Responsible Resourcing Alignment Supplement

This TSM Responsible Sourcing Alignment Supplement (‘supplement’) is a voluntary tool to support companies that are implementing the TSM standard alongside the following standards:

International Council on Mining and Metals (ICMM) Mining Principles (MPs)
World Gold Council (WGC) Responsible Gold Mining Principles (RGMPs)
Responsible Minerals Initiative (RMI) Risk Readiness Assessment (RRA), including the International Copper Alliance (ICA) Copper Mark (CM)

It also serves to qualify mine sites for ResponsibleSteel (RS) recognition.

If you are planning to use the supplement as part of your external verification process, please reach out to MAC for more information.

Title *

Year

Select your certification type: *

International Council on Mining and Metals (ICMM) Mining Principals (MP)
World Gold Council (WGC) Responsible Gold Mining Principles (RGMP)
Responsible Minerals Initiative (RMI) Risk Readiness Assessment (RRA), including the International Copper Alliance (ICA) Copper Mark (CM)
ResponsibleSteel (RS)

Section 1: Corporate Governance and Ethical Conduct

1. Legal Compliance *

Have processes been established to ensure compliance with applicable laws?

Yes
No
Not-Applicable

Description & Evidence

2. Code of Conduct *

Is a code of conduct maintained to make clear the standards with which employees, suppliers, and contractors are expected to comply?

Yes
No
Not-Applicable

Description & Evidence

Is awareness of the code actively promoted and are systems implemented to monitor and ensure compliance?

Yes
No
Not-Applicable

Description & Evidence

3. Combatting Bribery and Corruption *

Have policies, practices and controls been implemented that prohibit and effectively prevent bribery (including facilitation payments) and corruption in all their forms, conflicts of interest and anti-competitive behavior by employees, agents, or other company representatives?

Yes
No
Not-Applicable

Description & Evidence

4. Political Contributions *

Are the value and beneficiaries of financial and in-kind political contributions, whether directly or through an intermediary, publicly disclosed?

Yes
No
Not-Applicable

Description & Evidence

6. Accountabilities *

Is accountability for sustainability performance assigned at Board and/or Executive Committee level?

Yes
No
Not-Applicable

Description & Evidence

For RGMP equivalency, is the reporting done as per the RGMP reporting requirements?

Yes
No
Not-Applicable

Description & Evidence

7. Engagement with Corporate COI *

Have key corporate-level external stakeholders on sustainable development issues been identified and engaged with in an open and transparent manner?

Yes
No
Not-Applicable

Description & Evidence

Section 2: Integration of Sustainable Development Into Corporate Strategy and Decision-Making

8. Corporate Sustainable Development Strategy *

Have sustainable development principles been integrated into corporate strategy and decision-making processes relating to investments and in the design, operation, and closure of facilities?

Yes
No
Not-Applicable

Description & Evidence

9. Supply Chain Policy *

Has a Supply Chain Policy been adopted and published? Have contractors and suppliers been supported to operate responsibly to meet standards of ethics, safety, health, human rights, and social and environmental performance comparable to those standards within the reporting company?

Yes
No
Not-Applicable

Description & Evidence

Are due diligence processes conducted to identify human rights, corruption and conflict risks associated with facility and supply chain activities and practices by joint venture partners with the intention of preventing adverse impacts and supporting the adoption of responsible practices?

Yes
No
Not-Applicable

Description & Evidence

Is risk-based due diligence exercised on those entities to which the facilities’ products are sold?

Yes
No
Not-Applicable

Description & Evidence

Section 3: Respect for Human Rights and Labour Rights

10. Human Rights Due Diligence *

Have policies of the UN Guiding Principles on Business and Human Rights been adopted and implemented by: a) developing a policy commitment to respect human rights? b) Undertaking human rights due diligence? c) • Providing for or cooperating in processes to enable the remediation of adverse human rights impacts that the facility has caused or contributed to?

Yes
No
Not-Applicable

Description & Evidence

11. Conflict-Affected and High-Risk Area Due Diligence *

Has the facility undertaken risk-based due diligence on conflict and human rights that aligns with the OECD Due Diligence Guidance on Conflict-Affected and High-Risk Areas when operating in – or sourcing from – a conflict-affected or high-risk area? (Note: implementation of the WGC Conflict Free Gold Standard fully addresses this criterion)

Yes
No
Not-Applicable

Description & Evidence

12. Resettlement *

Are involuntary physical or economic displacement of families and communities avoided?

Yes
No
Not-Applicable

Description & Evidence

13. Security and Human Rights *

Has a human rights and security approach consistent with the Voluntary Principles on Security and Human Rights been implement, based on risk? (Note: this requirement is in line with MAC’s membership commitment on the Voluntary Principles and is deemed to have been addressed and externally assured by those members that conduct external assurance on their security systems and processes.)

Yes
No
Not-Applicable

Description & Evidence

15. Compensation for Work-Related Injury, Illness & Fatality *

Are processes in place to support injured or ill workers including their rehabilitation?

Yes
No
Not-Applicable

Description & Evidence

Are records kept related to work-related injury, illness, and fatality?

Yes
No
Not-Applicable

Description & Evidence

Does the company commit to and have procedures for determining and providing compensation, including for dependents, in the event of fatality? (Note: This only applies in jurisdictions where compensation for work-related injury, illness or fatality is not provided by a government scheme.)

Yes
No
Not-Applicable

Description & Evidence

16. Employee Renumeration and Terms of Employment *

Are employees remunerated with fair wages and benefits that are equal to or exceed legal requirements or represent a competitive wage within that job market (whichever is higher)? Is this requirement also applied to employment and recruitment agencies?

Yes
No
Not-Applicable

Description & Evidence

Are regular and overtime working hours assigned within legally required limits? Is this requirement also applied to employment and recruitment agencies?

Yes
No
Not-Applicable

Description & Evidence

Are employment terms documented in writing and communicated at the beginning of employment and when terms change, as well as when workers are hired through employment and recruitment agencies?

Yes
No
Not-Applicable

Description & Evidence

17. Diversity and Women in Mining *

Have policies and practices been implemented to promote diversity at all levels of the company, including the representation and inclusion of historically under-represented groups? Does the company report on progress?

Yes
No
Not-Applicable

Description & Evidence

Does the company commit to identifying and resolving barriers to the advancement and fair treatment of women in their workplaces?

Yes
No
Not-Applicable

Description & Evidence

Does the facility aim to contribute to the socio-economic empowerment of women in the communities associated with facilities through employment, supply chain, training, and community investment programs?

Yes
No
Not-Applicable

Description & Evidence

Section 4: Environmental Stewardship

18. Environmental Risk Management *

Does the facility demonstrate that an environmental management system (EMS) is implemented that is functionally equivalent to an internationally recognized EMS standard (e.g., ISO 14001)?

Yes
No
Not-Applicable

Description & Evidence

19. Closure *

Has the facility planned for the social and environmental aspects of mine closure in consultation with authorities, employees, affected communities and other relevant stakeholders?

Yes
No
Not-Applicable

Description & Evidence

Are financial and technical provisions in place to ensure planned closure and post-closure commitments are realized, including the rehabilitation of land, beneficial future land use, preservation of water sources and prevention of acid rock drainage and metal leaching? (Note: Security bonding provided under regulatory requirements satisfy this requirement.)

Yes
No
Not-Applicable

Description & Evidence

20. Pollution Prevention and Waste Management *

Is the mitigation hierarchy applied to prevent pollution, manage releases and waste (hazardous, non-hazardous, and inert), and address potential impacts on human health and the environment?

Yes
No
Not-Applicable

Description & Evidence

Are heap leach and large-scale water infrastructure managed consistently with internationally recognized good practice guidance? (Note: The TSM Tailings Management Guide is considered internationally recognized good practice guidance.)

Yes
No
Not-Applicable

Description & Evidence

23. Spills and Leakage *

Is a preventative maintenance program implemented aimed at preventing spills and leakages that includes a risk assessment of potential sources of spills and leakages, regular inspections and testing, record keeping, and corrective action processes?

Yes
No
Not-Applicable

Description & Evidence

Based on the risk assessment results, are emergency procedures in place to mitigate and remediate the effects of spills or leakages that include procedures to assess impacts of spills and leakage and the effectiveness of mitigation and remediation measures?

Yes
No
Not-Applicable

Description & Evidence

Is the effectiveness of the preventative maintenance program and readiness of the emergency procedures internally assessed annually and externally verified on a predetermined frequency at least every three years?

Yes
No
Not-Applicable

Description & Evidence

25. Land Use and Deforestation *

For new projects, is meaningful consideration given to the land access needs of nearby communities and to the preservation of biodiversity in determining the project footprint?

Yes
No
Not-Applicable

Description & Evidence

Does the facility aim to minimize deforestation arising from its activities?

Yes
No
Not-Applicable

Description & Evidence

26. Circular Economy *

In project design, operation, and de-commissioning, has the facility implemented cost-effective measures for the recovery, re-use, or recycling of energy, natural resources, and materials?

Yes
No
Not-Applicable

Description & Evidence

Section 5: Social, Economic and Institutional Development

27. Local Procurement *

Does the facility enable access by local enterprises to procurement and contracting opportunities across the project lifecycle, both directly and by encouraging larger contractors and suppliers, and by supporting initiatives to enhance economic opportunities for local communities? (Note: Facilities that can demonstrate inclusion of local procurement into their community benefit work as part of Indicator 4 in the TSM Indigenous and Community Relationships Protocol are deemed to have addressed this requirement.)

Yes
No
Not-Applicable

Description & Evidence

28. Cultural Heritage *

Does the facility identify cultural heritage sites and establish a process based on consultation with stakeholders to avoid, minimize, reduce, and compensate for adverse impacts on cultural heritage? (Note: Cultural heritage criteria are also included in the TSM Indigenous and Community Relationships Protocol (Indicator 3 Effective Indigenous Engagement and Dialogue Level A), which need to be addressed by the facility in conjunction with this supplement.)

Yes
No
Not-Applicable

Description & Evidence

29. Artisanal and Small-Scale Mining (ASM) *

Where artisanal and small-scale miners are present, does the facility support access to legitimate markets for ASM that: a) respect applicable legal and regulatory frameworks? b) seek to address the environmental, health, human rights and safety challenges often associated with ASM activity? c) and, in good faith, seek formalization?

Yes
No
Not-Applicable

Description & Evidence

Where mercury is in use by artisanal and small-scale miners, does the facility consider supporting government initiatives to reduce and eliminate the use of mercury?

Yes
No
Not-Applicable

Description & Evidence

Has the facility collaborated with government, where appropriate, to support improvements in the environmental and social practices of local ASM?

Yes
No
Not-Applicable

Description & Evidence

Section 1: Corporate Governance and Ethical Conduct

Section 2: Integration of Sustainable Development Into Corporate Strategy and Decision-Making

Section 3: Respect for Human Rights and Labour Rights

Section 4: Environmental Stewardship

Section 5: Social, Economic and Institutional Development

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