Top tips to get prepared for an external ESG review
With environment, social and governance (ESG) being a major priority for mining companies around the world, knowing what will be involved in an external ESG review will ensure your operation is well placed to pass the review with flying colours.
External ESG reviews can happen for a number of reasons. The review may be part of a multidisciplinary study aiming to raise finance from lenders or private investors; it may be part of a resource/reserve reporting statement; or it may just be to inform internal decision making. The guidance below aims to help you, the reviewee, be prepared so the process is streamlined and effective.
1. Agree on the assessment criteria to be used for the review
Assessment will almost certainly need to be done against the host country regulatory requirements, but external third parties may wish to see consideration of other international good practice guidelines or standards. There are now a plethora of standards, guidelines and assurance frameworks being used by financiers, insurers, supply chains and industry organisations so it is vital to understand what is going to be used during the review.
2. Establish a well-organised, logical and comprehensive data room
In addition to environmental and social impact assessment reports, monitoring reports and environmental and mining permits, your data room should contain evidence of operational controls, management plans, compliance assessments, third party audits, stakeholder engagement, management reporting and future planning.
3. Ensure commitment/obligation registers are established, comprehensive and up to date
These should not just indicate if the commitment has been met, but provide a linkage to where the evidence in support of this can be found. A robust up to date register is one of the best ways to streamline a review.
4. Have up to date site layout/s available
These site layouts should show project infrastructure (current and planned), monitoring locations, adjacent impact receptors (for example: communities, protected areas, water courses) and surrounding land uses.
5. Give a heads up to your team
Let your health and safety, procurement, security and human resources departments know that they may need to be interviewed as part of the review. Modern ESG assessments cover a much wider scope than just environment and community.
6. Prioritise ESG appropriately
Where the ESG review is part of a multi-disciplinary due diligence, ensure the ESG aspects are not sidelined in favour of geology, mining and processing disciplines, which come easier to most mine managers.
7. Do not limit site visits to the success stories
A thorough reviewer will see through this. If you are open and honest about your challenges, then they can be fairly represented in the review report. If they are hidden or glossed over, then the reviewer will likely be overly conservative and may be suspicious.
8. Talk the language of risk and materiality with the reviewers
They have input into the modifying factors of a resource/reserve statement and/or a project valuation economic model. Costs and schedule delays arising from a number of factors may well end up being material, so the more informed they are, the more accurately they can reflect your project.
9. Stand-up for your beliefs
ESG practitioners often have a broad background and may not be familiar with your site-specific context. If they indicate they are not comfortable with something, question why and, if you disagree, explain your reasons for why you do it your way. Remember, it is okay to disagree with the reviewer and it is important your perspective is acknowledged.
10. Make the most of having a set of independent eyes on your activities
See the review as an opportunity to help achieve continuous improvement, and try to get the best out of the process so you can continue to grow and evolve as an operation and a team.
About the author
Fiona Cessford MSc, FIMMM, CEnv has 30 years’ experience in environment, social and governance (ESG) management. Specialising in the application of good international industry practice, Fiona’s global mining knowledge assists her in communicating ESG risks in a language understood by mine managers, investors, corporate decision makers and other stakeholders. Fiona’s global experience includes ESIAs, permitting, project engineering studies and due diligence studies with reference to relevant financial, industry and globally recognised standards, as well as host country requirements.
A version of this article originally appeared on the SRK website.