IAMGOLD’s approach to Voluntary Principles on Security and Human Rights
IAMGOLD has operations in Burkina Faso, Suriname and Canada. As MAC has assessed the security-related human rights risks at the domestic-level in Canada to be low, the following is IAMGOLD’s approach to implementation and compliance with the Voluntary Principles on Security and Human Rights at our operations abroad.
At each of our sites, IAMGOLD’s approach to risk management includes annual security risk reviews which are then incorporated into the security risk register. The register is maintained on a continuous basis as new and emerging security risks are identified and managed. Statistics are kept on incidents that occur in the regions where our operations are based and all sites regularly monitor social and traditional media to identify any potential criminal activities. IAMGOLD also engages in information sharing on security and risk through various local industry forums.
All our security-related management systems are developed and implemented to be in compliance with VPSHR. For example, security procedures such as Use of Force, Firearms Control, Security Emergency Response Procedure and others incorporates specific requirements from the VPSHR framework. Where possible, we look to ensure that public and private security forces operate in a professional and responsible manner in respect of human rights considerations. All agreements with private security providers have mandatory compliance with VPSHR provisions and are trained in the proper Use of Force, while any MOUs signed by IAMGOLD with the security forces reference human rights requirements and state IAMGOLD’s commitment to VPSHR. Background checks (due diligence) are conducted on all private security companies to ensure any individuals or organizations implicated in human rights abuses do not private security services for the Company. Any alleged human rights abuses by private security contractors are reported and investigated with disciplinary action and/or contract termination undertaken where appropriate. Equipment transfers remain on IAMGOLD property, maintained and regularly inspected by IAMGOLD.
IAMGOLD obliges sites to undertake a regular and dedicated training program on human rights for all internal security personnel with a central module on the VPSHR. Our in-house security response personnel also receive annual recertification training with reference to VPSHR compliance conducted by a third party organization. In addition, we have designed specific human rights and VPSHR-related training documents that private and public security forces are required to undergo on a regular basis. Site security managers similarly liaise with managers and commanders of private security contractors or local security forces to ensure alignment. IAMGOLD conducts regular (at least annual) inspections of private security provider training records to ensure compliance with foundational and refresher VPSHR training. Training is also provided to key management and superintendents on VPSHR awareness by a third party.
IAMGOLD monitors and addresses potential grievances from the local community related to our security operations through our community relations department. Our human resources grievance process also provides a platform for reporting issues related to our security operations. Further, our ICAM process aids investigations on significant incidents related to illegal miner pit intrusions, small scale mining equipment invasion/ removal operations and use of force during encounters with external hostile elements.
At a broader level, our Corporate Security Standard ensures that an annual audit is conducted to ensure our security procedures are compliant with corporate strategy, standards and relevant local legislations and regulations. Additionally, we have integrated a VPSHR-specific Corporate Security and Human Rights Management Standard for distribution among corporate and sites. The Standard provides guidance for IAMGOLD site management and security personnel regarding the recognition and protection of human rights in line with the Voluntary Principles, including on procedures such as the Use of Force, Apprehension, Arrests, Detention, the contracting of Private and Public Security Forces, and other security-related challenges. IAMGOLD publishes details related to our security practices through the annual Sustainability Report available on the IAMGOLD website.
En 2009, Sherritt International Corporation (Sherritt ou l’entreprise) a commencé à appliquer les Principes volontaires sur la sécurité et les droits de l’homme dans sa mine de nickel Ambatovy, à Madagascar. En 2013, l’entreprise souhaitait officiellement se joindre à l’Initiative des Principes volontaires. Elle a donc effectué une série d’évaluations indépendantes des risques liés à la sécurité et aux droits de la personne dans la mine Ambatovy, dans ses installations pétrolières et gazières et ses installations de production d’énergie à Cuba ainsi que dans les sites liés à la coentreprise de traitement de nickel Moa, situés à Fort Saskatchewan (Alberta, Canada) et à Moa (Cuba). À la suite de ces évaluations, Sherritt a conçu un système de gestion complet pour cerner et atténuer les risques liés aux droits de la personne et à la sécurité, conformément aux attentes des Principes volontaires.
Sherritt a présenté une demande officielle et, à la fin de 2014, l’association des Principes volontaires a accepté d’intégrer l’entreprise.
En 2015, Sherritt a officialisé son engagement à l’égard des Principes volontaires; le président et chef de la direction a approuvé la politique de sécurité de l’entreprise et le chef de l’exploitation a approuvé sa norme sur la sécurité et les droits de la personne, deux documents conformes aux Principes volontaires. Sherritt a conçu d’autres procédures et directives pour intégrer certains éléments des Principes volontaires dans les pratiques de sécurité interne de l’entreprise.
Sherritt s’efforce d’appliquer les Principes volontaires dans tous ses sites; toutefois, la rapidité et l’étendue de la mise en œuvre dépendent du profil de risque et du contexte opérationnel de chaque site. L’application des Principes volontaires dans les sites à Cuba s’effectuera à long terme puisque les partenaires de la coentreprise (qui sont des sociétés d’État) et d’autres intervenants gouvernementaux doivent se familiariser avec ces principes. Au Canada, Sherritt sait que les risques liés à la sécurité et aux droits de la personne sont relativement faibles et que les pratiques de gouvernance ont atteint un certain niveau de maturité. Par conséquent, peu de mesures supplémentaires doivent être prises pour assurer la conformité aux Principes volontaires. À Madagascar, où les risques liés à la sécurité et aux droits de la personne sont plus importants, Sherritt a exécuté la majorité des tâches nécessaires pour se conformer aux Principes volontaires.
Ce rapport est le quatrième que l’entreprise présente à l’assemblée plénière sur les Principes volontaires. Il porte principalement sur les initiatives mises en œuvre au cours de la dernière année dans les sites de Sherritt à Cuba, au Canada et à Madagascar.
Voici quelques faits saillants de 2018 :
- Réalisation à 89 % de l’évaluation externe de la mise en œuvre des Principes volontaires à l’affinerie de Sherritt à Fort Saskatchewan (Alberta, Canada).
- Lancement de la Liste de vérification relative à la sécurité et aux droits de l’enfant d’UNICEF Canada, à laquelle Sherritt a contribué.
- Première année de mise en œuvre de l’initiative Vers le développement minier durable à titre de membre de l’Association minière du Canada (AMC), une association industrielle qui exige de ses membres qu’ils harmonisent leurs pratiques en matière de sécurité avec les Principes volontaires. En 2018, Sherritt a présenté un rapport sommaire à l’AMC concernant la mise en œuvre des Principes volontaires.
- Signature d’un protocole d’entente avec la Gendarmerie de Madagascar, qui comprend des engagements liés à la formation sur les Principes volontaires et à la sensibilisation à leur égard.
- Poursuite des discussions avec les représentants de Cuba concernant les Principes volontaires et l’initiative Vers le développement minier durable, ainsi que leur mise en œuvre potentielle dans les sites de Sherritt au pays.
ArcelorMittal aims to provide a safe and secure working environment for its employees and contractors and to protect its property. This is achieved in part through the use of public or private security forces in the locations where local conditions make this necessary.
Respect for human rights is fundamental to ArcelorMittal’s approach to business. The ArcelorMittal Human Rights Policy is aligned with the UN and International Labour Organization’s standards, and supports the UN Guiding Principles on Business and Human Rights (VPSHR) introduced in 2011. It includes commitments to our workforce, local communities and business partners, and covers health and safety, labour rights, and the rights of communities and Indigenous peoples. Our policy was developed in collaboration with NGOs, investors, and academic experts with experience in business and human rights, and was published in 2010, and updated in 2016.
ArcelorMittal’s human rights policy states that ‘ArcelorMittal aims to ensure that the provision of security to our operations and our engagement with public and private security forces is consistent with the laws of the relevant country and relevant international standards and guidelines, such as the VPSHR. We will adapt our security arrangements to balance the need for safety while respecting human rights’.
At present, ArcelorMittal is not an official member of VPSHR, however, we are supportive of this initiative and aim to align our activities to be these principles and good practice.
POLICIES AND PROCEDURES
Further to the ArcelorMittal Human Rights Policy, ArcelorMittal has a detailed security policy which sets out how and when our security personnel can use force, arms or firearms. We expect our officers to act in a way that respects human rights at all times, and to comply with all applicable national, state and local laws. Our policy is based on the Voluntary Principles for Security and Human Rights and the UN Code of Conduct for Law Enforcement Officials.
High risk countries in which we operate are required to maintain an up-to date security threat and risk assessment. This includes an assessment of security and human rights risks and means for developing appropriate plans to address risks of human rights infringements.
Every ArcelorMittal subsidiary is required to provide local stakeholders an effective channel to raise any grievance – this includes those related directly or indirectly to security matters.
COUNTRY IMPLEMENTATION EXAMPLE: ARCELORMITTAL LIBERIA
In Liberia, one of our higher risk countries of operation, we have established management systems for adherence to the VPSHR. Private security contracts include a requirement for adherence to VPSHR. Training and awareness raising is 2018 TSM Progress Report 38 provided to both our own staff and our security providers. All contracts with private security include a clause related to adherence to VPSHR. All of our security guards are trained on VPSHR as part of their induction. ArcelorMittal Liberia has conducted a risk assessment which includes a focus on security and human rights to identify where the key risks could exist and focus management attention. In addition, there is regular community engagement and discussions with the government on topics related to security and any concerns that may exist. Local internal assurance reviews are conducted to check implementation against these activities.
As a company that operates in areas where there is significant risk of human rights impacts related to the presence of extractive companies, we recognize our responsibility to identify our human rights risks and impacts and actively work to manage them – at all of our sites and through our partnerships and business relationships. Our approach is outlined in our Human Rights Standard, which is aligned with the Universal Declaration of Human Rights and other international human rights law, the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the Voluntary Principles on Security and Human Rights (VPs).
In 2017, a human rights risk assessment was conducted at our Fekola site in Mali, and a human rights impact assessment was carried out at Masbate in the Philippines, led by an independent experienced human rights lawyer and security and human rights consultant. VPs-based risk assessments were carried out in collaboration with our security departments in Mali and the Philippines as part of these human rights assessments. The VPs risk assessments were based on ongoing formal and informal engagement internally with our Community Relations departments as well as externally with local residents, officials and public security, monitoring and patrols, and community grievance mechanisms. Action plans were developed and integrated into plans and systems at those sites, and annual VPs risk assessments and planning will be carried out going forward. Similar assessments will be conducted in Namibia and Nicaragua in 2018. With the recommendations from the human rights assessments and VPs risk assessments built into site-level plans and systems, our existing annual audits of site social management systems will include security and human rights risks and actions. In the future, B2Gold will consider engaging a third party to conduct these audits.
B2Gold takes a proactive approach to managing relationships with public security providers. In both Mali and the Philippines, our security and human rights expectations have been communicated to relevant public security and government officials, and regular engagement occurs. Actions planned for 2018 include updating agreements, conducting joint training where possible, and continuing regular coordination and engagement.
Private security providers are coordinating with our security management teams in Mali and the Philippines to implement the VPs. Training based on the VPs was carried out in 2017 for B2Gold and private security personnel in Mali and the Philippines and has been built into ongoing security training. As of the end of 2017, 100% of private security staff in the Philippines and 92% in Mali had received training on the VPs. Ongoing work includes ensuring that B2Gold standards for human rights and security are built into all private security contracts, training, and operating procedures.
Further information on B2Gold’s implementation of the VPs is contained in our 2017 Responsible Mining Report, accessed at: www.b2gold.com/_resources/B2Gold_RMR2017_Interactive.pdf.
Eldorado Gold Corporation and its subsidiaries (together “Eldorado”) are committed to providing a safe and secure working environment for our employees, contractors and visitors. Through our participation in the International Social Responsibility Committee of the Mining Association of Canada (MAC), Eldorado was part of a 2017 membership commitment made by MAC to implement a human rights and security approach consistent with the Voluntary Principles on Security and Human Rights (VPs).
We are responsible for the security of our people, property and products so when our locations’ context warrants extra protection we enter into relationships with public and private consultants to provide this security. We acknowledge that security and human rights can, and should, be consistently applied across the organization, and we seek to operate in a manner that promotes and protects human rights.
Eldorado retained an independent consultant to conduct a long-term project to review existing security arrangements and to address performance gaps and training needs in accordance with the VPs. The assessment included a review of management policies, site actions, and stakeholder perceptions related to security and human rights. In November 2017, training on the VPs was provided to Eldorado’s leadership team including Officers, country Vice Presidents and mine managers, and in early 2018 a pilot project was undertaken at Eldorado’s Tocantinzinho project in Brazil. Key gaps and recommendations from the review will inform the development of security and human rights training materials that will be adopted, adapted and applied across all Eldorado sites. A human rights training video was also rolled-out for use in employee and contractor induction and refresher training.
Eldorado’s Human Rights Policy was updated in 2017, stating that all of our mine sites are required to align their security practices with the VPs, and follow all laws in the jurisdiction of operation when engaging with private or public security forces. The VPs are an important part of our commitment to protecting and respecting the human rights and safety of all our stakeholders while maintaining the security of our employees, contractors and assets.
Formal complaints and grievances pertaining to security and human rights are managed through our Whistle Blower Reporting Agency.
In 2017, we published our fourth annual Conflict-Free Gold Report. The Report details our findings that Eldorado’s operations, and all gold and gold-bearing material produced by our operations, conform to the World Gold Council’s Conflict-Free Gold Standard. The Standard creates a framework for assurance that the production of gold by a company does not contribute to unlawful armed conflict or human rights abuses. Eldorado’s conformance with the Standard was subject to independent assurance.
Eldorado is a gold and base metals producer with mining, development and exploration operations in Turkey, Greece, Romania, Serbia, Canada and Brazil. The company has a highly skilled and dedicated workforce, safe and responsible operations, a portfolio of high-quality assets, and long-term partnerships with local communities. Eldorado’s common shares trade on the Toronto Stock Exchange (TSX: ELD) and the New York Stock Exchange (NYSE: EGO).
Excellon Resources Inc. is a TSX-listed silver and base metals producer headquartered in Toronto, Canada. We mine Ag-Pb-Zn ore from our Platosa underground mine located near the town of Bermejillo, Durango, Mexico. Ore is crushed at Platosa and then trucked approximately 230 km to our wholly-owned concentrator facility located in the town of Miguel Auza, Zacatecas, Mexico. We are committed to meeting the requirements of the Voluntary Principles on Security and Human Rights (VPs) in our business.
In 2017 we began the development and implementation of our Corporate Responsibility Management System (CRMS), consisting of a series of 51 standards covering safety, health, security, environmental protection, community relations and development and human rights. As part of this process, we are assessing our vulnerability to security-related incidents, and the risk of potential human rights issues associated with our business and between our business and the communities surrounding our operations. Furthermore, we are developing a gap analysis against the requirements of the VPs; this will serve as a roadmap as we move forward.
We have contract security personnel at both locations to protect our property and assets; these personnel are unarmed. As part of our commitment to the VPs we will confirm that all such personnel have basic human rights-related training to ensure that our expectations vis-à-vis human rights are understood.
Since we are in the initial stages of developing and implementing a common approach to security across the business as part of our CRMS we have not undertaken assurance of our conformance against the VPs.
First Quantum Minerals Ltd. (the “Company”) respects human rights, which means First Quantum acts to avoid infringing on the rights of others and commits to addressing impacts that occur as a result of our business activities. In developing this policy we are guided by the principles of the internationally recognized human rights norms:
- The Universal Declaration of Human Rights
- The Voluntary Principles on Security and Human Rights
- ILO Declaration on Fundamental Principles and Rights at Work
- UN Declaration on the Rights of Indigenous Peoples
- Guiding Principles on Business and Human Rights
- Implementing the UN “Protect, Respect, and Remedy” Framework
We are also subject to the laws of the countries in which we operate and are committed to complying with all such laws, while abiding by the international human rights norms described above. We strive to protect our people and assets and provide a secure environment in which our businesses can operate. Our security policies, systems, guidelines and practices, to the extent reasonable, are consistent with international standards, including the Voluntary Principles on Security and Human Rights, and the laws of the jurisdictions where we operate.
Our focus to date has been on implementing strong policies and have not yet implemented a review or assurance program.
In 2011, through incorporation in Hudbay’s Human Rights Policy, we formally adopted the Voluntary Principles on Security and Human Rights to guide our security and human rights risk assessment process, management of private security, and relationships with public security. Our implementation of this commitment includes:
- All security contracts entered into by Hudbay require adherence to the Voluntary Principles.
- Hudbay conducts education sessions for its employees and contractors involved in security activities in respect of the United Nations’ Code of Conduct for Law Enforcement Officials (www2.ohchr.org/english/law/codeofconduct.htm) and in particular the Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (www2.ohchr.org/ english/law/firearms.htm).
The nature and level of our efforts in this area are guided by our assessment of nature of security risks and the public institutions overseeing public and private security forces at each of our locations. Our 2017 Annual and CSR Report further describes our activities under “CSR Approach” / “Human Rights and Security” (www.s1.q4cdn.com/305438552/ files/2017/en/human-rights.html).
For the audits of security policies and practices at Hudbay Peru that are mentioned in our report we utilize the framework provided in the Global Compact Network Canada document “Auditing Implementation of the Voluntary Principles on Security and Human Rights”.
Kinross supports the Voluntary Principles on Security and Human Rights and has established an internal Human Rights Adherence and Verification Program (HRA & VP) to implement this commitment. Maintaining safety and security at our operations, in a manner which respects human rights and recognized freedoms is an imperative for Kinross. Through our HRA & VP, we work to ensure the safety and security of our employees, people and our property and mitigate potential security, safety and human rights risks that may arise in our operations, development projects, and exploration concessions.
The HRA & VP program establishes procedures and training at all Kinross operating mines on an annual basis to help ensure that all security personnel, as well as key site management, understand and are consistently compliant with human rights best practices and standards as related to security. This includes specific training on the use of force in line with Kinross’ weapons policy, and provides guidance in such areas as reporting incidents and fostering a well-developed security relationship with public security forces. The training is required for all private security personnel and Kinross management teams. Public security forces are invited and encouraged to attend. In 2016 and 2017, 751 and 908 security people were trained respectively, representing 100% and 98% of Kinross’ security personnel respectively and an average of 2,500 training hours each year.
Through the HRA & VP, we also monitor the human rights records of security providers (private and public) used by the company. Monitoring includes information gathered through various international, regional and local agencies. All Kinross agreements now include respect for human rights as a major component.
The HRA & VP also includes comprehensive annual audits to assess risks and measure private and public security compliance across all Kinross sites. Human Rights Risk Assessments are carried out as part of our site security audits at each site.
Each Kinross location has robust systems for allegation reporting and verification, investigation and resolution, monitoring of investigations by public officials, and other essential elements of security oversight.
Grievances pertaining to security and human rights are managed through our Whistleblower reporting mechanism.
Through our active participation in the International Social Responsibility Committee of the Mining Association of Canada (MAC), Kinross was part of a 2016 public declaration made by MAC regarding a commitment to implement a human rights and security approach consistent with the Voluntary Principles on Security and Human Rights.
Lundin Mining Corporation (LMC) is committed to operating in accordance with the Mining Association of Canada’s (MAC) principles pertaining to security practices and human rights. We prioritize these goals at our global operations located in Portugal, Sweden, the United States and Chile, and at our exploration projects.
LMC strives to ensure that its business activities are always conducted in accordance with the company’s mission and values, which are aligned with and support the expectations established by the Voluntary Principles on Security and Human Rights (VPs). Our company values are safety, respect, integrity and excellence, and our commitment to upholding and respecting human rights is stated in the following documents: Code of Conduct, Ethical Values and Anti-Corruption Policy (Code of Conduct); Responsible Mining Policy; annual Sustainability Report; and, annual United Nations Global Compact Communications on Progress.
At each of our sites, local security is important to the success of our operations, and we have an ongoing process of engagement and coordination with regional authorities and emergency responders. Proactive relationships have been established with our private security providers to ensure that processes are in place to work directly with relevant authorities to report any issues, and to ensure LMC’s workforce is protected from circumstances associated with legal infringements or public disturbances that could affect their safety and well-being. These security services are reviewed on a periodic basis to ensure performance is held to the highest standards. At this time, LMC is not aware of any alleged or reported events or complaints related to human rights abuses involving private or public security services at our operations or sites.
Stakeholder engagement is a priority for LMC; we are committed to ensuring any issues or concerns that might arise related to actual or perceived human rights breaches or violations are taken seriously. Stakeholders have access to grievance mechanisms at all our operations; employees and on-site contractors working for LMC’s mines have access to a thirdparty administered confidential and, if desired, anonymous ClearView Connects reporting system, accessible by telephone and the internet. In accordance with the Company’s Code of Conduct and Whistleblower Policy, concerns related to discrimination or infringements on human rights are to be reported on that basis, via ClearView Connects or otherwise, to the Chair of the Corporate Governance Committee for timely review and follow-up.
With respect to assuring that our practices align with the VPs, in 2019, LMC will be conducting a comprehensive Human Rights Impact Assessment for all operations and exploration sites. The assessment Protocols and methodology will be based on international best practice including the VPs and the United Nations Guiding Principles on Business and Human Rights. In addition, we plan to conduct a formal risk assessment at each operation using the Voluntary Principles on Security and Human Rights Implementation Guidance Tools.
We are proud to be members of MAC and affirm our commitment to upholding and respecting human rights in the areas where we operate.
New Gold supports the Voluntary Principles on Security and Human Rights and has established a Human Rights Policy to articulate and support this commitment. At New Gold, our expectation is that safety and security at our operations is conducted in a manner which respects human rights and our company values. Wherever we operate, we work to ensure the safety and security of our employees, people and our property and mitigate potential security, safety and human rights risks.
Our Human Rights Policy establishes the expectations at our operating mines to help guide all security personnel, as well as key site management and to make them aware that they are expected to be compliant with human rights best practices and standards as related to security. This is particularly important at our Cerro San Pedro operation where human rights are at greatest risk relative to our Canadian and US operations. Training is required for all private security personnel and New Gold management teams. Public security forces are invited and encouraged to attend. In 2016 and 2017, 37 and 28 security people were trained respectively, representing 100% of New Gold’s security personnel respectively and an average of 761 training hours each year, which represents an average of 2.33% each year of the total training percentage.
We have also monitored the human rights records of security providers (private and public) used by Cerro San Pedro by auditing against the Voluntary Principles using an external auditor in 2013. The audit included information gathered through various international, regional and local agencies.
New Gold also includes comprehensive annual external audits to assess risks of our gold being used to fund conflict. As part of these audits private and public security compliance across at our Cerro San Pedro site is assessed. Internal Human Rights Risk Assessments are carried out as part of our site security audits at this site.
Each New Gold location has robust, anonymous “whistleblower” mechanisms and systems for allegation reporting and verification, investigation and resolution, monitoring of investigations by management, and other essential elements of security oversight. External grievances pertaining to security and human rights are recorded and managed through our sitespecific or corporate grievance and feedback reporting mechanisms.
Through our active participation in the International Social Responsibility Committee of the Mining Association of Canada (MAC), New Gold was part of a 2016 public declaration made by MAC regarding a commitment to implement a human rights and security approach consistent with the Voluntary Principles on Security and Human Rights.
Protection of human rights is fundamental to Nyrstar’s core values and we are committed to respecting fundamental human rights wherever we operate. The commitment to human rights is documented in our Code of Business Conduct which forms the basis for all our dealings with employees, communities and other stakeholders. At our mining operations in Canada and the US, security forces are unarmed and are primarily engaged in controlling access to the operating sites. This reflects the low security risks in these operating locations as confirmed by our risk assessment processes.
The implementation of the Voluntary Principles on Security and Human Rights (VPSHR) has been adapted to this low risk operating context and has not warranted the development of VPSHR-specific standards or procedures. Instead, human rights risks are managed through our enterprise risk management system and the ethical framework for decisionmaking established under the Code of Business Conduct. Examples of management processes implemented under these governance systems as relevant to security forces include: crisis management and emergency response arrangements, contractor management processes, workplace safety systems and conflict resolution mechanisms.
Pan American Silver Corp. (the “Company”) is a primary silver producer with six operating mines, projects, and exploration projects in Argentina, Bolivia, Mexico, and Peru. The Company has initiated a number of activities under the framework of the Voluntary Principles on Security and Human Rights, as part of its Mining Association of Canada commitments.
The priority for all security programs at Pan American Silver is to mitigate security risks to protect our people, and provide a secure and safe workplace, by acting in accordance with local laws while being mindful of international practices and principles, particularly with regard to the use of force. As with our safety programs, senior management provides oversight of our security program, with each site or project manager providing day-to-day oversight of specific programs. Under circumstances where there is an increased security risk or security incidents have occurred, our Corporate Crisis Management Committee may become involved to oversee additional activities, coordination, or incident investigations. The Company assesses security risks at our operations and projects through a collaborative effort between our senior and local management. As part of the risk assessment, we consider the site-specific incident history, international management practices, a wide range of possible security events, local intelligence & media reports and/or events that may have high risk potential.
In addition to the risk assessment, the Company has implemented a review process of its security program and site security operations. The first level of our review process is a five-point site self-assessment. Based on responses from the self-assessment, security risks, and insurance requirements, the Company may conduct additional security practice reviews and site visits.
The Company’s grievance mechanisms, whistleblower policy, anti-corruption and anti-money laundering, as well as financial reporting compliance programs are also key elements of the security process, providing additional guidance and verification of the Company’s relationships, support, and interface with public security forces.