Episode #4: Responsible Mining

The Initiative for Responsible Mining Assurance (IRMA) provides a solution to a global demand for more socially and environmentally responsible mining. IRMA offers true independent third-party verification and certification against a comprehensive standard for all mined materials that provides ‘one-stop coverage’ of the full range of issues related to the impacts of industrial-scale mines. Join us as we discuss IRMA and the mining sector with the organisation’s Executive Director, Aimee Boulanger.

Information about this episode and other industry news and insight can be found here on our blog, the Trubshaw Tribune. If you'd like to be kept up to date about future episodes, please subscribe to our newsletter.

Audio Transcription

[00:00:15] Sean: Hi there. Thank you for joining us. If you're involved in security, communities or sustainability in the extractive industry then you're in the right place. Today we're talking about the next evolution in responsible mining, and there are few as qualified on the topic as Aimee Boulanger. Aimee is the Executive Director of the Initiative for Responsible Mining Assurance, IRMA, under whose leadership published the standard for responsible mining.

My two cents worth IRMA standard goes far beyond ESG or sustainability reporting and is really about operational excellence. But I'm getting ahead of myself. Aimee, welcome. Thank you so much for joining us.

[00:00:50] Aimee: Well, it's wonderful to be here, Sean. And thank you so much for inviting me to join you. and join your listeners, to talk about mining, to talk about what happens when mining's happening to communities, to workers, for the companies doing this work, and others in this space.

I'll share first that, I started working on mining issues 25 years ago. I came in working for an NGO initially, and I was working with communities across the American West who had mining in their communities, and who were concerned about the impacts. In some cases they wanted a mine in their community. They really appreciated the income and the work and the opportunities it brought but, they may have been concerned about blowing dust or what was happening to their water or what would happen in their community when the mining company left. And other cases, there were communities where a new mine was proposed and they didn't want it there and they were afraid. They were afraid of what was going to happen to cultural heritage or sacred sites or they're farming and ranching situations. And so, our work was to help them understand what happens when mining does come, what were the laws, the regulations they could use to protect their interests as well as they negotiated with mining companies. And, and it was them choosing the goals and us creating support for them to be heard and to be a more equal negotiator when mining companies came to their region. Over those years, we were also working on trying to improve laws and regulations that covered mining in the US, which, you know, most people think of the US as a place with more rigorous laws and that's true in many cases. We have a clean air act and a clean water act and many others, but we also have a mining law that dates back to 1872. When the vision of those who passed it at that time was very much about colonization, about moving white settlers to the West about, creating capitalist ways to, quote, unquote, deal with what they saw as an indigenous problems and it really doesn't fit. It created a lot of conflicts that were there. It exacerbated conflicts. There was a lot of harm done in that process and it doesn't fit the American West of today. And so, there's been a lot of work to try to change that law over that time. But of course, during that time mining also, for many decades now, is globalized and there was a lot of talk then about the work in the US. Sometimes more, you were working to strengthen laws and regulations and give leverage to communities in the US or Australia or Canada. These other places with stronger laws, you were pressing the, need for mining to other countries in the world. Whether that be South Africa or Zimbabwe or Indonesia or the Philippines, and other countries that produce the materials that much of modern society and especially more affluent nations rely on. So there was an interest in, could you craft a, a more global standard for what mining would look like? And if I can take myself and you on a little detour in that, I mean, a lot of the reason that came about

[00:03:54] Sean: To, to jump there you say that kind of as a matter of factly, because it's old hat, but that's an entirely, such a daunting task. Oh created global standard for responsible mining. It's massive. It's mind boggling. I mean, where do you even start with that? You know, it's amazing.

[00:04:10] Aimee: And frankly, some of us, including me thought actually that might not be the right approach right now. We actually haven't reformed the mining law in the US. And you know, in the US right now, from over a hundred years of, industrial scale mining, it's estimated that half of Western watersheds are contaminated with mine waste, back from a pick and shovel time in the US, through industrial scale times more recently. And so, there were many who thought what business is there to look globally when the work isn't done here and we can't model out to the world yet that, that this has been accomplished. However, just as industry has been globalizing for decades, the need for communities to be networked with each other about the impacts and even to keep the track records of different companies, also began to globalize so that they could talk about, you know, how did this company perform in Canada? And then how did it perform when it went to Australia and how did it perform again then when it went to Ghana or somewhere else? Right. So, the conversation was beginning to spread and then of course there was a consciousness and, and somehow the consciousness has come later to mined materials than it has to other things. I think people have become more aware of know where your food comes from, know where your water comes from, your power comes from. Of course, many of people in the world, the vast majority know exactly the answer to that, right? Because their everyday lives are focused on that every single day. They know exactly where they're going for their food, their water, their power, but for more affluent industrialized nations, many people are distant from that. And so, they're certainly distant from the 60 mined materials in their phone and where did they come from or their car. And those materials don't look much like what they look like when they started right. A banana, when it leaves a plantation, still looks like a banana in the store, no matter where in the world it is, right. But iron ore that becomes steel or bauxite that becomes aluminium doesn't. It goes through so many changes and most people aren't aware of where that comes from and their part in that. And so, what was happening around 15 years ago was this increased awareness around what was becoming known in more popular circles as the issues of blood diamonds and the jewellery sector becoming aware that even though they didn't own or operate mines, they were going to be held to account for what happened in those spaces. And some of them wanted to be active in responding to that. They felt themselves as people who were working to craft something beautiful and something that was representative of family, and commitment, and the idea that it would be tied to harm in home communities where the resources came from, they knew was in direct conflict with what they were trying to craft and so at that time the CEO of Tiffany and Company, Mike Kowalski, reached out to the NGO Earthworks and said, look, you know, could we build something together? Could we craft some agreement of what would be more responsible mining? I mean to Earthworks credit at the time they said, look, we're not even sure we know what that looks like right now because it's so far from reality.

[00:07:12] Aimee: And, and frankly, we haven't had the luxury to think about who are the best and the cleanest and the greenness and the most responsible because we've really been focused on what are the worst. And how do we stop the worst practices that happen where mining is? But it started a conversation around what, what would it look like if you, especially if you were dealing with materials that people used every day and not just jewellery, but the things that were more based around what people needed like copper and iron ore. And so, they, they sat down to begin to look at what would a standard look like. And, and basically then what you're really talking about is a shared definition, right? What is our definition of what is responsible mining? And they started with, one chapter, what's human rights? And another chapter, what's protecting the drinking water? And then in another chapter, what about this blowing dust? How do you protect air? And then it became 10 chapters and now it's 26 because part of their interest was to stop trading issues off of one another. You know, it shouldn't just be, here's worker health and safety but don't look at the orange water flowing off our site over there, right? Or we're really proud that we've reduced the dust, but don't look at the fact that our security forces have gotten in conflict with local community folks, you know, three times in the last month.

[00:08:25] Sean: I'm probably jumping the gun here, but what I really love about the work that you guys have done and the standards you produce, as a consultant, I've referred to that so many times, even if my clients haven't actually asked for an audit or for that, because it's such a gold standard and so comprehensive in terms of the topics that you guys cover and the detail that you go into it. I feel that every general manager should at least read all of that to be able to actually understand what the game is outside, what that non-technical risk is, you know, if that's going to be affecting their business, because I feel so many you know, miners don't really know. They have a fuzzy feeling and idea of what ESG is and they've got a sustainability guy sitting, maybe in Perth or in Johannesburg, but the day to day what's happening on site and outside of the fence line. I think you guys have just really captured what to look for. What, what is that gold standard that, that you should be striving for? So I thought I'd just throw that in there, cause it really is some great work that you guys have done.

[00:09:26] Aimee: well, thanks for saying that Sean. And I think, it's interesting because IRMA I mean, I agree with you that it's a real guidebook and IRMA is criticized sometimes because the IRMA standard is long, you know, as I said, it's 26 chapters, right? And then if you add up all the individual requirements in them, it's more than 400 requirements. And as you said, it speaks to best practices. It's all doable. It was not written to be aspirational. It's all things that can be done. And it's all things that are being done at mines around the world. But the truth is there are very few mines who do all of the things in there because the market hasn't valued them doing that. So, you may have one mine that's doing a great job dealing with dust, but maybe not such a great job with worker rights. And so, the idea was to put it under one house. We stopped trading the issues against each other, but also to be brave about saying this is what's best and then can we create a market recognition and value for mining companies to get there? And some will say to us, well, it's way too long and it's too prescriptive. It's got so many details. It's it's too much. And I've said, I don't hear my managers say that, actually, because if, when you say to them, have a stakeholder engagement plan, many will say, well, well, what exactly do you mean by that? Right. They actually don't want less. They want more information, like describe, I mean, of course a stakeholder engagement plan in Zimbabwe is going to look different than the one in the Philippines because you're going to have a different community around you. You may have a different number of people around you and the distance to people and different with watersheds that flow off the mine and into the community. You're going to have different languages and, and stakeholder engagement plan should be accessible to people who live around you. So that we say things like it should be in a language which is accessible. Your community should know it exists. They should know how to talk to you. They should know they're safe to complain, and if they complain, they should know someone's going to respond to them and that's going to be a pretty satisfying response within a reasonable amount of time. Yeah. Everything I just said is a lot of words and it's more than just have a stakeholder engagement plan, but it's something that you can still flex around and you get a start to get a feel of what that's going to look like no matter where you are in the world.

And part of the reason it has so much description and it is the way it is now is because it didn't stay a process between a jeweller and an NGO because right away that company and that NGO knew that they weren't the right people to do this alone and that they would have to craft a multi-stakeholder table for it to have any chance of success.

They were using the Forest Stewardship Council at the time as a model for how to build something. I mean, forestry and mining have a lot of things similar and a lot of things really different. But in this context, they said, look, we could use that model of bringing together different stakeholders who are going to have this argument and debate about what is responsible mining. So that table became five houses. So, one was the purchasers of material like the jewellers and the others were the NGOs. That was second. Third was organised labour. Fourth was affected communities. And then fifth was mining companies themselves. And so, they're now 15 years deep in having what is a very public debate. They have equal governing authority to run IRMA. They've now invited a sixth house. So, the finance and investment sector is now the sixth governing house in IRMA. They all have two seats.

[00:12:38] Sean: I wasn't aware of that sixth house. That's interesting, I want to kind of touch on that later about the whole ESG rating and, and that's obviously key, but sorry I interrupt. Carry on.

[00:12:48] Aimee: Well, the only piece I wanted to make sure I say in that is that it's not only because this is so important to how you craft something, which is accountable. but it's not only that each of the six houses have two seats, but they each have veto authority over the others. So, two no votes from the same house, stop decisions. So, 10 out of 12 votes, don't carry a vote in IRMA if the two nos came from the same house, whether that house was the mining industry or affected communities, whether it was NGOs or the labour unions. So that idea being that they have agreed, they can't leave a house behind. One human can't hold everything up but if the two of them together in a house have said, you know, this new way to make a change in the IRMA standard on what's expected or change the way it's going to be audited is not going to be good for our sector. We think this loses its value or it's accountability or our trust in it. They can stop it and then everything in IRMA must stop and they must work together to get to solution. And that's part of why it took a very long time. but it's also part of its credibility now is that it's got to be out holding that accountability across sectors.

[00:13:53] Sean: Really, really interesting. This is 15 years. That's a long time to be working on this and there's a lot of due diligence that went into that and a lot of cross industry buy-in and contribution. On one hand, you've got operationally and tactically, it's all about impact that you're having on the ground and what you do matters, what miners do on the ground and what communities do matters. You spoke a bit about the valuation of meeting that standard and accreditation. How has this been taken forward in terms of being scaled, because you hear a lot about, ESG investing is a way forward or ESG is now dead. There are so many standards about, so how do you see that kind of mellay at the moment and how is it moving forward?

[00:14:40] Aimee: A good question. A few things I think about with it, I mean, one is that, um, I mean the work that I do and, and having the IRMA standard, which is a voluntary initiative, is never going to replace the role of law and government because anyone can opt out of what we do right now, right? You can choose to do the IRMA standard. You can choose not to do the IRMA standard and I'll come back to why would you choose? But, but I want to say first that, ideally one thing it does right there is stands as a tool, not only for communities living near mines or the mining companies running their mines, but also for governments who are looking at how do we set the rules that everyone needs to follow. And I hope it serves as a template for that. I, I mean, here in the US that conversation on mining reform is happening again right now because the 1872 mining law, 25 years later still exists here. And so, what can we do to bring it up, especially if you're trying to tell indigenous communities in the state of Nevada in the US you want more lithium in a place where they feel like the last century of gold extraction has not delivered them seven generations of prosperity into the future. So, they're pretty sceptical about the lithium promise now. So, I think, when I look at how do you take it forward and scale beyond it being a template for improving law and government, we've got to create value all the way across, right? So, it's got to be that mining industry says, okay, why would we do this? Why would we do more? I mean, I think part of that is because you've got a lot of new people that have come into the mining sector, who cared about being in places where materials are, they're often part of the community. They didn't come in saying I want to be as much trouble and cause as much harm here as I can, but often many clever, innovative people in these companies have been held down by saying, look at, this is not the cheapest way to get something done. Our competitor there, five kilometres down is doing it more efficiently. Keep wages low, keep costs low. This is a permission slip moment for them to invest more. To doing things in a way that is more socially and environmentally thoughtful. That's thinking about how are we going to leave this landscape in this community when we go? Because most mines do go. These materials run out, and then it's a space where the whole supply chain can also value. So, you're asking the mining company to change. But you're asking its customers also to change, change how you buy and what you ask for from your suppliers, so that they begin to value it. And they're shouldering that burden and creating value for those companies to make that effort. And then of course, it's not going to work if it doesn't serve as something that's trusted by workers, and communities and other advocates around those regions, because they need to trust that it's not just going to become some kind of greenwashing tool that just puts a new green check on a company who's doing the same thing they've always done, but now we call it, you know, ESG certified, right? And so it's got to be something which has some legitimacy and tangible change. And that again is part of the reason for it to be so detailed. Again, say we have a stakeholder engagement plan and everybody checks the box, yes. But no one's done anything different, right? Because it's so generalized. We can all say that we are all doing it when really it's not being done in many cases, it's aspirational. So, I think, what we saw now, I mean, I started by telling you that story of the jewellery sector coming in, but now with the press for mining, that's associated with the energy transition, with materials that would go into batteries or go into wind turbines. Not just the battery, but the infrastructure or solar panels or electric vehicles. There's a new attention on mining again now that says, look, if these are materials associated with energy transition and, they are harming people's agricultural lands, or they are destroying cultural resources or they are increasing conflict between communities. If they are exacerbating what's happening where the 500-year flood seems to come every five years right now or drought is dragging on for years right now. And it's pumping more water out of the ground. Well, then our solutions to the climate crisis are exacerbating the problems we're already living with from the climate crisis. And so, we better have higher expectations because we don't live in the same world anymore. I mean, we were doing harm to it over the last a hundred years, but we just, we don't have that wiggle room anymore. As many communities never did. But, for this change moment.

[00:19:03] Sean: No, absolutely. I mean, just on that, I think there's also a resurgence of mining in developed countries as well. And when you start doing exploration and operations and production in developed countries, there's that natural scrutiny that you have to step up to. So, I think there's a natural drive in that area as we go towards mining, for the energy sector. You said something really interesting about, the valuing of it and it making a difference on the ground for the last 10 years. There are many studies that have documented the cost of getting it wrong for major mining operation. It becomes very expensive into the tunes of millions a week if they get it wrong in the non-technical risk factor. And I can't wait until, in a few years’ time when you guys have got your own study to show the impact of IRMA. It's quite clear for me that, if you look across to the oil sector, ExxonMobil for all its sins, after the Exxon Valdez crisis just changed tact and when you speak to ExxonMobil employees they say we're a safety company that also does oil. And they learned that if they focus on safety, they can reduce a lot of pain and a lot of costs and make their business more effective. And that's kind of the way I see a lot of the sustainability issues. And, for me, if a big red flag of whether a company or a site is really progressive is how tightly coupled is sustainability into operations. Is there a clear understanding of what's going to be happening outside of the fence site today or tomorrow, you know, or is it just a case of just reporting stats up to be able to post onto the website? And I think, when the financiers, and this is just my impression when the financiers have a look at, how do we really tell if it's greenwashing or not? I think IRMA standards, you know, whatever industry they're looking at, where the rubber hits the road is about practical implementation that has got to have an impact on productivity and improve productivity. So yes, it might be more expensive to do things properly in the short term. But, like Michael Porter says, it's only in the very short term. I mean, when you look over the long term, it makes business sense just to be good at what you do, you know? And it just makes sense for me anyway.

[00:21:28] Aimee: That's so well said. And I think about one of the mining companies who started doing IRMA early, which of course is, is a brave leadership act itself, right. To step in and say, okay, I'm going to pick up this big document and I'm going to look across its 25 chapters. And now, you know, what does it look like on the ground? And when we were still writing, which was happening from 2006 to 2018, when the draft standard came out. For a dozen years, there was writing that was going out for public review and debate across stakeholder lines. Is this the right metric of responsible practice? Is that what your reference should be on human rights? What was realistic? And then field testing in Zimbabwe, field testing in the US, through all that time, when the first companies were picking it up, You know, of course not long after COVID hits. Right. And I remember one of those companies saying in 2020, the IRMA standard had only been out at that point for about 18 months. Our first two mines, one in Mexico, and one in Zimbabwe were going through their audits saying, the IRMA standard helped us so much, even though it couldn't have foreseen COVID. Between a chapter that was on emergency preparedness and response, a chapter that was on community health and what is the mining company's role in community health and a chapter on worker health and safety. There were so many pieces we already had in place because the IRMA standard had already been integrating what had been learned from Ebola, and from HIV aids and how mining was exacerbating or spreading these issues, from experiences with malaria and TB in this space that when COVID came along, you know, the experience of like, what could we have done? What should we have done? What did some companies do that could have helped in communities was already built in so much that if you, you had a whole structure where then you could flow into how do we respond when we've got to keep people six feet apart? And we got to think about how we're going to transport workers from point A to B when they're not supposed to be in a bus together. It just gave them a lot of that resiliency as well to think across. So, I think it really can be a tool there.

The other thing I was thinking, Sean, when you said this earlier about scaling up, is that, you know, IRMA's still new in the world. The first dozen mines, now that COVID restrictions have lifted some, the first dozen minds are amidst their audits. That's the case in South Africa. but also in Chile, in Argentina and in Brazil, and, there are another 55 mining companies with over 80 mines who are thick preparing with a self-assessment tool, which we make free available to mining companies. It's the entire IRMA standard and its guidance document built into a digital tool so that before auditors ever walk their ground, they can be their own auditor. They can run themselves through, they can score themselves, they can upload data. So, they get a strong sense of like, oomph, if the auditors we're walking our ground right now, you know, we're kind of weak in this area and doing pretty well over here because our leading purpose isn't just to score them in this moment, but it's to drive value for improvement. So, we want companies to see like, boy, we're weak in this area, in this one, but if we make these change, our scores are already going to be coming up. Let's do that before the auditors ever walk the ground. so now there's this pipeline of companies who are ready, coming out and there are now six car makers who have come into IRMA saying, we're going to use this in our sourcing. And of course, that has changed everything because while jewellery is important and that was important for getting things started, they and the tech sector, they buy little bits of things, right? Like small, small components that they're making. When you have the auto sector saying, this is what we expect. we're being asked to do our diligence, to know the harm in our supply chain and do what we can to lever it. We're going to use this tool so we can at least first understand where the harm is happening and then create value and expectation for improvement there. And, and that is shifting all of the opportunity for value in the mining sector.

[00:25:21] Sean: Fascinating. I quite often, before I step onto a site, and I'm doing my homework and due diligence, everything I can see open source, it looks amazing and you think, wow, these, these guys really have it, you know, squared away. And they know what they're doing. And then I step onto the site and within a day or so after kicking the tires, you realize, oh, they haven't connected the dots here. There are plenty of dots. They're just not being connected. And I think that where your standards Would help that is that even if you don't understand why they're, they're connected, if you paint by numbers, you're connecting the dots. And if I was a chief investment officer looking for a responsible fund or responsible sourcing for a supply chain, I would be very dubious of what I see on a website. But then if there is the IRMA mark, where this is an audited site, there's real assurance there. and I think that is a huge, huge value that is just waiting to be tapped.

[00:26:21] Aimee: Hmm, you know, it's so interesting. because even thinking about you walking that site, the majority of audits of mine sites, of course they tend to be confidential, right. They tend to be business to business, and you've got some purchaser there, right? Who hires, an auditor or other reviewer to give them a sense of risk walking the ground. but there's this critical missing piece in those dots that you're working to connect there, right. Is that, is this transparency of the audit is happening, and this is what we're looking at, and this is what we're going to measure it against. and this is what we consider best practice. I mean, every single one of those pieces are ones that if you live in a mining, Community, you've got an, a, a view on right. Is like, oh, that's how you defined clean water. I wouldn't have said that was clean water or, you know, that's what you think of our downstream uses. But do you know that we actually do fish in this area down here and you didn't look at aquatic life, right. You only looked at, which aquatic life is more sensitive than actually than human drinking water. and so, for us the key piece is the transparency of like, what is metrics? how is that set and is that public, but then is audits being publicly noticed? So before going in, we say, hello world, whether that world is an NGO sitting in Germany or the company itself, or a member of the community who lives half kilometre away, this audit is happening. If you want to speak, you can be heard. Here's your direct line. You can use your WhatsApp or you can use email or you can call, the auditors. This is how you reach them. If you want to speak to them, when they're on site, this is the time they'll be there. And they're meeting with community members and the mining company's not here.

So, we'll publicly notice audits so that community members know when audit's happening and they can speak to it. And then even if they don't raise our hands up, the auditors who are reviewing a mine under IRMA are going to community members and saying what do you think of this mine? What's your history been with it here? How does it operate? are there things that concern you? When things concern you, do you know who to call about it? Are people responsive? And so, they're talking to workers and community members. The amount that the dots created by those people help fill in what's happening. Because I agree when you walk a site and you see it just through one lense often you think this looks pretty good and there's, and many sites, you know, have things to be proud of, but then there's almost always industrial skill mining is an incredibly destructive practice and it's providing materials that industrialized society is using every day and asking for.

[00:28:51] Aimee: So we've got to hold that tension. It's time to stop having this very overly simplistic. It's all five star and triple A. And have a more authentic accounting for the impacts that go with it. And then can we value, reducing the harm where those impacts are there? Even if we acknowledge that there's going to be some amount of disruption.

[00:29:10] Sean: Fascinating. Aimee, I could spend ages talking about this and geeking out. I think that's, it's absolutely fascinating. I guess my final question is. What's next? You guys have achieved so much, what does 2023 look like for IRMA?

[00:29:] Aimee: I think the big moment that we need to prove, over this next year is mining companies coming in and doing independent audits. Having 55 companies with 80 mines doing their self-assessments right now isn't anything until they cross over and say, we'll do the independent review. We'll be transparent about our impacts and you've got their customers valuing that for them. starting to differentiate between suppliers. And I think we have yet to prove that. So, I think that's really the work this year. I hope if we talk a year from now, I'm closer to being in a place where I can tell you that the volume of material coming from mines that meet some threshold and IRMA is enough to make your car or your phone, out of, and it's not just, a template and an example of what would be better someday.

[00:30:11] Sean: Wonderful. Wonderful. Well, listen, absolutely good luck. And I can't wait to chat to you again about this in the years’ time. I'll hold you to that but thank you very much for your time. I really appreciate it. And I've loved this chat. Thank you.

[00:30:21] Aimee: Thanks for your work, Sean. Take good care.

[00:30:23] Sean: Well, that's the end of our episode for today. Thank you very much for listening.