies exceed legal limits; have access to their members in
• Ensures that workers do not pay deposits to the workplace.
providers/agencies;

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 19
10. Worker Consultation, Participation and 12. Harassment: The processor:
Grievances. The processor: • Prevents and addresses all forms of harass-
• Ensures an anonymous, free, unrestricted, ment in the workplace in line with ILO
unbiased, non-retaliatory and safe channel Conventions No. 100 and No. 111, including
for workers to report complaints about for example (this list is not exhaustive):
the workplace; ◦ Sexual harassment/abuse,
• Has procedures in place for investigating, fol- ◦ Corporal punishment,
lowing up and communicating the outcome
of such complaints; ◦ Mental or physical coercion
• Has processes in place to actively seek con- ◦ Verbal abuse
sultation and participation from its employ- ◦ Discrimination in hiring
ees in respect to the working conditions and
◦ Remuneration,
follow-up on their suggestions for continu-
ous improvement. ◦ Access to training, promotion, termination
or retirement;
• Maintains records of worker reports of
11. Discrimination. The processor:
harassment, disciplinary actions, associated
• Has a documented policy banning discrim- investigations and corrective actions;
ination of workers as defined in the ILO
• Provides training to employees on harass-
Convention 111:
ment.
• Ensures personnel are not subject to preg-
nancy or virginity tests under any circum-
stances; 13. Lay-off. The processor:
• Has implemented a management • Ensures any employee who has been in a
system that, in all aspects of its continuous service for a year should not be
employment, ensures processor laid off until he has been given a month’s
identifies and prevents discrimination notice in writing, indicating reasons, unless
based on: he has been paid wages for the period, in
lieu of such notice;
◦ Race, national or territorial or social ori-
gin, • Ensures that, in an ordinary lay-off, the last
person to be employed in a category of
◦ Caste,
worker is laid-off first. If not so, the employer
◦ Birth, records the reasons for the same;
◦ Religion, • Ensures that, in case of closing of a factory
◦ Disability, due to economic bankruptcy, an alternative
employment needs to be arranged with same
◦ Gender, remuneration on same terms and conditions,
◦ Sexual orientation, if notice or compensation isn’t provided.
◦ Family responsibilities,
◦ Marital status,
◦ Union membership,
◦ Political opinions,
◦ Age or
◦ Any other condition that could give rise to
discrimination;
• Maintains records of worker reports of dis-
crimination, disciplinary actions, associated
investigations and corrective actions;
• Provides training to employees on discrimi-
nation.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 20
14. Gender Equality. The processor: minimum wage and meet the appropriate
industry wage (if higher) and exceed a local
• Has a documented policy concerning gender fair wage, with a plan to identify and where
equality in the workplace; and possible implement the living wage;
• Has implemented a management system and
continually assesses and monitors gender
equality in the workplace.

15. Working Hours. The processor:


• Keeps workers’ total regular and overtime
working hours to a maximum of 60 hours
per week as defined in ILO Convention
C001 and without prejudice to the
exceptions set out thereunder:
• Only exceeds this limit of hours if
permitted by applicable national legislation
or collective bargaining agreements
provided that they are in line with
exceptions defined by the ILO;
• Has a documented policy concerning work-
ing hours, overtime and annual and man-
dated leave;
• Ensures overtime is voluntary;
• Provides annual and sick leave in compliance
with local laws;
• Maintains records of employee work hours,
overtime and annual and mandated leave in
compliance with local laws;
• Ensures that, when overtime work is needed
in order to meet short-term business
demand, such overtime work is managed in
accordance with a freely negotiated collec-
tive bargaining agreement representing a
significant portion of its workforce.
• Makes reasonable accommodation
for worker religious practices.

16. Remuneration/Compensation. The processor:


• Has a documented policy concerning mini-
mum wages, overtime, severance
and benefits;
• Does not engage in labor practices that
reduce workers’ wages or benefits or result
in employment situations such as labor-only
contracting arrangements, consecutive short-
term contracts, use of temporary workers for
more than six months and/or false appren-
ticeship or similar schemes that avoid a
country’s labor and social security require-
ments;
• Pays wages that equal or exceed the national
© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 21
• Pays appropriate overtime/nightshift wages, grievances anon- ymously;
paid leave (including maternity leave),
social security, compensation for
injuries/death, and provides other
benefits such as those related to years of
service, seniority, perfor- mance, etc.;
• Does not deduct or reduce wages for
disci- plinary purposes;
• Pays government or regulatory
deductions on time;
• Does not make deductions from worker pay
for staying employed;
• Ensures workers are not required to sign
up for accommodation rental exceeding
period of employment or require excessive
depos- its with financial penalties for
leaving early employment or
accommodation;
• Provides pay slips to workers in a
language they understand and to include
a detailed account of all deductions;
• Maintains records of timely payment of
wages, severance and benefits to workers;
• Ensures wages are paid only to the
employee, including bank accounts con-
trolled by the employee;
• Ensures none of worker pay is withheld
for any reason that is not allowed by law
or union/collective bargaining
agreement;
• Ensures that workers are not required to
pay deposits to access their documents or
take vacation/leave;
• Does not charge rents for accommodation
that are in excess of local
norms/market conditions;
• Only maintains one set of books/records
that accurately reflect worker
compensation.

17. Grievance mechanism. The processor has:


• A grievance mechanism accessible to
all employees, other affected parties,
and the public;
• A “no retaliation” policy that prohibits
disci- plining, dismissing or otherwise
discriminat- ing against any personnel or
interested party for providing information
on this standard compliance or for making
other workplace complaints; whistleblower
protections, including ability to submit

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 22
• Procedures for investigating, providing • Evaluates general social practices and
remedy for, and communicating the outcome human rights risks, as well as occupational
of, complaints concerning the workplace or health and safety (OHS) conditions at the
of its implementation of policies and proce- mine site including basic mine safety rules,
dures outlined in this standard; job hazard evaluations and appropriate
◦ These results are freely available to all personal protective equipment is provided to
personnel and, upon request, to relevant, and used by miners, in cases where proces-
interested parties; sor is sourcing from ASM.

• The grievance mechanism may be provided


by the company directly or through collabo- 21. Human Rights. The processor:
rative arrangements with other companies or • Has a documented policy concerning
organizations or affected communities, or by respecting human rights;
facilitating recourse to an external expert or
body (i.e., ombudsman) or industry associa- • Fully implements the UN Guiding Principles
tion. on Business and Human Rights including
human rights impact assessment and due
diligence; and
18. Community Health and Safety. The processor
monitors, avoids, minimizes, reduces and pro-
vides remedies for adverse impacts on commu- 22. Security and Human Rights. The processor:
nity health and safety beyond the fence line of • Has a documented policy concerning phys-
the facility by: ical workplace security and its impact on
• Collaborating with relevant community worker human rights;
members and other stakeholders, including • Implements the Voluntary Principles on
workers who live in affected communities; Security and Human Rights (VP on SHR)
• Considering that input in scoping community when engaging with private or public secu-
health and safety risks and impacts; rity forces; and
• Monitors for adverse impacts on community • Continually assesses and monitors human
health and safety beyond the fence line of rights conformance in the workplace.
the facility;
• Where reasonable, undertakes activities 23. Indigenous Peoples’ Rights and Ethnic
to avoid, reduce and provide remedies for Minorities Rights. The processor:
adverse impacts on community health and
• Has a documented policy concerning indig-
safety beyond the fence line of the facility.
enous people’s right and Free Prior and
Informed Consent;
19. Community Development. • Respects the rights of Indigenous Peoples,
The processor has identified community needs including FPIC (free prior and informed con-
in consultation with affected communities, sent);
developed a plan, and committed resources to • Respects the rights of ethnic minorities;
support community development.
• Avoids adverse impacts on Indigenous
Peoples’ lands, livelihoods, resources, and
20. Artisanal and Small-Scale Mining. cultural heritage;
The processor: • Maintains a buffer area between its opera-
• Engages artisanal and small-scale miners tions and any indigenous peoples’ lands for
(ASM) and facilitates their formalization and settlements; and
improvement of their social and environ- • Has developed and implemented an
mental practices, in cases where processor is Indigenous Peoples’ engagement plan.
sourcing from ASM;

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 23
24. Land Acquisition and Resettlement. The proces-
sor:
• Implemented policy to avoid and/or minimize
land acquisition and resettlement, and its
projects’ design has been optimized to mini-
mize land acquisition and avoid resettlement;
• Explores alternative project designs to avoid
and/or minimize land acquisition and physi-
cal or economic displacement;
• Where land acquisition or resettlement is
necessary, the processor implements a
resettlement action plan to fairly address and
compensate for residual adverse impacts, in
consultation with impacted stakeholders.

25. Cultural Heritage. The processor:


• Has a documented policy concerning cultural
heritage sites;
• Has identified cultural heritage sites in the
area of the processors; and
• Based on consultation with stakeholders,
avoids, minimizes, reduces and compensates
for adverse impacts on cultural heritage.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 24
VIII. GOVERNANCE STANDARDS
1. Legal Compliance. For all criteria included in the policies;
this standard, the processor has: • A process to ensure personnel with responsi-
• Identified the legal compliance requirements bilities for policy/procedure implementation
related to operating the business, and oper- have/maintain relevant training and educa-
ates in accordance with those requirements, tion related to their duties;
including avoiding doing business with • A process or system for control of documen-
sanctioned entities and ensuring payment tation relevant to ESG related activities, in
of taxes; paper or electronic form at a level of detail
• Obtained all applicable authorizations; necessary and sufficient to describe the ele-
ments of this standard.
• Maintained documentation to demonstrate
on-going compliance with all applicable
authorizations and regulatory requirements;
• Addressed and documented non-compliance
situations through corrective actions and
determination of effectiveness;
• Maintained documentation concerning any
legal enforcement actions/lawsuits involving
the processors and corrective actions/resolu-
tion of such actions;
• Fundamental to adopting the ESG standard
is the understanding that a business, in all
of its activities, must operate in full
compliance with the laws, rules, and
regulations of the countries in which it
operates. The ESG standard also
encourages processors to go beyond legal
compliance, drawing upon internationally
recognized standards, in order to advance
social and environmental responsibility and
business ethics. If there are differing
standards between this ESG standard and
local law, the processor shall meet the
requirements that provide the highest
protection to human rights and the
environment, while remaining within the
legal boundaries of the country. In
alignment with the UN Guiding Principles
on Business and Human Rights, the
provisions in this standard are derived
from and respect internationally
recognized standards.
2. Processor Policies and Procedures/Document
Management. The processor has:
• Developed, communicated and enforced
documented policies on the processor’s
expectations and requirements for environ-
mental management, occupational health
and safety, social responsibility and corpo-
rate governance;
• Operating procedures in place to support

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 25
3. Business Integrity. The processor prohibits
and prevents bribery (including facilitation
pay- ments), corruption, money laundering,
conflict financing and anti-competitive
behavior. This includes processes and
procedures
that address:
• Formally establishing responsibility for busi-
ness ethics management to someone in
the company;
• Employee, contractor and visitor training
as appropriate to their function in the
work- place;
• Fraud and collusion identification and man-
agement systems;
• Giving, offering or accepting gifts; offers
of employment, contracts, favors or anything
of value, whether directly or indirectly
through third parties or family members;
• Internal employee whistleblower process;
• Whistleblower protections;
• Ongoing monitoring and enforcement;
• Misuse and security of confidential data.

4. Business Relationships. The processor pro-


motes responsible business practices with sig-
nificant business partners, including
suppliers. This includes:
• Conducting due diligence on business part-
ners;
• Assuring suppliers and critical vendors
are in alignment with processor
environmental, health and safety
requirements, throughout the
procurement process;
• Assessing potential new business relation-
ships;
• Periodically reviewing existing relationships
to evaluate changes.
Where the processor receives, handles or pro-
motes goods and/or services from suppliers/
subcontractors or sub-suppliers who are clas-
sified as home workers, the processor ensures
that such home workers are afforded a level of
protection substantially equivalent to
other workers.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 26
5. Employee Incentives/Rewards. • When undertaking corrective actions, has
Employees are not incentivized or pressured identified specific mitigation actions to be
to perform their duties in a manner that con- carried out to address negative environmen-
travenes the company policy and operating tal and social impacts highlighted during
standards. They are routinely and continuously environmental and social impact assess-
encouraged to report injuries/incidents and their ments;
concerns about company operations, perfor- • Made resources available for such investi-
mance, activities or personnel. gations, corrective/preventive actions and
implementation, and maintains records
of the results, monitoring effectiveness of
6. Grievance Mechanism. The processor has: efforts undertaken to mitigate negative social
• Established a grievance mechanism, which is and environmental impact;
being fully implemented and in line with the • Assigned personnel responsible for imple-
UN Guiding Principles’ Effectiveness Criteria mentation of various elements the environ-
for Non-Judicial Grievance Mechanisms; mental and social management plan;
• Ensured that stakeholders, including affected • Updated and revised overall environmental
community members, as well as employees, and social management plan based on moni-
and whistleblowers, have access to an oper- toring results or other additional information;
ational-level mechanism that allows them to
raise and seek resolution or remedy for the • Disciplinary policies communicated and
range of complaints and grievances that may procedures in place for staff, contractor and
occur in relation to the company, its process- supplier nonconformance to legal or
ing-related activities, and other operations in contract requirements;
scope of this standard. Complainants shall • A process of monitoring disciplinary actions
have the ability to file grievances anony- taken against staff, contractors and suppliers;
mously.

8. Internal Monitoring Programs.


7. Management Responsibility and Accountability. The processor implements on-going monitor-
The processor has: ing processes for its ESG matters, which at a
• Established formal documented manage- minimum, identifies social and environmen-
ment responsibility and accountability for tal impacts throughout the life of the mineral
implementation of due diligence, safety, processing operation. This may include internal
social and environmental management, audits/assessments against all relevant ESG
including an environmental and social man- requirements, management system certification
agement plan; reviews, automated information management
• Demonstrated management accountability systems/reporting/dashboard and internal whis-
and implementation through actions enforc- tleblower mechanisms. Audits or investigations
ing due diligence, safety, social and environ- done on behalf of other parties (such as custom-
mental management requirements; ers, insurers and governmental agencies) may
cover some ESG elements but may be limited in
• Made available training programs to workers their scope and use. Monitoring should always
on processor requirements, expectations and be designed and performed by competent indi-
effective implementation on safety, environ- viduals.
mental management, social matters, griev-
ance mechanisms and business ethics;
• Implemented processes for root cause inves-
tigations for complaints, grievances,
or incidents;

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 27
9. Stakeholder Consultation and Participation. 11. Performance Metrics and Improvement Goals.
The stakeholders in the processor’s operating The processor has reviewed and evaluated ESG
activities are invited to review and comment on performance metrics and goals for improve-
the following: ments/reductions to ensure that they are realis-
• Issues and impacts to be considered in the tic and/or reasonable.
proposed structure of an environmental and
social impact assessment;
12. Management/Executive Compensation
• Methodologies for the collection of environ- and Incentives.
mental and social baseline data;
The processor compensation and incentives for
• Findings of environmental and social stud- management/executive is consistent with its
ies relevant to conclusions and recommen- requirements on safety, social and environmen-
dations of the environmental and social tal management.
impact assessment;
• Options and proposals to mitigate negative
environmental and social impacts; 13. Board Structure, Makeup and
Member Selection.
• Provisional conclusions and recommenda-
tions of the environmental and social impact Where the processor has a Board of Directors,
assessment, prior to finalization; there is a formal documented set of procedures
concerning the Board structure and makeup
• Final conclusions and recommendations of to ensure the Board functions as an indepen-
the environmental and social impact assess- dent and objective entity to the extent practi-
ment. cal. Criteria for the selection and exclusion of
The processor shall provide for timely and Members should be formally documented
effective stakeholder consultation, and facilitate and followed.
stakeholder participation, where possible, in the
implementation of the environmental and social
monitoring program. The processor shall record 14. Communication.
all stakeholder comments received in relation Processors must implement procedures for
to environmental and social impact assessment; communications, both internal and external, in
related findings, conclusions, and recommenda- support of its ESG commitments and manage-
tions; and the environmental and social moni- ment system. When determining what com-
toring program. The company shall record how munications are required, processors should
it responds to stakeholder comments. consider what will be communicated, when and
how it will be communicated, and with whom it
will be communicated.
10. Transparency and Disclosure.
As part of the corporate ESG management
The processor reports annually on environmen- system, all applicable communications must
tal, safety, social and governance performance follow established processes to ensure that
in line with internationally recognized standards compliance obligations are considered, met and
(e.g. GRI etc.) where practical or integrate that communicated. Furthermore, processors must
information into annual sustainability, corporate assure that relevant EHS information commu-
responsibility or due diligence reports where nicated to both internal and external interested
the processor publishes one. Annual reporting parties is consistent with its management sys-
shall be made publicly available and include tem and is reliable, and that records are main-
data and methodologies relevant to the moni- tained, as applicable.
toring program and social and environmental
impacts assessments. Regardless of the period-
icity of regular reporting, the environmental and
social management plan shall be made avail-
able to stakeholders on request. The processor
publicly supports the implementation of EITI,
and reports in line with the EITI, where required.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 28
IX. ANNEXES
ANNEX A: DEFINITION OF TERMS AND ACRONYMS

NOTE
Some terms are used in these criteria in both defined and general terms.

Artisanal or Artisanal and Small-Scale Mining (ASM): Formal or informal mining operations with predom-
inantly simplified forms of exploration, extraction, processing, and transportation. ASM is normally low
capital intensive and uses high labor-intensive technology.
Assessment/Audit: A formalized evaluation of an entity against criteria established independent of the
audited entity, typically resulting in a report containing specific findings. In this document, the term
“audit” is used specifically in the context of the OECD Guidance Step 4 or the ISO19011:2001 Standard. The
evaluation of a processor against the conformance criteria in this document is referred to as “assessment”.
Auditor/Audit firm: The individual/entity that carries out an assessment of a processor against the criteria
and produces an audit firm report.
Assessment period: The period of time covered by the assessment, typically one year.
Business confidentiality and other competitive concerns: Information regarding supplier relationships as
well as factors that may affect price or competition such as capacity, trading routes, mineral sources and
other information normally protected by competition/anti-trust law.
Company: A legal business entity with overall management responsibility of operations and administra-
tion of at least one processor. A processor can consist of a single facility and business processes (process-
ing) or multiple facilities and business processes (in addition to processing).
Criteria: The requirements of the standards against which an auditor evaluates companies to assess the
processor’s level of conformance in an assessment.
Critical Information: Any and all information related to the processor’s due diligence and that is necessary
for all parties involved, specifically employees and suppliers, to effectively carry out the tasks and respon-
sibilities assigned to them as part of the processor’s due diligence.
Facility: A singular location of a processor.
Hazardous Work: Work which exposes children to physical, psychological or sexual abuse; work under-
ground, underwater, at dangerous heights or in confined spaces; work with dangerous machinery, equip-
ment and tools or carrying heavy loads; exposure to hazardous substances, agents or processes, or to
temperatures, noise levels or vibrations damaging to health; work for long hours, night work, and unrea-
sonable confinement to the premises of the employer.
ISO 14001:2015: International Organization for Standardization specification that documents the require-
ments for an environmental management system that an organization can use to enhance its envi-
ronmental performance. ISO 14001:2015 is intended for use by an organization seeking to manage its
environmental responsibilities in a systematic manner that contributes to the environmental pillar
of sustainability.
ISO 45001:2015: International Organization for Standardization specification that documents requirements
for an occupational health and safety (OH&S) management system, and gives guidance for its use, to
enable organizations to provide safe and healthy workplaces by preventing work-related injury and ill
health, as well as by proactively improving its OH&S performance.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 29
ISO 19011:2018: International Organization for Standardization guidelines for auditing management system
provides guidance on auditing management systems, including the principles of auditing, managing an
audit program and conducting management system audits, as well as guidance on the evaluation of com-
petence of individuals involved in the audit process, including the person managing the audit program,
auditors and audit teams.
Large Scale Mining (LSM): All formal operations characterized by substantial capital, heavy equipment,
high technology and a significant workforce (large and medium in size) not meeting the ASM definition.
Local Fair Wage: Remuneration which is regularly & formally paid in full to workers that respects the min-
imum wage regulations and applicable standard of living norms (food, water, housing, education, health
care, transportation, clothing, and other essential needs including provision for unexpected events) and
which progresses at least in proportion to conditions such as living conditions, regional/local economic
setting, employer profits or with changes in intensity at work or evolving skills or tasks.
Material(s): Any mineral-containing products or secondary materials.
Mineral: Naturally-occurring inorganic compounds that are extracted from a mine.
Mobile emissions sources: Sources of fuel combustion emissions that are not fixed in place or stationary.
Examples include cars, trucks, fork trucks, buses, generators, farm and construction machines, lawn and
garden equipment, marine engines and locomotives.
Processor: An entity that receives material (which includes primary, intermediate and/or secondary mate-
rials) and produces refined, smelted, treated, transformed, purified, or cleaned mineral or metal products
for use in a downstream manufacturing and other midstream or downstream processes. This includes
processors co-located with mines and stand-alone operations. Processor definition for the purposes of this
standard includes, but is not limited to, smelters, refiners (fine and crude), processors, treatment units,
transformation operations, toll millers, aggregators, and recyclers.
RMAP: Responsible Minerals Assurance Process, the processor assessment program under the RMI.
RMI: Responsible Mica Initiative.
Secondary: Materials commonly referred to as recycle/scrap. This includes recycled minerals which are
scrap processed minerals created during product manufacturing including: excess, defective, and scrap
mineral materials which contain processed minerals that are appropriate to recycle. It also includes
post-consumer or end-of-life materials from which minerals can be reclaimed. Minerals partially pro-
cessed, unprocessed, or byproducts from another mineral are not recycled or secondary materials.
Waste Hierarchy: A method of ranking waste management strategies from most to least environmentally
preferred in the following order:
• Product/process design to prevent waste generation
• Source reduction and reuse
• Recycling
• Energy recovery – conversion of non-recyclable waste materials into useable heat, electricity or fuel
through a variety of processes
• Treatment and disposal

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 30
ANNEX B: EFFECTIVE DATE &
REVISION HISTORY
This revision of the document is in effect as of the
date identified on the cover page as the “Effective
Date.” All assessments utilizing these standards
must use the most current version of the standards,
which is identified by the “Publication Date” on the
cover page.
Revision History: Environmental, Social &
Governance (ESG) for Mineral Supply Chains
December 2020 – Draft released to members and
stakeholders for comment.
January - February 2021 –
60-day Public Consultation.
June 3, 2021 – Final ESG Standard Issued.

© 2021 Responsible Business Alliance and Responsible Minerals Initiative. All Rights Reserved. 31

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