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Principle 1

Apply ethical business practices and sound systems of corporate
governance and transparency to support sustainable development.

Performance expectations

Summary of consultation feedback


Establish systems to maintain compliance with applicable law.

Several consultees suggested that legal compliance is a minimum expectation, so this should be guaranteed, but they also would expect ICMM members to go beyond these basic requirements. Some recognised that law is inadequate in some countries – and therefore companies should comply with international best practice.

Note: The consultation draft included a footnote to the effect that ‘ICMM’s member companies already comply with all applicable law in the countries that they operate in. However, many stakeholders say they want mining companies to show that they have strong systems that ensure legal compliance’.


Implement policies and practices to prevent bribery, corruption and
to publicly disclose facilitation

Some consultees requested further detail about the practices to prevent bribery and corruption and others also suggested complete prevention of facilitation payments.


Implement policies and standards consistent with the ICMM policy framework.

Some consultees encouraged extending this to include member management systems.


Assign accountability for
sustainability performance at the Board and/or Executive Committee level.

Feedback was broadly positive, but it was suggested that this performance expectation would fit better elsewhere under a different principle.


Disclose the value and beneficiaries of financial and in-kind political contributions whether directly or through an intermediary.

Some consultees suggested revenue disclosure should also be included, but overall the response was positive.

Note: Revenue disclosure is dealt with in PE10.2

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