Audits

1 Oct note: this blog has been edited since it was originally published to add IRMA’s position on “certification” and to increase clarity

An acknowledgment

IRMA acknowledges the continuing frustrations and important concerns raised in a statement by a network of civil society groups in relation to voluntary initiatives and certification systems, and specifically critique of the IRMA Standard for Responsible Mining and its associated independent audit system. We hear loud and clear their concerns that the Standard’s verification and achievement levels, and even participating in the audit process, could enable what some affected communities see as “greenwashing” the impacts of large-scale extraction. While we respond here to the concerns raised, we will respect request of groups in this network to not be named in our response.

IRMA’s Standards seek to reflect the perspectives of all stakeholders and Indigenous rightsholders using an equal, multi-stakeholder governance model. We actively seek out and encourage diverse perspectives from civil society actors as evident through the composition of working groups that aim to ensure that IRMA equally represents all concerned with the impacts of mining and the need to reduce harm. Some in civil society will find use in IRMA’s tools to make mining projects better, reducing negative impacts and increasing benefit sharing, others may reference IRMA’s definition of best practices when resisting mining in a place where Indigenous rights holders and others affected believe the risks and losses are too great. IRMA’s Standards reflect the principles of international conventions such as ILO 169 and the United Nations Decrlation on the Rights of Indigenous Peoples, and also the International Finance Corporation’s expectations that companies demonstrate they have achieved “broad community support” where they do business.

Not a replacement for government oversight

IRMA is a voluntary initiative intended to be used as a tool to offer transparency and accessibility to independently verified information of a mine site’s performance. It is not intended to replace or interfere with government oversight. We agree that no voluntary initiative has enforcement power to hold mining companies financially or legally accountable for infractions. IRMA’s independent audits are meant to provide unprecedented transparency and information about individual mining operations that affected stakeholders and rightsholders can use to demand better mining practices. This also offers opportunity for diverse sectors to differentiate and create greater value for mining companies who reduce harm, increasingly adopt best practices and more equitably share benefits with host communities.

IRMA doesn’t certify

It is important to note that IRMA is not a “certification” system. Although many voluntary standard systems do assign a stamp of approval, IRMA does not. We create and maintain a best-practice mining Standard, and through independent auditing, we report how a mining operation performs against that Standard. An IRMA 50 or 75 isn’t a stamp of approval. Rather, it’s insight into how an independent audit firm decided that the mine scored no lower than either 50% or 75% in the 4 IRMA principles: environmental and social responsibility, business integrity, and leaving positive legacies. Information is power, and power to positively change how mining is done. IRMA is dedicated to ensuring all those affected by mining have the information they need to make informed decisions about the mining that affects them.

Funding

Many voluntary standard systems related to mining are governed and primarily funded by private entities or industry trade associations. Civil society organizations have expressed concern that the motives of mining trade associations may appear in conflict with those whose highest priority is avoiding or minimizing mining’s negative impacts. We seek opportunities to collaborate with mining trade associations as they offer powerful potential to support their members to improve practices – and IRMA will maintain its fundamental commitment to equal governance by affected communities, labor unions, and NGOs working alongside private sector leaders. IRMA’s funding structure does include income from private sector membership fees and special project grants. However, over 50% of our funding is from philanthropic organizations that are passionate about climate justice and an equitable energy transition, including but not limited to the Ford Foundation, Climateworks Foundation, 11th Hour Project and Waverley Street Foundation.

Audits and audit firms

The network’s statement criticizes voluntary initiatives for not requiring surprise/unscheduled audits, expressing concern that mine sites can prepare in advance to clean-up or hide negative aspects of their operations. Auditor firms trained and approved by IRMA conduct an extensive review of documentation (including but not limited to records of site photos and digital files) to make informed decisions regarding compliance with standard requirements. IRMA is the only mining standard that requires public notice of audits before they begin – so that any Indigenous rights holder or other stakeholder may have direct access to auditors, to share their perspectives and concerns. Auditors reach out to stakeholders though various means to hear diverse perspectives, including online comment forms and social media (including WhatsApp), radio announcements, flyers and word of mouth individual outreach. IRMA staff also work to spread the word, including in-person conversations with workers, local community members, and NGO allied organizations.

IRMA acknowledges and shares the concerns regarding the expertise and impartiality of auditors and the auditing companies that employ them. As mentioned in the network’s statement, the reality is that most auditors for the mining sector, to date, have historically been accustomed to assessing mine sites against industry-led initiatives and standards. Affiliates of auditing companies have at times also served mining company clients either directly or indirectly through other means such as technical consulting services. IRMA requires its approved audit firms to follow conflict of interest rules, meet technical and expertise criteria, and draft audit reports are reviewed by IRMA’s Director of Assurance prior to finalization. The first 15 initial audits against the IRMA Standard for Responsible Mining have served and are serving both the IRMA Secretariat and Board, and the audit firms with whom we work, an opportunity to listen, learn and identify ways to improve the process for training of auditors, clarifying requirements in the Standard and improving civil society engagement in the audit process.

Improvement is for IRMA too, not just mining operations

The IRMA Secretariat and Board of Directors appreciate the recommendations from organizations that are critical of voluntary initiatives, and we commit to a practice of continually improving the IRMA system to build the trust, value and confidence for everyone who uses the system. IRMA is currently in the process of acting on civil society recommendations to improve methods for communicating audit report results and accessibility to IRMA’s Issues Resolution System.

IRMA’s approach to supporting more responsible mining encompasses the need to have mining operations be measured against best practices as assessed through the 400+ requirements of the standard. By supporting civil society participation in audits, we work to amplify the right of Indigenous rights holders and other stakeholders who say “No” to a mining operation, and to those who seek reduction of harm, increased access to information, improved benefits sharing and elevating their perspectives at an international level. IRMA firmly believes that through constructive dialogue with all IRMA can be a tool that encourages change that is equitable and inclusive of all perspectives in relation to mining.