CSR Abroad – Due Diligence and Risk Assessment
Due diligence can be understood as the process through which enterprises identify, prevent, and mitigate the actual and potentially adverse impacts of their operations. Due diligence is an on-going, proactive and reactive process, and can cover a variety of CSR-related financial, social and environmental factors. Below are some examples of the due diligence and risk assessment processes of Canadian mining and exploration companies:
Responses by Company
Agnico Eagle Mines Limited
As part of our Responsible Mining Management System, we carry out internal audits. For Conflict Gold, TSM (Towards Sustainable Mining) and the Cyanide Management Code, we carry out external audits. As part of our Responsible Mining Management System, we carry out risk assessment and maintain a risk register. Our standard is to establish action plans for high and very high risks to reduce them to at least moderate. The risks register is presented to the Board of Directors.
American Potash Corp.
The company conducts due diligence through direct oversight of operations.
American Vanadium Corp.
The company conducts due diligence through a multi-disciplinary review of new projects, project developments and potential acquisitions.
Angkor Gold Corp.
On acquisition of license, we look to the holders and agreements on the license (all 7 of ours are 100% owned by Angkor). On purchase of supplies and equipment, down to the smallest item, we have terminated staff that undertake any level of unethical conduct. We check out personnel with legal, social, and financial conduct prior to them becoming part of the team.
On a potential project, we would ask questions like, ‘is it affected by any baseline contamination from prior owners? Is it affected by parks or conservation areas?’ ‘How many people are in the affected area and what is the demographic and social impact on those people if we proceed?’ ‘How are the upper levels of politics going to view this project, and what do we need to do to gain ethical permitting to proceed?’ ‘What impact will the project have on the economic situation of the village, the district, the province, and the nation?’ ‘What do we need to do in HSE (Health, Safety and Environment) to bring it up to a Canadian or international standard?’
AuRico Gold Inc.
The company has oversight via Management and the Board Technical and Sustainability Committee along with a Risk Committee. These teams and committees meet on a quarterly basis.
Barrick Gold Corp.
At Barrick, we conduct due diligence across a wide range of social and environmental issues, from supply chain and community relations to human rights and environmental impacts. This process is guided by policies, management systems, and programs which direct us to provide oversight, monitor performance, and complete regular risk assessments at both a site and corporate level.
Our own due diligence process is supported by several external third party assurance and audit processes, including ongoing external ISO 14001 audits; annual human rights assessments; annual external assurance of our alignment with the International Council on Mining & Metal’s Sustainability Development Framework and related Position Statements; third party review of our performance against the Mining Association of Canada’s Toward Sustainable Mining framework; annual Voluntary Principles on Security and Human Rights assessments, among others.
Due diligence is required under Cameco’s International Business Conduct Program when hiring employees, engaging third parties and entering into mergers and acquisitions. Due diligence plans are created, as required, using a risk-based approach.
Delta Gold Corp.
All new activities are subject to strict technical, environmental, social, and legal due diligence.
HudBay Minerals Inc.
Elements of our due diligence process include:
- daily reporting requirements to the corporate office for all incidents (environment, health & safety, and community related) at any location
- regular site visits by corporate personnel
- the frequency and focus of the visits partly determined by assessments of areas of risk at each location
- quarterly reporting of more serious / higher potential incidents to the Board committee responsible for CSR
- selective use of consultants to carry out reviews on sites / topics determined to be higher CSR risks
In 2015 we intend to define a more structured CSR audit program as part of our corporate management system. The CSR aspects of our business are also included in our Enterprise Risk Management program. Specific risks identified through that program are also tracked by the Audit Committee of our Board of Directors. We also have a Whistleblower hotline that links directly to the Audit Committee of our Board of Directors.
Kinross Gold Corp.
Due diligence is observed and integrated into investment decisions at each stage of project life cycle as part of our Corporate Responsibility Management System (CRMS) from acquisition to development, operation, and closure. This includes conducting due diligence and risk assessments to identify areas where our activities may impact the lands, rights, or interests of the environment, community, and Indigenous peoples.
NOVAGOLD Resources Inc.
Our senior management and Board of Directors consistently review our performance and potential risks across all aspects of environmental management and compliance, health & safety, and CSR on a regularly scheduled basis, and when specific events necessitate additional scrutiny.
Rhyolite Resources Ltd.
We evaluate potential environmental liabilities through legal and governmental searches.
Strata Minerals Inc.
When analysing prospective exploration targets, a full due diligence process (legal, technical, financial, environmental, political, etc.) is performed prior to any commitments being made.
Suncor Energy Inc.
We have incorporated due diligence processes into our asset development evaluation and planning.
A company indicated that its due diligence process involves cross-functional team members throughout all areas of the business, including various upper management positions. This company undertakes extensive desktop and on-site evaluation of the applicable matters which are thoroughly reviewed and discussed at both the senior leadership and executive leadership levels.
A company indicated that they assess community issues, needs, and concerns at each area or project. Discussions are held with community leaders and individuals to ensure that the company fits into and complements the local situation rather than clashes with it. For example, if wages for workers on a mining/exploration project are too much higher than those paid for farm labour, there will be concern and complaints from farmers concerned with planting, crop care, and harvesting as workers would want to work on the exploration project instead or demand similar wages that the farmer may not be able to afford. Consideration must also be given to learning if local employers are exploiting local labour by paying rates that are too low. A balance that makes everyone happy has to be found if the project work is for more than a few days.
A company explained that the decision to spend limited resources on one project or another is very important. All risk assessment programs include working with people from the community, so they can all be made aware of the work that is being done. Plus, at community dialogues and talks with the community, all the relevant results are exposed to the entire community for them to understand the complexity of the risk assessments in general.
The following companies indicated that they conduct due diligence as part of their management process, but declined to include any further details:
- Banro Corp.
- Brazil Resources Inc.
- Endeavour Silver Corp.
- Goldcorp Inc.
- Handa Copper Corp.
- Nortec Minerals Corp.
- Sherritt International Corp.
- Unigold Inc.
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