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Responsible Gold Mining Principles 2020

The Global Mining Supply Industry is being called to action by mine operators to help create a sustainable mining industry.

See this message by The World Gold Council who has created an industry leading set of 10 sustainability principles including Supplier Conformance, (Principle 3). All other global mining operator institutions will follow this development.

Global Mining Suppliers assists the mining supply and services industry to develop sustainable value to standards, and to message this value to operators and other stakeholders.

Join us to meet mine operator expectations and to make an impact on the value chain of the mining industry

Principle 3: We will require that our suppliers conduct their business ethically and responsibly as a condition of doing business with us.

3.1 We will adopt and publish a Supply Chain Policy and support our contractors and suppliers to operate responsibly and to standards of ethics safety, health, human rights, and social and environmental performance comparable with our own. We will conduct risk-based monitoring of compliance

What has the company done to achieve the intent of the Principles and is there documentary or other evidence to demonstrate this?

  • Develop a Supply Chain Policy and/or Supplier Code of Conduct (or equivalent) that sets out the company’s requirements of suppliers, including ethical, safety, health, human rights, social and environmental standards and expectations
  • Ensure the policy is available on the company’s website and communicated to suppliers either as an appendix included in procurement contracts or a web link to the relevant provisions in procurement contracts
  • Ensure the Supply Chain Policy is readily available for staff to see throughout the business, e.g., via internal communications and intranet, and is particularly visible to procurement teams
  • Put steps in place to ensure small, local suppliers/contractors are not inadvertently excluded from the supply chain due to unrealistic requirements aimed at larger companies. Conduct regular risk-based monitoring and internal audits to ensure current suppliers adhere to this policy and that procurement teams are using this as part of their processes
  • Establish a process for screening and on-boarding potential suppliers
  • For monitoring of existing suppliers, perform periodic risk-based supplier audits, either by the company’s internal auditors or an independent auditing firm, and set up periodic meetings with suppliers/contractors to discuss performance
  • Embed understanding of the Supply Chain Policy/Supplier Code of Conduct with local suppliers by providing periodic briefings and local language translations
  • Establish a disciplinary process in which, if a company observes its supplier not conforming to the company’s Supplier Code of Conduct or committing egregious breaches, the contract is terminated
  • Update the policy as required.

Illustrative assurance provider procedures

  • Validate the existence of the Supply Chain Policy and/or Supplier Code of Conduct and check if it is readily available for review, including on the company’s website
  • Sample procurement contracts to assess if the contracts include references to the requirement of the Supply Chain Policy and/or Supplier Code of Conduct
  • Observe where the Supply Chain Policy is displayed for staff (both on the intranet and physically) and other ways it is communicated with stakeholders
  • Enquire of head office how often the policy is reviewed and if there is evidence of this
  • During site visits, ask procurement teams if they are knowledgeable about the policy
  • Obtain an understanding of the monitoring/internal audit plan and gather evidence that the risk-based monitoring and supplier audits have taken place
  • Review whether measures have been put in place to accommodate local suppliers
  • Confirm that, where appropriate, the Supplier Code of Conduct is translated into local languages
  • Assurance providers should recognise that it may not be possible for an implementing company to deliver on the intent of this Principle in the case of its dealings with State-owned or monopoly providers of infrastructure or utility services.

3.2 We will promote access for local businesses to procurement and contracting opportunities generated by our operations and, where appropriate, provide capacity building support to help them improve their capabilities as suppliers

What has the company done to achieve the intent of the Principles and is there documentary or other evidence to demonstrate this?

  • Establish a policy or procedure aimed at providing a preference for local contracting. * Organise capacity building programmes or local supplier fairs to identify and support promising local companies
  • Ensure that a company’s intention to promote access for local businesses is communicated across relevant company site locations to relevant staff and, especially, procurement teams
  • Engage in collaborative working, where possible, with local/ regional government entities in order to help local businesses access opportunities, e.g., by career workshops
  • Track and disclose externally local contracting numbers/value
  • Develop reporting criteria to ensure consistency across sites in how they record and report on percentage spend used to empower local communities.
  • Please note that context will be important in relation to implementation of this Principle since capacity building may not be as relevant in some developed countries or in areas with a well-established mining sector and associated skills base.

Illustrative assurance provider procedures

  • Perform a process walkthrough with procurement and/or the community or sustainability teams to understand the company’s approach to promoting access for local businesses
  • Request evidence that local businesses are promoted internally as suppliers (i.e., through interviews with procurement included in the Supply Chain Policy)
  • Verify whether internal or external reporting is undertaken to report on these activities and, if so, obtain evidence to verify its accuracy
  • Ascertain whether the company makes available any loans or investment in actual or potential local supplier companies through enterprise development programmes.

3.3 We support access to legitimate markets for those artisanal and small-scale miners (ASM) who respect applicable legal and regulatory frameworks, who seek to address the environmental, health, human rights and safety challenges often associated with ASM activity, and who, in good faith, seek formalization. We will consider supporting government initiatives to reduce and eliminate the use of mercury by ASM

What has the company done to achieve the intent of the Principles and is there documentary or other evidence to demonstrate this?

  • Where relevant, develop a position on supporting access to legitimate markets for legitimate artisanal and small-scale miners where they are operating in proximity to the company’s sites
  • Contribute, where relevant, to national and international dialogue on ASM issues
  • Utilise WGC or other industry association memberships as a platform to share ideas or good practices on ASM issues
  • Support, where practical, well-founded host government and civil society initiatives aimed at improving practices in the ASM sector.

Illustrative assurance provider procedures

  • Where relevant, review the company’s approach, e.g., policies. to support market access for legitimate ASMs, such as helping them to discharge supply chain due diligence requirements or through buying-in programmes
  • Obtain evidence, where relevant, of participation in co-operative activities that support legitimate ASM activities
  • Understand the company’s efforts, where relevant, to support legitimate ASMs
  • If the company has business relationships with ASMs, seek evidence of how they may be partnering and supporting legitimate and responsibly conducted ASM activities
  • Seek evidence of due diligence undertaken into such ASM suppliers in the event of gold production being bought-in, e.g., through the implementation of relevant sections of the Conflict-Free Gold Standard.
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