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Validation Guidance

13 February 2020

This is a supplement to ICMM's Assurance and Validation Procedure providing explanatory information on the implementation and evaluation of ICMM's Mining Principles.

ICMM does not require company members to implement every aspect of this guidance. It is not intended to be a complete list of all elements of a management system nor is it designed to provide ‘compliance criteria’ for every element of ICMM's Mining Principles. It is our intention that the guidance be a ‘living document’ that will be subject to periodic revision in light of experience.

Validation Process and Outcomes

Validation includes two types of activities related to a member’s implementation of the performance expectations at the asset level. These are:

  • Self-assessment – First-party confirmation (ie self-assessment) of the existence and integrity of systems and/or practices relating to implementation of the performance expectations, to the extent that they are applicable in a given context.
  • Third-party validation – Independent confirmation of the reasonableness and authenticity of assertions made in self-assessments. This review may take place as part of a separate system, eg an ISO 14001 environmental management system audit.

Outcomes of Validation Activities

Validation activities evaluate the implementation of the performance expectations individually. There is no overall outcome for a given asset. The possible outcomes for the validation of an individual performance expectation are 'meets', 'partially meets', and 'does not meet' as defined below:

  • Meets — Systems and/or practices related to the performance expectation have been implemented and there is sufficient evidence to demonstrate that the intent of the performance expectation is being met, however opportunities for improvement may still remain.
  • Partially Meets — Systems and/or practices related to meeting the intent of the performance expectation have been only partially implemented. Gaps or weaknesses persist that may contribute to an inability to meet the intended outcome of the performance expectation, or insufficient verifiable evidence can be provided to demonstrate that the activity is aligned to the intent of the performance expectation.
  • Does Not Meet — Systems and/or practices required to support implementation of the substantive intent of the performance expectation are not in place, or are not being implemented, or cannot be evidenced.

Relationship Between Position Statements and Performance Expectations

All ICMM position statements include a number of commitments that company members are required to implement. These may either apply to individual company members or can be delivered collectively through membership of ICMM. Where position statement commitments apply to individual company members, they are also referred to in the Assurance and Validation Procedure as 'mandatory requirements'.

The introduction of the performance expectations has caused a degree of uncertainty regarding the status of position statement commitments as many, but not all, of the mandatory requirements have been incorporated within the performance expectations. To avoid ambiguity, where a performance expectation has related position statement commitments, these are explicitly included within this guidance document and linked to the relevant performance expectation.

For self-assessment and third-party validations, members are required to provide evidence of implementation of the mandatory requirements of related position statements. For those performance expectations that have related mandatory requirements, the determination of 'meets', 'partially meets' or 'does not meet' needs to be made on the basis of the wording of the performance expectation and any related mandatory requirements.

Applying the Self-Assessment Template

A self-assessment template is provided that may be used to document validation activities. The following considerations apply to the completion of the self-assessment template.

  1. The first step in the self-assessment process is to consider applicability of the performance expectations – as in some cases, a performance expectation may not be applicable to an asset. If a member determines that a performance expectation is not applicable at a given asset, select ‘Not Applicable’ from the drop-down menu and provide comments explaining this determination.
  2. The next step in the self-assessment process is to consider equivalency (see the Assurance and Validation Procedure).

    Note that ‘equivalent programmes’ are defined as having standards/requirements and validation requirements that are similar in scope and intent as the ICMM performance expectations validation process.
  3. Equivalency applies at the individual performance expectation level, rather than at the overall programme level. ICMM will maintain details on an ongoing basis regarding what other equivalent programmes can be recognised as such – and the extent to which their requirements are equivalent to each individual performance expectation.

    Where the requirements of performance expectations are incorporated into a members’ ISO 14000 environmental management system or other management systems that are subject to certification, these can also be considered as equivalent.
  4. If a performance expectation has been validated by an equivalent programme in the past three years, this should be indicated by either selecting 'covered by equivalent programme' or 'partially covered by equivalent programme' and providing comments explaining this determination.
  5. Where an equivalent programme has a requirement that only 'partially meets' (or 'does not meet') the corresponding ICMM performance expectation, an asset should provide evidence that it is meeting the supplementary elements of the performance expectation in order to ‘meet’ the performance expectation requirements.
  6. The next step is to evaluate performance expectation implementation. In evaluating the implementation of individual performance expectation, aspects such as frequency, quality and extent should be considered (see the Assurance and Validation Procedure for definitions).
  7. For each applicable performance expectation, members should include details of what they are doing to achieve the intent of the performance expectation and the evidence to demonstrate this. This might include links to relevant internal or publicly available documents. The evidence that supports the self-assessment determinations will be used for subsequent third-party validations. For this reason, the better the quality of evidence collected during self-assessment the better-placed an asset will be for third-party validations.
  8. Lastly, defining implementation gaps will help assets establish action plans to close any identified gaps and will facilitate future disclosures, as outlined in the Assurance and Validation Procedure.