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Principle 4

Implement effective risk-management strategies and systems based on sound science and which account for stakeholder perceptions of risks.

Performance expectations

Summary of consultation feedback

PE4.1

Undertake environmental and social impact assessments (ESIAs) as required for new projects or significant changes to existing operations in consultation with interested and affected stakeholders, and publicly disclose ESIA reports.

Some consultees expressed concern over the qualifier ‘as required’ and emphasised the need for ESIAs to be in line with international best practice. Some encouraged strengthening disclosure, transparency, and emphasised accessibility of community communications. Some suggested explicitly including health to as part of the scope of ESIAs.

Note: The footnote to PE 4.1 states ‘These should cover issues such as air, water, biodiversity, noise and vibration, health, safety, human rights, gender, cultural heritage and economic issues. The consultation process should be gender sensitive and inclusive of marginalised and vulnerable groups.’

PE4.2

Undertake 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.

Some consultees suggested that due diligence should be carried out regardless of the location of operation or origin of materials sourced.

PE4.3

Implement risk-based controls to avoid/prevent, minimise, mitigate or remedy health, safety and environmental impacts to workers, local communities, cultural heritage and the natural environment, based upon a recognised international standard or management system.

Some consultees requested further clarification and a clear outcome from application of risk-based controls. Others suggested that ‘mitigate or remedy’ should be ‘mitigate and or remedy’.

PE4.4

Develop, maintain and test emergency response plans. Where risks to external stakeholders are significant, this should be in collaboration with potentially affected stakeholders and consistent with established industry good practice.

Some consultees suggested considering climate risks in relation to emergency response plans. Others expressed concern that the determination risk enables the company to decide what is significant.

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