RBA - Risk Readiness Assessment Tool - SMELTER

8/5/2020 RBA - Risk Readiness Assessment Tool
RRA Questions
Governance
Legal Compliance
Industry Norm :
To implement a management system that ensures compliance with all national legal
requirements, including national obligations under international law.
Does Not Meet

Currently we have no formal system in place, documentation, or a member of staff with
responsibility to understand, monitor and ensure our compliance with national legal
requirements in our country of operation.
Partially Meets
We are fully compliant with all national legal requirements.
Fully Meets
We are fully compliant with all national legal requirements and with international
conventions and law where these are required nationally.
Business Integrity
Industry Norm :
To implement a management system that prohibits and effectively prevents bribery
(including facilitation payments), corruption and anti-competitive behavior.
Does Not Meet

We have not implemented a management system or process that prevents bribery,
corruption and anti-competitive behavior.
Partially Meets
We have begun implementation of a management system or process to prevent bribery
(including facilitation payments), corruption and anti-competitive behavior, but it is
incomplete and/or not (yet) fully implemented.
Fully Meets
https://app.riskreadiness.org/Document/DownloadRraQuestions?type=SME 1/19
We have in place a documented management system or process that effectively

prevents bribery (including facilitation payments), corruption and anti-competitive
behavior.
Exceeds
1. Formally participate in a national or international recognized initiative for the
combatting of bribery, corruption or anti-competitive behavior.
2. Comply with guidelines of an international convention or framework on the prevention
of bribery, corruption or anti-competitive behavior.
3. Disclose payments to national governments and significant business
partners/operations in countries considered to be at high risk of corruption, bribery or
anti-competitive behavior.
Stakeholder Engagement
Industry Norm :
To carry out stakeholder mapping, and to implement an engagement plan, and to
establish a grievance mechanism.
Does Not Meet

We have not developed a public or documented stakeholder map, engagement plan or
established a grievance mechanism.
Partially Meets
We have begun to develop and maintain a stakeholder map and engagement plan, and
to establish a grievance mechanism, but it is incomplete and/or not (yet) fully
implemented.
Fully Meets
We have developed a documented stakeholder map, engagement plan and established
grievance mechanism, which are being fully implemented.
Exceeds
1. Maintenance of a mechanism to have continually informed consultation and
participation of stakeholders in key decisions and activities throughout the project
lifecycle.
2. Establishment of a formal stakeholder committee/panel (that includes local, national
and international representatives) that meets at least annually to review the
environmental, social and governance performance of the site / facility, and which
publishes a report of their findings and recommendations for improvements at the site /
facility.
Business Relationships
Industry Norm :
To promote responsible business practices with significant business partners, including
suppliers.
Does Not Meet

We have no communication or direct engagement with significant business partners to
promote responsible business practices.
Partially Meets
We have begun to communicate with and/or directly engage some business partners to
promote responsible business practices, but we do not currently communicate with
and/or engage all our significant business partners.
Fully Meets
We communicate with and/or directly engage all our significant business partners to
promote responsible business practices.
Exceeds
1. Implementation of a comprehensive business-partner engagement policy/process
that meets prevailing industry best practices.
2. We monitor sustainability performance of our business partners on a regular basis.
Labor and Working Conditions

Child Labor
Industry Norm :
To implement a management system that prevents the employment of children under
the age of 15, prevents the worst forms of child labor, and prevents the exposure of
employees under the age of 18 to hazardous work in line with ILO Conventions No. 138
and No. 182.
Does Not Meet

We do not have in place policies, procedures or practices (a management system) that
i t th l t f hild d th f 15 d th f
ensure against the employment of children under the age of 15 and the exposure of
employees under 18 to hazardous work.
Partially Meets
We have begun to develop policies, procedures and practices (a management system)
that ensure against the employment of children under the age of 15 and the exposure of
employees under 18 to hazardous work, but implementation has not started or is
incomplete.
Fully Meets
We have in place policies, procedures and practices (a management system) that ensure
against the employment of children under the age of 15 and to the exposure of
employees under 18 to hazardous work.
Exceeds
1. Active influencing of contractors, consultants and suppliers to apply the standards in
ILO Conventions 138 and 182 at their operations.
2. Active support for (especially 'at risk') children in zone of influence.
Forced Labor
Industry Norm :
To implement a management system that prevents the use of any forms of forced labor
and participation in acts of human trafficking in line with ILO Conventions No. 29 and
No. 105.
Does Not Meet

We do not have in place policies, procedures or practices (a management system) that
ensures against the use of any forms of forced labor and against participation in acts of
human trafficking.
Partially Meets
that ensure against the use of any forms of forced labor and against participation in
acts of human trafficking, but implementation has not started or is incomplete.
Fully Meets
We have in place policies, procedures and practices (a management system) that
assures we do not use any forms of forced labor or participate in the acts of human
trafficking.
Exceeds
Freedom of Association and Collective Bargaining
Industry Norm :
To respect employees’ rights to freedom of association and to collective bargaining in
line with ILO Conventions No. 87 and No. 98, participate in collective bargaining
processes in good faith and not obstruct alternative means of association where there
are legal restrictions.
Does Not Meet

We do not have in place policies, procedures or practices (a management system) to
respect employee rights to freedom of association and collective bargaining.
Partially Meets
We have begun to develop policies, procedures and practices (a management system) to
respect employee rights to freedom of association and collective bargaining, but
implementation has not started or is incomplete.
Fully Meets
we respect employee rights to freedom of association and to collective bargaining.
Where national law restricts workers’ organizations, we do not restrict workers from
developing alternative mechanisms.
Exceeds
Discrimination And Harassment
Industry Norm :
To prevent and address all forms of harassment and discrimination in the workplace in
line with ILO Conventions No. 100 and No. 111.
Does Not Meet

We do not have in place policies, procedures or practices (a management system) to
prevent discrimination in all aspects of our employment practices including recruitment,
hiring, compensation, benefits, work assignments, access to training, advancement,
discipline, termination or retirement.
Partially Meets
We have begun to develop policies, procedures and practices ( a management system)

to prevent discrimination in all aspects of our employment practices including
recruitment, hiring, compensation, benefits, work assignments, access to training,
advancement, discipline, termination or retirement, but implementation has not started
or is incomplete.
Fully Meets
we prevent discrimination in all aspects of our employment practices including
recruitment, hiring, compensation, benefits, work assignments, access to training,
advancement, discipline, termination or retirement.
Exceeds
Gender Equality
Industry Norm :
To continually assess and monitor progress to ensure the implementation of a policy on
gender equality in the workplace.
Does Not Meet

We do not have a public or documented policies on gender equality.
Partially Meets
on gender equality, but implementation has not started or is incomplete.
Fully Meets
We have in place public policies, procedures and practices (a management system) on
gender equality and continually monitor our progress on its implementation to address
gender inequality in the workplace.
Exceeds
1. Set and met targets for female employment at all levels of the organization and equal
pay; positive progression towards the target is demonstrated.
2. Female positions in senior and line management exceed industry average.
Working Hours
Industry Norm :
To keep employees' total regular and overtime working hours to 60 hours per week
unless defined otherwise by applicable law or a collective bargaining agreement; and to

ensure overtime is voluntary, provide one rest day in seven; and, provide annual leave.
Does Not Meet

We do not have in place policies, procedures or practices (management systems) to
keep employees' regular and overtime working hours within legally required limits / not
more than eight hours in the day and forty-eight hours in the week.
Partially Meets
We have begun developing policies, procedures and practices (management systems) to
keep employees' regular and overtime working hours within legally required limits / not
more than eight hours in the day and forty-eight hours in the week, but implementation
has not started or is incomplete.
Fully Meets
We have in place policies, procedures and practices (a management system) to keep
employees' regular and overtime working hours within legally required limits / not more
than eight hours in the day and forty-eight hours in the week.
Exceeds
ILO Convention 1 at their operations.
Remuneration
Industry Norm :
To pay wages that equal or exceed the national minimum wage, the appropriate industry
wage (if higher), or a living wage.
Does Not Meet

We do not have in place policies, procedures or practices (a management system) to pay
employees wages that equal or exceed national minimum wage or the appropriate
prevailing industry wage.
Partially Meets
We have begun implementing policies, procedures and practices (a management
system) to pay employees wages that equal or exceed national minimum wage or the
appropriate prevailing industry wage, but implementation has not started or is
incomplete.
Fully Meets
We have in place policies, procedures and practices (a management system) to pay

employees wages that equal or exceed national minimum wage or the appropriate
prevailing industry wage.
Exceeds
1. Active influencing of contractors, consultants and suppliers to pay wages that equal
or exceed national minimum wage or the appropriate prevailing industry wage,
whichever is higher to employees working at their operations.
2. In cooperation with employees, the development of a mechanism for determining and
achieving payment of living wages for employees.
Occupational Health and Safety
Industry Norm :
To implement an occupational health and safety management system that is in line with
internationally accepted best practice frameworks (e.g. OHSAS 18001 or ISO 45001).
Does Not Meet

We do not to conform with a recognized occupational, health and safety international
convention, standard or best practices guidance framework.
Partially Meets
We have begun to align our polices, procedures and practices (a management system)
with occupational, health and safety international convention, standard or guidance
framework, but implementation has not started or is incomplete.
Fully Meets
We conform with a recognized occupational, health and safety international convention,
standard or guidance framework.
Exceeds
1. Requirement for and monitoring of significant service providers and suppliers to
conform with a recognized international convention, standards or guidance frameworks
on occupational health and safety.
Employee Grievance Mechanism
Industry Norm :
To establish and implement a grievance mechanism accessible to all employees.
Does Not Meet

We have not established a grievance mechanism for employees.
Partially Meets
We have begun to develop a grievance mechanism for employees but implementation

has not yet started or is incomplete.
Fully Meets
We have implemented and maintain a grievance mechanism developed in consultation
with employees.
Environment
Environmental Risk Management
Industry Norm :
To implement an environmental management system (EMS) functionally equivalent to
an internationally recognized EMS standard (e.g. ISO 14001).
Does Not Meet

We do not have in place an environmental management system.
Partially Meets
We have begun to develop an environmental management system but implementation
has not yet started or is incomplete.
Fully Meets
We have fully implemented and maintain an environmental management system that
meets the requirements of, or is functionally equivalent to, an internationally recognized
EMS standard.
Greenhouse Gas (GHG) Emissions
Industry Norm :
To quantify, establish reduction targets for and disclose CO2 equivalent emissions in
line with established international reporting protocols (e.g. IPCC or GHG Protocol).
Does Not Meet

We do not quantify or disclose our CO2-e emissions.
Partially Meets
We have made a public and documented commitment to quantify and disclose (at least
Scope 1) our CO2-e emissions, but implementation has not yet started or is incomplete.
Fully Meets
We have published total (at least Scope 1) CO2-e emissions for the site / facility.
Exceeds
1. Absolute target set that requires a reduction in total CO2-e emissions in a future year
when compared to a base year.
2. Residual GHG emissions that have not been avoided are fully offset in Clean
Development Mechanism (CDM) or Reducing Emissions from Deforestation and Forest
Degradation (REDD+) projects, resulting in no net emissions of GHGs or a net positive
impact (if the offset exceeds the residual GHG emissions)
Energy Consumption
Industry Norm :
To implement and quantify energy efficiency improvements and increased use of
renewable energy to reduce total energy consumption and/or energy intensity.
Does Not Meet

We do not quantify our energy efficiency or consumption and we do not have in place
programs to improve efficiency or reduce energy consumption.
Partially Meets
We have publicly committed to quantify our energy efficiency and consumption and to
put in place programs to improve efficiency and reduce consumption, but
implementation has not yet started or is incomplete.
Fully Meets
We have in place programs to reduce energy consumption and improve energy
efficiency, and we publish, at least annually, quantitative performance data on energy
efficiency and energy consumption.
Fresh Water Management and Conservation
Industry Norm :
To conduct a comprehensive assessment of water-use impacts and risks in
collaboration with relevant stakeholders and to implement measures to ensure that
water consumption does not restrict availability/access for other water users or reduce
the range and populations of fauna and flora in the catchment area of the site / facility.
Does Not Meet

We have not implemented a water management system to minimize impacts on other
water users and on fauna and flora in the catchment area of our site / facility.
Partially Meets
We have begun to develop a water management system to minimize impacts on other
water users and on fauna and flora in the catchment area of our site /facility but
Fully Meets
We have implemented a water management system and / or other measures that
minimize consumption on other water users and on fauna and flora in the catchment
area of our site / facility
Exceeds
1. Absolute target set that requires for a year-by-year reduction in (a) total freshwater
abstracted and (b) fresh water consumed.
Waste Management
Industry Norm :
To implement a risk-based waste management system that includes a commitment to
the ‘waste hierarchy’ and is applicable to all waste types (hazardous, non-hazardous and
inert).
Does Not Meet

We have not implemented a waste management system.
Partially Meets
We have begun to develop a waste management system that includes a commitment to
the ‘waste hierarchy’ and is applicable to all waste types (hazardous, non-hazardous and
inert), but implementation has not yet started or is incomplete.
Fully Meets
We have implemented a waste management system that includes a commitment to the
‘waste hierarchy’ and is applicable to all waste types (hazardous, non-hazardous and
inert).
Exceeds
1. Absolute target set that requires for a year-by-year reduction in total hazardous waste
generated.
Pollution
Industry Norm :
To implement the mitigation hierarchy to avoid, minimize, reduce and compensate for
the adverse impacts of pollution on human health and the environment.
Does Not Meet

We have no policy that follows the mitigation hierarchy to avoid, minimize, reduce and
compensate for the impact of pollution on human health and the environment.
Partially Meets
We have a policy that follows the mitigation hierarchy to avoid, minimize, reduce and
compensate for the impact of pollution on human health and the environment, but
Fully Meets
We have implemented a policy that follows the mitigation hierarchy to avoid, minimize,
reduce and compensate for the impact of pollution on human health and the
environment.
Exceeds
1. Target set and met for year-by-year reduction in total pollutant releases to the
environment (air, water and land).
2. Material releases of pollutants to the environment (air, water and land) have been
eliminated.
Biodiversity and Protected Areas
Industry Norm :
To implement the mitigation hierarchy to avoid, minimize, reduce and compensate for
adverse impacts on biodiversity; to avoid adverse impacts to Critical Habitats or
Endangered Species; and to prevent operational activities in World Heritage sites or in
designated protected areas unless specifically and legally permitted.
Does Not Meet

We do not follow the mitigation hierarchy for the management of our impact on
biodiversity; nor do we avoid adverse impacts on Critical Habitats or Endangered
Species; nor do we disallow operational activities in designated protected areas unless
specifically and legally permitted.
Partially Meets
We have in place a policy, procedures and practices (a management system) to follow a

mitigation hierarchy for the management of our impact on biodiversity; to avoid adverse
impacts on Critical Habitats or Endangered Species; and, to disallow operational
activities in designated protected areas, but implementation has not yet started or is
incomplete.
Fully Meets
We actively use the mitigation hierarchy for the management of our impact on
biodiversity; and, we have published a statement, to confirm that a) our activities are not
causally related to adverse impacts to Critical Habitat or Endangered Species, and b) our
operation is not illegally operating in a protected area or its buffer zone.
Exceeds
1. A measurable outcome of no net loss of biodiversity at the operation.
2. A measurable outcome of a net gain of biodiversity at the operation.
Not Applicable
Not Applicable. Please explain in the comment box why the norm is not applicable to
your site / facility.
Community
Community Health and Safety
Industry Norm :
To implement a management system to monitor, avoid, minimize, reduce and
compensate for adverse impacts on community health and safety.
Does Not Meet

We have not implemented a policy to avoid, minimize, reduce and compensate for
adverse project-related impacts on community health and safety.
Partially Meets
We have begun to develop a policy, procedures and practices (a management system) to
avoid, minimize, reduce and compensate for adverse project-related impacts on
community health and safety, but implementation has not yet started or is incomplete.
Fully Meets
We have implemented a policy to avoid, minimize, reduce and compensate for adverse
project-related impacts on community health and safety.
Community Development
Industry Norm :
To identify community needs in consultation with affected communities, develop a plan,
and commit resources to support community development.
Does Not Meet

We have not assessed the needs of the community around our operation and no plans
have been developed to make contributions to or support development in affected
communities.
Partially Meets
We have assessed the needs of the community around our operation and have
developed a plan to make contributions to or support development in affected
communities, but its implementation has not started or is incomplete.
Fully Meets
We have completed a community needs assessment (including provision of training to
give local people access to project-related jobs), and we have developed and are
implementing a plan to make contributions to or support community development,
including strengthening local economic linkages.
Exceeds
1. A formal mechanism for sharing project-related financial benefits to community
development programmes.
2. Community has formal ownership/share of control of the project.
Artisanal and Small Scale Mining
Industry Norm :
To engage artisanal and small-scale miners (ASM) and facilitate their formalization and
improvement of their environmental and social practices, where there are known to be
legitimate ASM in the sphere of influence of the site / facility.
Does Not Meet

Where there are known to be legitimate ASM in the sphere of influence of the site /
facility, we have not engaged ASM.
Partially Meets
facility, we are committed to engage ASM on formalization and improvement of their
environmental and social practices, but the implementation of our program has not
started.
Fully Meets
facility, we engage with ASM on formalization and to improve their environmental and
social practices at their operations.
Exceeds
1. Target set and met for annual increase in ratio of licensed to unlicensed (or equivalent
measure of 'formalization') ASM in site's / facility's area of influence.
2. Agreement with formalized ASM to operate within site's concession in areas that
cannot economically be mined using industrial mining technologies and in accordance
with appropriate standards, or a sourcing agreement from immediate areas outside the
mine concession, and which promote continual improvement of operating practices.
Not Applicable
Business and Human Rights

Human Rights
Industry Norm :
To implement the UN Guiding Principles on Business and Human Rights including
human rights due diligence.
Does Not Meet

We have not implemented the UN Guiding Principles on Business and Human Rights.
Partially Meets
We have begun to implement the UN Guiding Principles on Business and Human Rights,
but implementation is incomplete.
Fully Meets
We have made a public and documented commitment to implement the UN Guiding
Principles on Business and Human Rights, and we publish, at least annually, our
f i t th it t
performance against the commitment.
Indigenous Peoples Rights
Industry Norm :
To implement a management system to respect the rights of Indigenous People,
including free, prior and informed consent (FPIC); avoid adverse impacts on Indigenous
Peoples' lands, livelihoods, resources, and cultural heritage; and develop and implement
an Indigenous Peoples' engagement plan.
Does Not Meet

Where there are known to be Indigenous Peoples communities or groups in the sphere
of influence of our site / facility, we do not consult with Indigenous Peoples or develop a
specific Indigenous Peoples engagement/development plan or strategy.
Partially Meets
of influence of our site / facility, we do commit to achieve FPIC with Indigenous Peoples
and to develop a specific Indigenous Peoples engagement/development plan or
strategy, but we have not started to implement the commitment or implementation is
incomplete.
Fully Meets
of influence of our site / facility, we have continue to have FPIC of the Indigenous
Peoples communities or groups and we have and are implementing a specific
Indigenous People's engagement/development plan
Exceeds
1. Convening/facilitation of the creation of an Indigenous Peoples' consultation
committee comprised of organizations or individuals that legitimately represent
Indigenous Peoples; proceedings and recommendations from the committee, and the
operator's responses to them, are made publicly available.
Not Applicable
Land acquisition and resettlement
Industry Norm :
Where land acquisition or resettlement is necessary: to implement a policy to explore all
viable alternative project designs to avoid and/or minimize land acquisition and physical
or economic displacement and to implement a resettlement action plan to fairly address

and compensate for residual adverse impacts.
Does Not Meet

We have not considered the avoidance of land acquisition or resettlement in our project
designs.
Partially Meets
We have a policy to avoid and/or minimize land acquisition and resettlement (including
the absence of a resettlement action plan), but we have not started to implement the
policy or it is incomplete.
Fully Meets
We have a fully implemented policy to avoid and/or minimize land acquisition and
resettlement, and our projects’ design has been optimized to minimize land acquisition
and avoid resettlement and a resettlement action plan has been developed to address
residual impacts.
Exceeds
1. Project design adapted so that there is no resettlement of Indigenous Peoples.
2. Project design adapted so that there is no resettlement of communities whether
Indigenous Peoples’ communities or not.
Not Applicable
Cultural Heritage
Industry Norm :
To identify cultural heritage sites and to establish a process based on consultation with
stakeholders to avoid, minimize, reduce and compensate for adverse impacts on cultural
heritage.
Does Not Meet

We have not consulted with stakeholder on the risks to cultural heritage from our site's /
facility's activities.
Partially Meets
We have committed to a process to manage risks to culture and heritage based on
consultation with stakeholders, but we have not started to implement the policy or it is
incomplete.
Fully Meets
We have a fully implemented a process to manage risks to culture and heritage
i t d ith ti iti th t i b d lt ti ith t k h ld
associated with our activities that is based on consultation with our stakeholders.
Exceeds
1. Positive contributions to the conservation and archiving of (tangible and intangible)

cultural heritage.
2. Adaptation of project design / layout to avoid impacts on fixed points of cultural
heritage significance (e.g. sacred forest and shrines; cemeteries).
Not Applicable
Due Diligence in Mineral Supply Chains
Industry Norm :
To implement the OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk Areas.
Does Not Meet

We do not implement policy or complete a due diligence that conforms with the OECD
DDG.
Partially Meets
We have committed to implement a policy and to complete a due diligence that
conforms with the OECD DDG, but we have not started to implement the Principles or
implementation is incomplete.
Fully Meets
We have a fully implemented a policy and completed a due diligence that conforms with
the OECD DDG.
Exceeds
1. Published OECD conformance report/audit/plan on website.
2. Participation in an initiative to create or support conflict-free supply chains.
Not Applicable
Transparency And Disclosure
Industry Norm :
Report annually on environmental, social and governance performance in line with
( )
internationally recognized standards (e.g. GRI) and to publicly support the

implementation of EITI, and report where appropriate.
Does Not Meet

We do not report on our environmental, social and governance performance, and do not
support the implementation of or report in accordance with the EITI.
Partially Meets
We have committed to reporting on our environmental, social and governance
performance, and to supporting the implementation of and reporting in accordance with
the EITI (where applicable), but we have not started to implement the commitments or
implementation is incomplete.
Fully Meets
We have a fully implemented a policy and completed a due diligence that conforms with
the OECD DDG.
Exceeds
1. Annual report on environmental, social and governance performance is assured.
2. Participation in initiatives to promote EITI implementation in non-member countries.
3. Voluntary reporting in accordance with EITI in non-member countries.

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8/5/2020 RBA - Risk Readiness Assessment Tool

Does Not Meet

Does Not Meet

We have in place a documented management system or process that effectively

Does Not Meet

Does Not Meet

Labor and Working Conditions

Does Not Meet

Does Not Meet

Freedom of Association and Collective Bargaining

Does Not Meet

Discrimination And Harassment

Does Not Meet

We have begun to develop policies, procedures and practices ( a management system)

Does Not Meet

unless defined otherwise by applicable law or a collective bargaining agreement; and to

Does Not Meet

Does Not Meet

We have in place policies, procedures and practices (a management system) to pay

Occupational Health and Safety

Does Not Meet

Employee Grievance Mechanism

Does Not Meet

We have begun to develop a grievance mechanism for employees but implementation

Does Not Meet

Greenhouse Gas (GHG) Emissions

Does Not Meet

Does Not Meet

Fresh Water Management and Conservation

Does Not Meet

Does Not Meet

Does Not Meet

Biodiversity and Protected Areas

Does Not Meet

We have in place a policy, procedures and practices (a management system) to follow a

Does Not Meet

Does Not Meet

Artisanal and Small Scale Mining

Does Not Meet

Business and Human Rights

Does Not Meet

performance against the commitment.

Indigenous Peoples Rights

Does Not Meet

Land acquisition and resettlement

or economic displacement and to implement a resettlement action plan to fairly address

Does Not Meet

Does Not Meet

1. Positive contributions to the conservation and archiving of (tangible and intangible)

Due Diligence in Mineral Supply Chains

Does Not Meet

Transparency And Disclosure

internationally recognized standards (e.g. GRI) and to publicly support the

Does Not Meet

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