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Program components, governance, and policies

TSM is a globally recognized sustainability program that supports mining companies in managing key environmental and social risks. In order to ensure consistency between companies implementing TSM, there are core components of the program, governance, and policies in place.

Core Components of TSM

TSM has been adopted internationally, and each national mining association is able to tailor the performance areas and approach used to reflect their unique context. However, there are core components that associations must implement in order to maintain the high standards of TSM.

These core components include: the guiding principles, performance indicators, facility-level reporting, independent verification, condition of membership, and multi-interest advisory body.

Guiding Principles

When adopting TSM, the first step is to commit to the TSM Guiding Principles.  In doing so, mining companies commit to acting responsibly by adopting social, economic and environmental practices that align with the priorities and values of their communities of interest. As a condition of membership in MAC, companies endorse the TSM Guiding Principles and commit to reporting on TSM performance elements within three years of membership.

Performance Indicators

The TSM Guiding Principles are backed by a suite of performance protocols to measure mining facility sustainability performance. For more information on these protocols and performance indicators, click here.

Facility-Level Reporting

Facilities self-assess their performance annually against the sustainability performance indicators within the various protocols. They assign a letter grade to each indicator that reflects their performance, ranging from Level C to Level AAA. The overarching goal of TSM is for all mining companies to achieve a Level A or higher, which means they are effectively managing their key social and environmental risks, and are adhering to good practices in environmental management, safety and community engagement.

These grades are made public in MAC’s annual TSM Progress Reports. New members have three years to start publicly reporting their results. The implementation period is as follows:

  • Year 1: The company must undertake TSM training and conduct a gap analysis. The results of this analysis are shared with MAC to inform opportunities for capacity building and training.
  • Year 2: The company must self-assess their TSM performance, and their results are included in industry aggregated reporting.
  • Year 3: The company’s facility-level results are published for the first time in the TSM Progress Report.
  • Year 4: The company’s TSM performance results undergo a first external verification and are published in the TSM Progress Report.

Independent Verification

Associations must implement an appropriate framework for independent verification of performance to ensure that facilities’ self-assessed results accurately reflect performance.

Every three years, a company undergoes third-party verification. In the year of external verification, mining companies must submit a Letter of Assurance from their CEO stating that the verification was conducted in accordance with the Verifier Terms of Reference. Annually, the Community of Interest Advisory Panel selects two mining companies to appear before the Panel and participate in a Post-Verification Review. In this review, the verified results are discussed, and the Panel further examines the company’s ESG performance.

Condition of Membership

TSM must be a condition of membership in the implementing association. For instance, since 2006, TSM has been a condition of membership for MAC members. 

Multi-Interest Advisory Body

Associations must establish an independent, multi-interest advisory body that represents challenging interests and a broad spectrum of societal perspectives. This body must work closely with the association to support the governance and implementation of TSM.
 

Support from MAC

MAC provides ongoing training, frameworks and guides to support members in achieving these conditions and to ensure that the program is consistently applied across the membership. In turn, members are expected to demonstrate continuous improvement over time. 

 

TSM Governance

The governance and decision-making process for the TSM program involves several groups and committees – both internal and external to MAC. Each of these groups has an important role to play in ensuring the credibility, transparency, accountability, and continual improvement of the program. Learn more about TSM governance below.

 

TSM Policies

Claims and Labels Policy

Published in December 2021, this policy describe how members and non-members can use messages, logos, and imagery to communicate TSM performance.

Issues Resolution Policy

This policy ensures that any issues, concerns, or grievances related to TSM are resolved in a timely, consistent, and transparent manner. This policy allows individuals or groups to submit issues to MAC or a third party and outlines a multi-step process for resolving any issues raised. No issues, concerns, or grievances related to TSM were received in 2022 and 2023.

Public Comment Policy

MAC posts relevant draft policies and protocols on the MAC website for public comment. After an initial review by the TSM Governance Team, documents are typically posted for 30 days, though the duration of the public comment period may change depending on the timelines involved. Any comments received are shared with the TSM Initiative Leaders and the Community of Interest Advisory Panel to inform further drafts of a given document. MAC also publishes a high-level summary of comments received, alongside a brief explanation of how the comments were or were not addressed.

Conflict of Interest Policy

The TSM Conflict of Interest Policy is an internal document generally applicable to those involved in supporting TSM including employees, boards of directors, third-party verifiers, and Community of Interest Advisory Panel (COI Panel) members. Violations of this Policy will be handled in accordance with the TSM Issues Resolution Policy.

Digital Trusted Credential Governance Framework

MAC has been engaged in a pilot project with the Government of British Columbia that allows companies to securely exchange TSM data with verifiers, investors, customers, and others, using a digital trusted credential. The governance framework for MAC’s role as a participant in this project is available here. The governance framework for the performance credential is available here.

Adherence Policy

Should a member company not meet the minimum expectations of the TSM program as outlined above, a process has been established by the MAC Board to ensure adherence to the commitment and drive continuous improvement.

The first step in the this process requires engagement between the member’s TSM Initiative Leader (i.e., the individual responsible for a company’s TSM implementation) and MAC staff to work to resolve any issues. If the MAC staff member and the TSM Initiative Leader are not able to find a solution, the issue is escalated to the MAC President and/or MAC Board Chair, who will raise the issue with the company’s MAC Board representative. If the issue is still not rectified, it is brought to the TSM Governance Team, made up of representatives from MAC’s member companies, for discussion.

At each of these stages, the objective of the process is to identify ways to bring the company into conformance with the condition of membership (e.g., additional training, a grace period, etc.). If the issue still cannot be resolved, it is brought to MAC’s Executive Committee to consider whether a recommendation should be made to the MAC Board for revocation of membership.

Step #1
Company Initiative Leader raises issue with MAC staff.
Step #2
MAC's President and/orthe Board Chair discusses issue with company Board representative.
Step #3
The issue is brought to the TSM Governance Team.
Step #4
The issue is brought to the MAC Executive Committee.
Step #5
The MAC Executive committee develops a recommendation for the MAC Board of Directors.

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