On 19th May IRMA hosted the inaugural meeting of its IRMA Law & Policy Forum. Formed in response to requests across IRMA’s six houses, the Forum serves as a regular hub for IRMA Members and Partners to:
share updates related to law and policy frameworks relevant to responsible mining, mineral processing, and mineral value chains;
develop and implement strategies to integrate the best practices in the IRMA Standard into law and policy frameworks; and
inform the IRMA Standards and system, ensuring that IRMA maintains best practice approaches that incorporate relevant international frameworks and standards and reduce duplication in reporting requirements.
IRMA is committed to supporting governments and working across sectors to incorporate the best practices in IRMA Standards into law and policy frameworks. The Forum kicked off with updates on IRMA’s engagement with governments and policymakers across jurisdictions, including an overview of the 10 Key Benefits of IRMA for Governments and Policymakers. We discussed ways that governments around the world, including Indigenous and Tribal Governments, have referenced IRMA, with examples from Australia, British Columbia First Nations and the Union of BC Indian Chiefs, Chile, the European Union, Germany, the United Kingdom, the United States and beyond. We shared ways that we are working with intergovernmental bodies, including to advance implementation of the UN Secretary-General’s Panel on Critical Energy Transition Minerals Guiding Principles and Actionable Recommendations. The IRMA Secretariat also shared updates on IRMA’s first National Level Forum in Indonesia, a multi-stakeholder forum focused on cross-sector engagement and implementation of IRMA in Indonesia.
The remainder of the meeting was a space for IRMA Members & Partners to share their priorities and expertise and participate in a cross-sector discussion of key developments, such as the EU Omnibus package proposing changes to the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).
The Forum will continue to meet on a quarterly basis. It is available to anyone in IRMA Member & Partner organizations working on law and policy and seeking to engage across IRMA sectors to advance IRMA’s Mission and Vision.
The Initiative for Responsible Mining Assurance (IRMA) seeks to be a collaborative partner with governments. Government actors, from intergovernmental bodies to tribal governments and national and subnational government bodies, are key partners in accomplishing IRMA’s mission and vision for responsible mining. IRMA complements, but can never replace, the important role of governments to create and implement robust laws and regulations.
Governments, policymakers, and advocates use the IRMA Standard for Responsible Mining, based on over a decade of global multi-stakeholder dialogue, as a benchmark for internationally recognized best practices and the IRMA system as an avenue to provide market recognition for responsible actors. Governments and policymakers increasingly work with IRMA to incentivize responsible supply chains and enhance trade competitiveness.
Share Your Experience: ISO Workshop on “Sustainable Critical Minerals Supply Chains” 16-17 April, New York City
RSVP with ISO for Virtual or In-Person Participation
IRMA is participating in a series of International Organization for Standardization (ISO) International Workshop Agreement (IWA) 45 sessions focused on “sustainable critical minerals supply chains.” ISO welcomes you to share your experience at the second session of IWA 45 this 16-17 April.
The series, hosted by Standards Australia, explores sustainability tools, guides, and frameworks available to “assist in improving an organization’s sustainability outcomes.” Following a first in-person only session held in Tokyo, Japan, the second IWA 45 session aims to broaden stakeholder engagement, including by enabling both in-person and virtual participation in the New York City session.
The IWA 45 series is important as it will inform the work of the ISO and the national standards bodies of its member countries, including, for example, work under ISO/PC 348 to specify criteria for sustainable raw materials from extraction to final product manufacturing.
As the ISO takes on important work on responsible mining, IRMA restates the importance of inclusive and meaningful multi-stakeholder engagement
On 15-16 February 2024 in Tokyo, Japan, IRMA participated in the first working session of the ISO IWA 45, an international working agreement on “sustainable critical mineral supply chains.” This project is led by Standards Australia (Australia’s national standardization body) under the auspices of the International Organization for Standardization (ISO) and is tasked to “understand the range of sustainability tools/guides/frameworks available which will assist in improving an organization’s sustainability outcomes.” ISO is a quasi-governmental organization dedicated to standard development, headquartered in Switzerland and composed of the national standards bodies of its member countries.
This workshop was an in-person-only event which, while providing constructive opportunity for people to connect directly, dramatically reduced the number and diversity of stakeholders affected by mining and mineral value chains to participate. There were about 45 participants, with a majority from industry (mining and mineral processing) and consultants to the private sector, followed by government delegations (including national standardization bodies and state agencies or research institutions). The most represented countries were the United States, Canada, China, and Japan.
Articulating the perspectives of our members from six houses—affected communities, downstream purchasers, investment and finance, mining industry, NGOs, and organized labor—IRMA worked actively in the session to integrate the perspectives of civil society and organized labor, as those groups were not in attendance. We are concerned about how their absence might leave a significant gap in this process and encourage the event organizers to increase this outreach.
The working session opened with a summary of the results obtained from a preliminary survey circulated by Standards Australia in January 2024. Of the 115 full responses received, two-thirds came from the mining and mineral processing industry, 7% from NGOs, and 7% from academia. Most of the responses originated from China and Canada (over 10%), followed by the U.S., the United Kingdom, Australia, Japan, Germany, South Africa, and Sweden; other countries were all under 3%.
Given the survey feedback was foremost from industry, the main insights shared by the workshop organizer reflected the positions of industry representatives who engaged in the survey, including the “proliferation,” “overlap,” and “inefficiency” of sustainability standards, the “confusion” they would create, and the “burden” created by assurance mechanisms that would be “significant, costly, and time-consuming”.
It is worth noting that IRMA has never heard civil society or mine workers complain that “assurance processes are too expensive,” but rather that they see need for increased investment in transparent sharing of information on performance and for improved practices. We hope that Standards Australia will be able to soon provide a breakdown of the responses by stakeholder groups and increase outreach to civil society, Indigenous rights holders, and labor leaders.
IRMA emphasized throughout the workshop the importance of inclusive and meaningful multi-stakeholder engagement for ISO to ensure robustness and credibility in its processes and its efforts to standardize responsible business practice. A number of other participants similarly asked for more proactive and targeted outreach to all stakeholder groups. The issue of inclusive and meaningful multi-stakeholder engagement was then selected by the organizer as the final topic for plenary discussion.
As currently designed, IWA and ISO processes, including IWA 45, are not inclusive for affected communities, NGOs, and organized labor, and do not allow for meaningful multi-stakeholder engagement. We ask that this fundamental gap be identified as the top priority in the final report that will be produced by Standards Australia this year, including as a key recommendation to inform the other ongoing ISO committees and workstreams on responsible mining and sustainable mineral value chains.
IRMA participated in the United Nations Framework Convention on Climate Change (UNFCCC) 28th Conference of the Parties (COP28) held in Dubai, UAE from 30 November to 12 December 2023. As an admitted UNFCCC Observer for this and future COPs, IRMA participated in COP28 to engage across sectors on issues of importance to our mission and vision, including addressing environmental and social impacts of mining for the energy transition.
An IRMA op-ed leading up to COP28 detailed the need for advocates and policymakers at COP28 and beyond to act quickly to implement robust environmental and social standards for mining, noting that meeting mineral demands for the energy transition requires responsible practices that emphasize transparency, industry-wide standards, and engagement.
This post summarizes IRMA’s participation at COP28, represented by our Law and Policy Director, Kristi Disney Bruckner.
What is COP28?
COP28 was the 28th annual meeting of the UNFCCC Conference of the Parties (COP). The COP meets every year, bringing together governments from almost every country in the world in a multilateral decision-making forum to act on climate. COP28 focused on implementation of the Paris Agreement, include limiting the global temperature increase to 1.5 degrees Celsius, adaptation to climate change, and achieving net-zero emissions by 2050.
Over 100,000 delegates participated in COP28, making it the largest COP to date. Delegates included member states (Parties to the UNFCCC), Indigenous Peoples, scientists, journalists, youth, business leaders, philanthropy, investors, lawyers, academics, and a wide range of other experts.
What was the significance of COP28?
COP28 was significant for many reasons and led to multiple outcomes and commitments. The first Global Stocktake under the Paris Agreement took place at COP28. The Global Stocktake is an assessment of collective progress of Parties to meet Paris Agreement objectives. It indicated Parties are not on track to meet their 1.5 degree target, thus more ambitious action is needed, now. Following a debate around phasing out fossil fuels, Parties agreed in the Global Stocktake to “transition away from” fossil fuels. Parties launched a loss and damage fund for affected communities facing climate impacts. They agreed to triple renewable energy capacity and double energy efficiency improvements by 2030. Parties were encouraged to develop more ambitious, economy-wide emission reduction targets that cover all greenhouse gases, sectors, and categories, aligned with the 1.5 degree Celsius limit. These are to be incorporated into national climate pledges, referred to as Nationally Determined Contributions under the Paris Agreement, by 2025.
On the topic of mining and the energy transition, UN Secretary General António Guterres remarked at the 2nd December G77 + China COP28 Leaders’ Summit that:
“The extraction of critical minerals for the clean energy revolution — from wind farms to solar panels and battery manufacturing — must be done in a sustainable, fair and just way. Demand for these minerals is set to increase almost fourfold by 2030.
At my Climate Ambition Summit, I heard repeated calls from G77 leaders for their countries and communities holding these minerals to fully benefit with maximum local added value. We cannot repeat the mistakes of the past with a systematic exploitation of developing countries reduced to the production of basic raw materials.”
The UN Secretary General then announced that he is establishing a Panel on Critical Energy Transition Materials that will “bring together governments, international organizations, industry and civil society to develop common and voluntary principles to guide extractive industries in the years ahead in the name of justice and sustainability.” IRMA will continue to engage with UN leaders, stakeholders, and Indigenous rights holders to inform this initiative and promote the best practices in the IRMA Standard and system.
IRMA Participation
As IRMA’s representative at COP, Kristi spoke at multiple events, including:
Marrakech Partnership for Global Climate Action Industry Action Event organized by the UN High-Level Climate Champions, Marrakech Partnership, and World Business Council on Sustainable Development, focused on “the transformative levers within the energy and industry sectors, aligned with the Energy and Industry 2030 Breakthroughs and the Sharm el Sheik Adaptation Agenda of the Marrakesh Partnership.” The event provided “a platform for stakeholders to collaborate, share insights, and create strategies to drive these essential changes, charting a course toward a more sustainable and equitable future for all.”
Marrakech Partnership for Global Climate Action Implementation Lab “Enablers to Tripling Renewable Power Generation by 2030 Through a Just, Financed, and Equitable Transition.” This event, organized by the African Export Import Bank, Global Renewables Alliance (GRA), IRMA, and Utilities for Net Zero Alliance, launched a new report by GRA, the COP28 UAE Presidency, and the International Renewable Energy Agency (IRENA) detailing how to increase renewable energy capacity to 11,000 GW by 2030. The panel highlighted IRMA’s work across sectors to improve environmental and social standards in transition mineral supply chains.
Private Adaptation to Climate Change: The Case of the Mining Industry, organized by the Intergovernmental Panel on Climate Change (IPCC), World Meteorological Organization, Philanthropy Cortés Solari through MERI Foundation, and l’Université Côte d’Azur, featured examples of adaptation responses of companies in the mining sector, as well as the importance of cooperation between the public, private, and civil society sectors to ensure private sector adaptation efforts.
Regional Approaches to Financing Just Transition, organized by Ceres and Barclays, explored the need for regional approaches to a just transition and tailored financial strategies for diverse geographical needs to ensure an equitable shift towards a sustainable economy. The panel considered impacts on local communities and Indigenous rights holders and metrics financial institutions can utilize.
IRMA was featured in the UN High-Level Climate Champions Top of the COP Newsletter, noting IRMA’s Call to Action inviting a state-owned enterprise that produces transition minerals to become the first to engage in an independent IRMA audit.
IRMA also participated in meetings organized by Indigenous rights holders, NGOs, business organizations, mining companies, investors, foundations, governments, voluntary standards, law associations, academic institutions, and beyond, expanding IRMA’s network and deepening relationships across sectors.
IRMA is participating in the United Nations Framework Convention on Climate Change 28th Conference of the Parties (COP28) in Dubai, UAE as an Observer and panelist in multiple events, represented by IRMA Law & Policy Director, Kristi Disney Bruckner.
Events include:
5 December 10:00–12:30 GST
Action Arena – Al Hur Room, Blue Zone Marrakech Partnership for Global Climate Action Industry Action Event Taking Stock of Climate Action on Industry and Energy: Accelerating Systems Transformations Click here for livestream
This event, organized by the United Nations Climate Change High-Level Champions, Marrakech Partnership for Global Climate Action, and World Business Council on Sustainable Development (WBCSD) will focus on “the transformative levers within the energy and industry sectors, aligned with the Energy and Industry 2030 Breakthroughs and the Sharm el Sheik Adaptation Agenda of the Marrakesh Partnership. This event will provide a platform for stakeholders to collaborate, share insights, and create strategies to drive these essential changes, charting a course toward a more sustainable and equitable future for all.
IRMA will share a Call to Action, inviting State Owned Enterprises and others to engage in advancing responsible mining of transition minerals in Africa. Contact us at info@responsiblemining.net to inquire about IRMA engagement and available support.
5 December 15:00–16:00 GST
Al Shaheen Room, Blue Zone Marrakech Partnership for Global Climate Action Implementation Lab Enablers to Tripling Renewable Power Generation by 2030 Through a Just, Financed, and Equitable Transition Click here for livestream
This event, organized by the African Export Import Bank, Global Renewables Alliance (GRA), IRMA, and Utilities for Net Zero Alliance, will launch a new report by GRA, the COP28 UAE Presidency, and the International Renewable Energy Agency (IRENA) detailing how to increase renewable energy capacity to 11,000 GW by 2030, including:
Infrastructure and operation;
Policy and regulation;
Supply chain, skills, and capacities;
Scaling-up finance; and
Enhancing international collaboration.
The event will highlight linkages between these key enablers and parallel efforts from IRMA and the Extractive Industries Transparency Initiative (EITI) regarding critical mineral supply chains, the African Export Import Bank regarding the scaling-up of finance, and the Utilities for Net Zero Alliance across all enablers.
5 December 16:15–17:45 GST Science for Climate Action Pavilion, Blue Zone Private Adaptation to Climate Change: The Case of the Mining Industry Click here for livestream
This event, organized by the Intergovernmental Panel on Climate Change (IPCC), World Meteorological Organization (WMO), Philanthropy Cortés Solari through MERI Foundation, and l’Université Côte d’Azur, features examples of adaptation responses of companies in the mining sector, as well as the importance of cooperation between the public, private, and civil society sectors to ensure private sector adaptation efforts.
6 December 10:30–11:30 GST
Chez International Chamber of Commerce Pavilion, Blue Zone Regional Approaches to Financing Just Transition Click here for livestream
This event, organized by Ceres and Barclays, will “explore the regional aspects of a just transition and tailor financial strategies to diverse geographical needs. Global banks must account for local nuances to ensure an equitable shift towards a sustainable economy and this panel hopes to understand what dialogues banks should engage in with clients concerning regional just transition aspects, including the influence of local communities on banks and their portfolio companies, and evaluate the just transition metrics financial institutions can utilize to incorporate regional considerations into their clean energy transition product and service offerings.” RSVP to Ceres is encouraged hereand anyone with a Blue Zone pass may attend.
On 30 Jun, IRMA submitted comments to the American National Standards Institute regarding the DIN ISO Sustainable Raw Materials Proposal. Available here, the introduction is excerpted below:
June 30, 2023
Steven Cornish
ANSI Senior Director of International Policy and Strategy
scornish@ansi.org
We do not think the ISO Sustainable Raw Materials standard as outlined in this proposal is needed because the Initiative for Responsible Mining Assurance (IRMA) is already addressing the gaps identified in the proposal.
Article 29 should specify a certification scheme is not a replacement for a company’s responsibility or for government oversight
Additional criteria for certification schemes in Annex IV including they be equally governed multi-stakeholder initiatives, provide access to a grievance mechanism and require publicly noticed third-party audits that are published in their entirety
Public Information, Rm. 6808
Bureau of Public Affairs
U.S. Department of State
Washington, D.C. 20520-6810 AskPublicAffairs@state.gov
Re: The U.S. and Minerals Security Partnership Should Require IRMA when Selecting a Standard for Critical Minerals Projects
Dear Colleagues,
On January 23rd Jose Fernandez announced that the U.S. and other members of the Minerals Security Partnership (MSP) are carefully selecting a set of critical minerals projects to support and are identifying a set of standards companies and countries will need to meet to receive related assistance.
The U.S. and the MSP should require the Initiative for Responsible Mining Assurance (IRMA) because it is a standard and system equally governed by private and public sectors, unique from industry trade association standards.
IRMA is a multi-stakeholder coalition that brought leaders from diverse sectors together in 2006 to craft the world’s first shared definition of what it means to mine responsibly: the IRMA Standard for Responsible Mining. The IRMA Standard is the result of a comprehensive process spanning more than ten years, including a public consultation process incorporating 1,400 comments from more than 100 different individuals and organizations.
IRMA members include six major automakers, leading jewelers, a wind energy company, mining companies, the world’s two largest global trade unions, leading human rights and environmental advocates, indigenous leaders, leaders of mine-affected communities, and increasing engagement from the investor and finance sector.
Not all standards for the mining sector are equal. Various sets of principles and standards are promulgated by industry trade associations and may identify as multi-stakeholder but do not provide an equal seat at the table for NGOs, affected communities, and labor alongside the private sector. The level of detail in the standards varies widely, as does the quality of assessment and reporting—ranging from company self-reporting with no public reports to independent third-party audits resulting in transparent public reports. Local stakeholders and rights holders may or may not know in advance that an assessment will occur or even be provided with an opportunity to share their experience and opinions.
IRMA stands out from industry trade association standards because it is recognized across stakeholder sectors and has already been recognized by multiple MSP members. The United Kingdom’s 2022 Critical Minerals Strategy references IRMA as a globally recognized framework for responsible mining.[1] In 2021, the White House referenced IRMA in its 100-Day Review on Building Resilient Supply Chains, noting that IRMA is a possible “method for U.S. companies and the Federal Government to ensure that minerals are being sourced from mines with robust environmental, social, and financial responsibility practices.”[2] The European Parliament referenced the IRMA Standard in its 2021 strategy for critical raw materials.[3] The Government of Australia called IRMA a “no regrets approach” in its 2020 study of certifications and strategies to increase competitiveness of Australian battery materials for use in the EV sector in Europe.[4]
IRMA is the only standard for the mining sector that fully embodies the Biden Administration’s environmental justice goals. This is because IRMA is the only standard for the mining sector that:
is equally governed by directly affected communities, NGOs, labor unions, mining companies, purchasing companies, and the investor and finance sector;
requires public notice in advance of an audit so that local stakeholders and rights holders can prepare to engage in the audit;
is applicable globally and covers all mined materials (apart from thermal coal, uranium, and deep seabed mining projects);
includes the full range of environmental and social issues related to industrial-scale mines;
requires detailed public reports made available at no cost to the public, with scoring and rationale on over 26 topics across over 400 requirements; and
has demonstrated credibility with civil society and labor unions.
IRMA is built on best practice norms. Existing international systems and frameworks form the basis of requirements in the IRMA Standard and are assessed in IRMA audits. These include but are not limited to the Extractive Industries Transparency Initiative (EITI), the International Cyanide Management Code, International Finance Corporation (IFC) Performance Standards, International Labour Organization Conventions, International Union for Conservation of Nature (IUCN) Protected Area Management Categories, the Minamata Convention on Mercury, OECD Due Diligence Guidance, UNESCO Biosphere Reserves, the United Nations Guiding Principles on Business and Human Rights, and the Voluntary Principles on Security and Human Rights.
IRMA requires completion of an independent third-party audit before any public claims may be made related to IRMA achievement. The IRMA system enables companies to clearly communicate their performance across a holistic set of best practices and work toward continuous improvement in environmental and social responsibility.
IRMA’s equal governance model upholds a standard and system that creates confidence and value across all stakeholder sectors and greater trust across supply chains. The U.S. and MSP should support and incentivize the IRMA Standard and system because of its unique accountability to all sectors and alignment with the MSP’s commitment to “adhere to the highest environmental, social, and governance standards.”[5]
[4] UTS Institute for Sustainable Futures and the University of Melbourne, Certification and LCA of Australian Batter Materials – Drivers and Options: Scene Setting Project Prepared for Future Battery Industries CRC, Future Battery Industries CRC, Australian Government Department of Industry, Innovation and Science Business Cooperative Research Centres Program, August 2020, https://fbicrc.com.au/wp-content/uploads/2020/10/Certification-of-Au-Battery-Materials-WEB-INTERACTIVE-SEPT-2020.pdf.
At the invitation of Indonesia’s Coordinating Ministry for Maritime and Investment Affairs, IRMA participated in a series of meetings held September 5-9 in Jakarta to introduce the IRMA Standard and system to a wide range of sectors with interest in mineral development and processing. Represented by Senior Policy Advisor Kristi Disney Bruckner, the meetings occurred following requests from members of IRMA’s Buyers Group for engagement in Indonesia, calling on mine sites to complete independent, third-party audits.
Indonesia’s Coordinating Ministry for Maritime and Investment Affairs, EITI Indonesia, Eramet, and others collaborated to host a full-day Introducing the Initiative for Responsible Mining Assurance (IRMA) to Indonesian Mining Companies forum on September 6th. Over 140 participants attended the event, including representatives of more than 25 companies with experience in nickel, aluminum, steel, coal, and other sectors. Participants also included representatives of the Ministry of Energy and Mineral Resources, Environment and Forestry, Finance, and Investment; the National Standardization Agency; state-owned enterprises; French and U.S. Embassies; and NGOs Publish What You Pay, Action for Ecology and People Emancipation (AEER), and others; media; consultants; academics; investors; and purchasing companies. Speakers at the event included representatives of Eramet, IRMA, the Coordinating Ministry for Maritime and Investment Affairs, the EITI Secretariat, and Ørsted.
IRMA participated in a separate NGO Roundtable on September 7th, attended by Publish What You Pay, Keanekaragaman Hayati (Indonesian Biodiversity Foundation), Yayasan Konservasi Alam Nusantara (Indonesian Nature Conservation Foundation, YKAN), Auriga Nusantara, World Resources Indonesia, Peduli Konservasi Alam (Movement for Nature Conservation, PEKI), Konservasi Indonesia (Conservation Indonesia), Wetlands International Indonesia, and AEER.
IRMA also held ad hoc meetings throughout the week with representatives of NGOs, government, and companies.
Indonesia is a major producer of nickel and other materials needed for EVs and is key to the energy transition. The recent history of mining in Indonesia includes environmental harm and human rights violations, particularly in Papua Province. Addressing those harms, preventing future harm, and ensuring equitable distribution of benefits requires responsible management of the mining sector.
The Indonesian government’s invitation and its completion of a gap analysis between the country’s legal framework and the IRMA Standard for Responsible Mining signal recognition of the IRMA Standard as a model to capture the increasing market value of environmental and social responsibility. IRMA is a tool available to all Indonesian stakeholders–government, NGOs, affected communities, organized labor, mining companies, purchasing companies, and investors–to promote more responsible environmental and social management in the mining sector. IRMA’s engagement in Indonesia supports efforts to improve governance of the mining sector and bring Indonesian mines into IRMA’s independent, third-party audit and transparent reporting process. These steps can promote good governance from national to mine site levels, benefitting diverse stakeholders and rights holders in Indonesia.
Regional Approaches to Financing Just Transition
