Barbara Strozzilaan 101
1083 HN Amsterdam
The Netherlands
gssbsecretariat@globalreporting.org

Item 05 – GRI Sector Standard
Project for Mining - Draft Basis forConclusions for GRI 14: Mining

Sector 2024
For GSSB review and discussion
Date

23 November 2023

Meeting

14 December 2023

Project

Sector Standard Project for Mining

Description

This document summarizes the significant issues raised by respondents about the
exposure draft of the Mining Sector Standard during the public comment period
held from 7 February to 30 April 2023. It also outlines the draft GSSB responses
to the significant issues based on discussions and recommendations by the
Mining Working Group.
The GRI Standards Division has prepared this draft, which will be updated, as
needed, based on GSSB feedback to the final Standard. The draft is circulated for
the GSSB for review and discussion. A final version of this document will be
released following the approval of GRI 14: Mining Sector 2024.
As outlined in the Due Process Protocol, this document is not subject to voting
approval, it does not constitute part of the final Standard, and is non-authoritative.
The full set of comments can be downloaded from the project page on the GSSB
website.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. The
GSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2023

Contents
Contents .................................................................................................................................................. 2
About this document ............................................................................................................................... 3
Introduction ............................................................................................................................................ 3
Objectives for the development of GRI 14: Mining Sector 2024 ......................................................... 3
Scope of the public comment .............................................................................................................. 3
Overview of participation in public comment ....................................................................................... 4
Methodology for analyzing comments ................................................................................................. 5
Significant issues and GSSB responses ................................................................................................. 6I.

General feedback ........................................................................................................................ 6

II.

Issues regarding specific sections of the exposure draft .......................................................... 11

Appendix 1. Participation in events and webinars ................................................................................ 23
Appendix 2. Overview of respondents .................................................................................................. 24

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1

About this document

2
3
4
5

This document summarizes the significant issues raised by respondents about the exposure draft of
the Mining Standard during the public comment period held from 7 February to 30 April 2023. It also
outlines the draft GSSB responses to the significant issues based on discussions andrecommendations by the Mining Working Group.

67
8

The document incorporates comments received through the public comment form hosted on the
Sector Standard Project for Mining webpage and feedback submitted by email. Where relevant, it also
references comments made at stakeholder workshops held during the public comment period.

9
10
11

All comments received, together with an analysis of the issues raised, were considered by the Mining
Working Group. The recommendations of the working group were shared with the Global
Sustainability Standards Board (GSSB) for review and approval.

12
13This document provides a summary of the GSSB responses to the significant issues raised during the
public comment period.

14

The full set of received comments can be downloaded from the project page on the GSSB website.

15

GRI 14: Mining Sector 2024 can be downloaded [here].

16

Introduction

17

Objectives for the development of GRI 14: Mining Sector 2024

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19

The project proposal for a Mining Sector Standard was approved by the Global Sustainability
Standards Board (GSSB), GRI’s independent standard-setting body, at its meeting on 17 June 2021.

20
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In November 2020, the GSSB approved the list of sectors prioritized for the development of a GRI
Sector Standard. Mining was included in Group 1, and is the first Standard to be developed after thepilot projects. Prioritization was based on the significant impacts of mining activities on people and theenvironment, and the synergies with the already developed Sector Standards GRI 11: Oil and Gas
Sector 2021 and GRI 12: Coal Sector 2022.

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29

The primary objective of the Sector Standard is to improve the sustainability reporting of mining
organizations, enabling more complete and consistent disclosure across the sector. GRI 14: Mining
Sector 2024 identifies and describes the topics that are likely material for a reporting organization in
the mining sector, provides a list of relevant disclosures for reporting on those topics, and includes
evidence and authoritative references to evidence the sector’s impacts.

30
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33

The project followed the GSSB Due Process Protocol. Proposed revisions to the exposure draft of the
Mining Sector Standard were discussed with the working group during a two-day in-person meeting in
June, and two consecutive virtual meetings. Feedback on the exposure draft was also discussed with
the GSSB in its September 2023 meeting.

34

Scope of the public comment

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The exposure draft of the Mining Sector Standard was open for public comment from 7 February to 30
April 2023.

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The public comment period aimed to solicit input on the clarity, feasibility, completeness, andrelevance of the draft Standard in relation to the impacts associated with the sector, accurateness of
likely material topics, and the relevance and feasibility of the reporting disclosures linked to those
topics. Specific attention was given to the granularity of reporting, particularly where mine-site data isrequested. Feedback was solicited whether mine-site level data for the proposed topics is feasible fororganizations to report, and whether it would produce relevant information for information
users. Efforts were made to support representation from key regions/markets for the sector, key

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44
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stakeholder groups, and specific areas of expertise. Outreach activities included webinars, in-person
workshops, briefings, and individual stakeholder consultations. The complete series of engagements
during the PCP reached approximately 1,500 stakeholders.

47
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49

Comments collected during PCP activities such as workshops or webinars, though not considered
official public comment submissions, were also taken into account when they aided understanding of
the official submissions or flagged a significant issue that was not raised in the official submissions.

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Any comments outside the scope of this public comment were compiled and directed to theappropriate teams. Along with the developing Sector Standards, the GRI Sector Program supports theenhancement and expansion of the GRI Standards by surfacing issues not previously covered by the
GRI Standards. Feedback on Topic and Universal Standards received during PCP and the Standard
development process has been collated and published separately [link].

55

Overview of participation in public comment

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Respondents were asked to submit comments on the exposure draft using an online survey. The linkto the survey was made available on the Mining project page. Respondents could also submit
additional feedback via email to mining@globalreporting.org.

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A total of 93 public submissions from individuals and organizations were received on the exposure
draft. See Figure 1 and Figure 2 for a breakdown of submissions by stakeholder constituency andregion. Submissions were received from all five stakeholder constituencies represented by the GSSB:
business enterprises, civil society organizations, investment institutions, labor, and mediating
institutions. In this PCP, mediating institutions comprised consultants, academics, standards setters,
governments, multilateral organizations, lawyers, and assurance providers, representing close to halfof the submissions. Submissions were received from 40 countries across five continents.

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Figures 1 and 2. Breakdown of the submissions received by constituency and geographic
region:Global4%

Other Labor
1%
Investor 2%
6%

Africa9%

Civilsociety
12%

Business
28%

Oceania10%Mediatinginstitution
51%

North
America
12%Europe
23%

Asia
22%
Latam
22%

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For more details on the submissions received, see:•••

The full set of comments on the Mining project page.
Appendix 1 for a list of stakeholder events and an overview of participation.
Appendix 2 for an overview of respondents.

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72

Methodology for analyzing comments

73

The Standards Division collated all comments submitted by respondents.

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Each comment was categorized according to the public comment objective it responded to, therelevant section of the Standard, and an overarching theme, where relevant. If a respondent raised
several different points in one comment, the points were separated as distinct comments.

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The qualifiers in Table 1 indicate the percentage of respondents who provided feedback on
a significant issue. However, as the Sector Standards cut across all dimensions of sustainable
development, covering 25 topics, individual PCP submissions tend to result in more targeted
feedback. The survey asked mostly open questions to encourage respondents to provide feedback on
sections relevant to their interests and/or expertise, with respondents often focusing their comments
on a specific topic or set of topics in the exposure draft. Consequently, many sections or disclosures
have fewer comments relative to the overall number of respondents, although often from highly
specialized organizations.

85

Table 1. Qualifiers indicating the percentage of respondents who provided feedback
QualifierRespondents

Majority> 50 %

Many

30-50%

Some

10-30%A few< 10 %

One

1

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87

Significant issues and GSSB
responses

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In line with the GSSB Due Process Protocol, this section summarizes the significant issues raised byrespondents during the public comment period, outlines proposed changes to the exposure draft of
the Mining Sector Standard, and explains why significant changes suggested by respondents were orwere not accepted by the GSSB.

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The issues included in this document are either significant themes raised by a large number of
respondents or issues that were brought up by a few respondents but led to a significant change in
the Standard. Other minor and editorial comments were received and actioned but are notsummarized here.

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This document includes references to the exposure draft of the Mining Sector Standard and the final
version of GRI 14: Mining Sector 2024. The names of the sections and likely material topics, as they
were in the exposure draft, are used to organize the significant issues and when describing feedback.

99

Identified significant issues have been organized into the following sections:

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100

I.

General feedback and cross-cutting themes

101

II.

Issues regarding specific sections of the exposure draft

102

I. General feedback

103a) Scope of Sector Standard

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The proposed scope of the Standard as laid out in the exposure draft, covering exploration (including
quarrying), extraction, and primary processing of minerals, as well as the provision of specialized
products and services and support activities, was welcomed by the majority of respondents. A few
respondents suggested expanding the scope to include further minerals and metals processing, suchas refining and smelting, due to the significant impacts of these activities, especially on emissions.

109
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111

A few respondents raised concerns over whether the topics and disclosures would be applicable toexploration companies. A few others asked to clarify or emphasize that the scope covers specificminerals, such as sand, cobalt, lithium, magnesium, potash, and uranium.

112

GSSB response:

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While the scope of GRI 14 does not explicitly cover further mineral processing – such as smelting or
refining – this does not prevent mining organizations with such activities in their core operations toreport on these impacts.1 Further, GRI 3: Material Topics 2021 sets expectations to identify and report
most significant impacts across the organization’s value chain. For emissions accounting, GRI 14
includes reporting on other (indirect) Scope 3 emissions, including from further processing of minerals
and metals.

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The Sector Standard scope covers all minerals raised by respondents, as signaled in the Sector
Standard ‘Table 1 Industry groupings relevant to the mining sector in other classification systems’.
Whereas the other minerals were explicitly mentioned in the Standard, the exposure draft included noreference to uranium. A mention to uranium was added into the section ‘Sector Profile’, along with a
Bibliography reference to International Atomic Energy Agency (IAEA), Safety Standards and World
Nuclear Association best practices.

1 A dedicated Sector Standard is planned for metal processing, scheduled in the GSSB work program for 2025.

Organizations with activities in mining and metal processing are expected to use both Sector Standards.

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125b) Mine-site reporting

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Due to the significance of impacts related to mining activities at the local level, the exposure draft
included several sector-specific recommendations to report disclosures at the mine-site level.

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Many respondents – almost exclusively information users2 – stated that mine-site-level reporting
would be essential to understanding a mining organizations’ impacts for the topics listed in the
exposure draft. These views were corroborated throughout engagements during the public comment
period. The reasons given included fulfilling expectations for information from affected stakeholders;building trust and enhancing engagement; accurately representing impacts and risk profiles
associated with locations, operations and minerals; and incentivizing performance improvements
across all sites. A few respondents recommended that asset-level disclosure would be relevant toalso include for topics 14.4 Biodiversity, 14.5 Waste, 14.7 Water and effluents, 14.12 Security
practices, and 14.15 Occupational health and safety.

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Some organizations – mostly reporting organizations – raised concerns about the extent of site-level
reporting in the exposure draft. Many reporting organizations stated that mine-site data is commonly
collected on the topics listed, but public reporting of the data would pose challenges or not be
feasible. The reasons given included reports becoming too lengthy, losing focus over critical impacts
and actions; difficulty or effort of collecting or reporting data; lack of resources; and businesssensitivity of certain data. A few claimed site-level information is not used by local communities, andthat site-level disclosure would not contribute to comparability of reported data. A few respondents
pointed out that operations have different material impacts and interest groups, requiring disclosures
to be considered for each operation as company-level risks may not be relevant locally. It was
acknowledged that reporting granular data would require investment into building internal systems.

147
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149

A few respondents raised concerns over the lack of a disclosure to inform where an organization’smine sites are located and what their size is, which hinders external stakeholders in their assessmentof risks and impacts relevant to an organization. The definition of a mine site was also requested.

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GSSB response:

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In line with the public comment feedback from information users, there are increasing expectations
set out by intergovernmental organizations and recognized sector organizations focusing on mine-sitelevel management and disclosure of how mining activities impacts people, economies, and theenvironment at a local level. The current practice of aggregating and reporting sustainability data at acompany level is not seen as allowing sufficient scrutiny into the key impact areas of mining, nor theactions taken to address them.3 In addition to the stakeholder groups identified through the publiccomment period, customers of mining organizations, local communities, and (future) workers havebeen identified as stakeholder groups with a keen interest in site-level data.4

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Furthermore, several GRI reporting principles in GRI 1: Foundation 2021 stipulate organizations
should report information ‘that is correct and sufficiently detailed to allow an assessment of theorganization’s impacts’ (Accuracy); report information ‘in a concise way and aggregate information
where useful without omitting necessary details’ (Clarity); and ‘if operating in a range of locations,
report information about impacts in relation to appropriate local contexts’ (Sustainability context). The

2 The respondents supportive of including mine-site reporting included civil society organizations, academics,

investors, consultants, standard-setters, benchmark organizations, development organizations, assurance
providers, lawyers, think tanks, and governments.
3 See, for example, United Nations Environment Programme (UNEP), Sustainability Reporting in the Mining

Sector, 2020; International Energy Agency (IEA), The Role of Critical Minerals in Clean Energy Transitions, 2021;
Responsible Mining Foundation (RMF), RMI Report 2022, Summary, 2022; Fonseca, A., McAllister L.,
Fitzpatrick, P., Sustainability reporting among mining corporations: a constructive critique of the GRI approach,
Journal of Cleaner Production, 1-14, 2012.
4 UNEP 2020, RMF 2022.

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additional sector recommendations are thus well aligned with the approach and principles of the GRI
Standards.5

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While the inclusion of mine-site reporting recommendations might translate into increased volume ofreported data, this data serves many different purposes and stakeholder groups. The responses alsosuggest that data for the topics suggested for site-level reporting in the exposure draft is alreadycommonly collected by mining organizations. Regarding the volume of information, manyorganizations publish spreadsheet data books, which is found as an efficient and practical way topublish information.

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As to concerns over relevance of information or losing focus over critical impacts and actions,
reporting in accordance with the GRI Standards requires each organization to determine their material
topics based on their own specific circumstances. An organization should prioritize reporting on those
topics that represent the organization’s most significant impacts on the environment, economies, andpeople, including their human rights. Similarly, when determining disclosures to report, anorganization should report those disclosures that are most relevant for its impacts and circumstancesin relation to each topic it has determined as material to report. This applies for site-level disclosures
as well (which are recommendations, not requirements, to be in accordance with the GRI Standards)6.

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The GRI approach, based on materiality, offers flexibility for organizations to build towards thereporting expectations over time. Due to the broad stakeholder demand for asset-level information,
the existing mine-site recommendations in the exposure draft were retained, with additional site-level
expectations introduced for the topics of biodiversity, waste, and water, due to the severity andlikelihood of local impacts.

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New mine site disclosure

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The GRI 14: Mining Sector 2024 introduces a new disclosure recommendation to report the name ofeach mine site, geographic location, and the size in hectares. This disclosure also includes a footnote
that defines a mine site in the Sector Standard.

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The disclosure (REF 14.0.1) is placed at the start of the section ‘Likely material topics’, not affiliatedwith any specific topic. In practice, the disclosure would be reported by any organization that owns oroperates mine sites. The reported information can be used to inform assessment of risks and impacts
for several topics.

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The disclosure is accompanied by an example table that organizations can use to indicate which sites
have significant impacts related to the topics in the Sector Standard. This will also address feedback
from reporting organizations about the utility for organizations to be able to signal material topics anddisclosures per location or operation.

197c) Materiality and additional sector reporting

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A few respondents raised concerns over the requirement to explain why a topic is not material, which
was seen as adding to the reporting burden.

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A few respondents asked for clarification between ‘additional sector disclosures’ and ‘additional sector
recommendation’.

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A few respondents raised concerns over the fact that sector-specific disclosures are not mandatory
and lack guidance, as these disclosures were often seen as representing critical impacts for thesector.

5 This approach is similarly in line with the reporting requirements in the European Sustainability ReportingStandards (ESRS) E1, which states that ‘When needed for a proper understanding of its material impacts, risks
and opportunities, the undertaking shall disaggregate the reported information:(a) by country, when there are significant variations of material impacts, risks and opportunities across countries
and when presenting the information at a higher level of aggregation would obscure material information about
impacts, risks or opportunities; or(b) by significant site or by significant asset, when material impacts, risks and opportunities are highly dependent
on a specific location or asset.’
6 See GRI 1: Foundation 2021 for in accordance requirements.

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205

GSSB response:

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The Sector Standard offers a well-researched resource depicting the significant impacts related tomining activities. As outlined in GRI 1: Foundation 2021, an organization uses applicable Sector
Standards as an input to its materiality process, with an expectation to review the topics listed in theStandard and determine which ones are material based on its specific impacts and circumstances.
Topics that are determined as not material are listed in the GRI content index with an explanation for
why they are not material (see GRI 1: Foundation 2021, Requirement 3). This additional level ofaccountability is seen as critical to avoid ‘box-ticking’ and instead focus reporting on the mostsignificant impacts. Reporting a reason for why a topic is not material is unlikely to pose unreasonableadditional work for organizations.

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Disclosures demarcated as ‘additional sector recommendations’ are intended to give additional
information about a sector’s impacts related to an existing Topic Standard disclosure, whereas‘additional sector disclosures’ give information about a sector’s impacts where the disclosures fromthe Topic Standards do not provide sufficient information about the organization’s impacts. Thisdistinction was clarified in Figure 2 in GRI 14.

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While reporting the additional sector recommendations or disclosures is not required to be inaccordance with the GRI Standards, Requirement 5 in GRI 1: Foundation 2021 states that an‘organization should provide sufficient information about its impacts in relation to each material topic
so that information users can make informed assessments and decisions about the organization’.
Should the disclosures from the Topic Standards not provide sufficient information about theorganization’s impacts, it should report additional disclosures. The additional sector reporting,recommended in the GRI Sector Standards, have been developed for this purpose.

227d) Gender

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Some respondents suggested reinforcing the representation of impacts of mining on gender and onother groups in situations of vulnerability. A few also found the exposure draft lacked a holistic
representation of how mining activities impact women and other marginalized members ofcommunities. The standard was perceived as not adequately capturing impacts of mining on different
genders, nor achieving an appropriate representation of key women's rights issues such as unpaid
care work or gender-based violence. Respondents also raised that the exposure draft did not
sufficiently cover the need for gender-disaggregated information for many of the likely material topics.

235

This feedback was corroborated by feedback received during public comment engagements.

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In total, proposals to include gender-disaggregated data were made for 14 likely material topics in theStandard, ranging from economic impacts, to water, and conflict-affected and high-risk areas.

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GSSB response:

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Gender was found to be an important issue for the mining sector and is discussed in the context ofseveral topics in GRI 14. Instead of a standalone topic for gender, the Standard includes content on
gendered impacts in relevant topics and reporting, including recommendations for genderdisaggregated data.

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In summary, the following modifications to strengthen the Standard’s gender perspective were
implemented in the final draft of the Mining Standard:

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•

•
•

Box 1 ‘Gender in mining’ was included in the Sector profile section to illustrate gender-specificimpacts as a contextual issue for the sector, to elaborate how gender impacts can be better
captured by organizations through, for example, gender-specific human rights due diligence andexpanding the need for gender-disaggregated data;
Contents related to gendered impacts from mining were added into 13 topic descriptions, basedon public comment feedback and supported by authoritative references;
Reporting recommendations with gender considerations or gender disaggregation were added
where the impacts are sector-specific or occur in an outsized manner in the sector (topics listed
below).

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Additional reporting was only included for those instances where impacts were found to be highly
sector-specific, and when the relevant Topic Standard Disclosures did not already require data with abreakdown by gender.

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261
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263

•
•
•
•
•
•
•

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More information about the specific additions in the reporting sections of these topics can be foundbelow in Section II Issues regarding specific sections of the exposure draft.

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Some respondents emphasized collaboration and alignment with other existing reporting standards
and frameworks. Respondents highlighted the need for efficiency and comparability of reporting andunderstanding where overlap and alignment exist. A few called for alignment with andacknowledgment of organizations’ implementation of various sector-relevant performance standards
and site-level certification schemes.

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GSSB response:

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The Sector Standard contains sector-specific disclosure recommendations, which draw, as much as
possible, from external sources and frameworks already used by the sector. For example, thedisclosures in topic 14.6 Tailings are aligned with the Global Industry Standard for Tailings
Management; the disclosures in topic 14.12 Land and resource rights draw from the IFC PerformanceStandard 5 Land Acquisition and Involuntary Resettlement; the disclosure in the topic 14.20 Freedomof association and collective bargaining aligns with the SASB Metals and Mining Industry Standard;
and the disclosures in topics 14.23 Payments to governments and 14.22 Anti-corruption have beenaligned with the Extractive Industry Transparency Initiative EITI Standard 2023. Other reporting
sections refer to principles or guidelines recognized in the sector, such as the Voluntary Principles for
Security and Human Rights in topic 14.14 Security practices and the OECD Due Diligence Guidancefor Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas in topic 14.25
Conflict-affected and high-risk areas.

Topic 14.9 Economic impacts
Topic 14.10 Local communities
Topic 14.11 Rights of Indigenous Peoples
Topic 14.12 Land and resource rights
Topic 14.13 Artisanal and small-scale mining
Topic 14.16 Occupational health and safety
Topic 14.21 Non-discrimination and equal opportunitye) Alignment and harmonization

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286

II. Issues regarding specific sections of the exposure draft

287

Topic 14.1 GHG emissions

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GHG emissions was the third most commented topic in the Standard, partly due to the inclusion of
two questions around Scope 3 emissions reporting at the site level. The majority of PCP respondents
supported the inclusion of an expectation to report other indirect (Scope 3) emissions for the mining
sector. While reporting organizations expressed feasibility concerns, such as difficulties in datacollection or lack of guidance on methodologies and calculations, it was acknowledged that Scope 3
emissions reporting is becoming mainstream and expected in many other reporting instruments (e.g.,
ISSB, ESRS).

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Feedback was also solicited on the need and feasibility to report Scope 3 emissions at the mine-sitelevel. Many information users supported site-level reporting of these emissions. However, the majorityof reporting organizations opposed it, arguing that information on Scope 3 emissions is not generallycollected at a mine-site level.

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300

A few respondents questioned the inclusion of a mine-site recommendation to disaggregate Scope 1
and Scope 2 emissions data on the basis that impacts from climate change do not manifest locally.

301

GSSB response:

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305
306

As proposed in the exposure draft, the Disclosure 305-3 Other indirect (Scope 3) GHG emissions will
be maintained in the Topic 14.1 GHG emissions, without a mine site recommendation, due toconcerns over the quality of information. This inclusion represents a step forward for emissions
reporting, as it is not yet a widespread practice for mining organizations to publicly disclose thisinformation.

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The recommendations to report site-level information for Scope 1 and 2 GHG emissions wereretained to allow information users to assess how specific sites contribute and take actions to manage
emissions from their operations. It was also noted by some mining organizations that this informationis already collected on a site level for internal and/or corporate reporting purposes.

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A few business respondents recommended stronger alignment with the recommendations from theTaskforce for Climate-Related Financial Disclosures (TCFD), including with terminology in disclosure
14.2.1 around organizational resilience to temperature scenarios ‘including a 2°C or lower scenario’.

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A few respondents called for a disclosure on adaptation plans that contains clearer expectations forreporting (14.2.1).

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A few respondents considered recommendation 14.2.2 to Disclosure 201-2 Financial implications andother risks and opportunities due to climate change to not be clear in its focus toward impact
materiality as it could lead to reporting on climate risks to the organization’s economic value.

321

GSSB response:

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In light of the ongoing Topic Standards Project for Climate Change to revise GRI’s sector-agnostic
climate-related disclosures, the feedback received regarding alignment with TCFD, guidance and forreporting on adaptation plans, as well as the urge for impact-focused reporting on climate change, will
be considered as input in the development of the Climate Change project.

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Recommendation 14.2.1 was more closely aligned with wording from the Paris Agreement, and thelatest scientific evidence from the IPCC7, by including ‘a well-below 2°C, preferably 1.5°C, scenario’.

328

Topic 14.3 Air emissions

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A few respondents, especially reporting organizations, raised concerns over the relevance of thepollutants listed under the recommendation to Disclosure 305-7, including nitrogen oxides (NOx),sulfur oxides (SOx), and other significant air emissions (14.3.2). Respondents argued that not all of

Topic 14.2 Climate adaptation and resilience

7 Intergovernmental Panel on Climate Change (IPCC), Sixth Assessment Report—Working Group 1 Contribution,

2021.

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the listed pollutants are relevant or applicable to all types of mining or to all mine sites; that many
naturally occurring emissions are challenging to estimate; and that the site-level recommendation
could pose challenges, especially in the absence of further guidance and methodology.

335

GSSB response:

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The exposure draft included a recommendation (14.3.2) for mining organizations to report hydrogencyanide, mercury, PM10 and PM2.5, carbon monoxide, ground-level ozone, and hydrogen sulfide
emissions for all mine sites, in addition to the significant air emissions listed in the Topic Standard
disclosure 305-7. This list of pollutants was removed, and the recommendation was modified to‘report all significant air emissions relevant to each site’. A footnote was included to provide moreguidance for reporters, outlining the most common air emissions in the sector (mercury, particulatematter, hydrogen sulfide, etc.). This allows organizations in the sector to determine and report thepollutants relevant for each of their sites, rather than a prescribed list that may not be universally
applicable.

347
348

A few respondents raised concerns over the exposure draft for mining incorporating biodiversity Topic
Standard disclosures that were still in draft form.

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351
352

A few respondents raised concerns over the lack of site-level disaggregation for the draft biodiversity
disclosures. They argued that reporting this data for all mines and facilities would make reporting
more equal, more consistent, and more relevant for all operators while also reducing organizations’burden of determining and justifying which sites have the most significant impacts on biodiversity.

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356

Another respondent suggested expanding reporting so that organizations disclose the coordinates
and area in hectares for all of their operated mines, assets, and tailings. This would allow a better
understanding of the spatial extent of a mining operation and would allow information users tounderstand how potential impacts can manifest.

357

GSSB response:

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361
362

To ensure that reporters in the mining sector, which has significant impacts on biodiversity, are set toreport on their biodiversity impacts with the most up-to-date disclosures, the exposure draft for mining
incorporated the exposure draft biodiversity disclosures to identify additional sector-specific gaps. The
revised Topic Standard for Biodiversity (GRI 101) was approved consecutively with GRI 14, reflecting
the global best practice on transparency over biodiversity impacts.

363
364
365
366
367
368
369
370
371

Seven out of the eight disclosures from GRI 101: Biodiversity 2024 were incorporated in the Mining
Standard, with Disclosure 101-3 Access and benefit-sharing not considered relevant for the sector.
Sector-specific recommendations were added to disclose information at the site level to four
disclosures (14.4.5, 14.4.6, 14.4.7, and 14.4.8). While the sector-agnostic disclosures require
reporting on operational sites ‘with the most significant impacts on biodiversity’, it was deemednecessary to include a recommendation to report information on ecologically sensitive areas in ornear operations, direct drivers of biodiversity loss, changes in the state of biodiversity, and information
on ecosystem services for all mine sites. This will also simplify reporting for mining organizations by
avoiding the need to assess and contrast which sites most contribute to biodiversity loss.

372
373
374
375

Feedback on reporting spatial information of all mine sites was addressed in the newly developed
disclosure 14.0.1, where organizations should report the name of the mine site, its geographic
location, and its size in hectares. Further information on the inclusion of additional sector disclosure
14.0.1 can be found in chapter b) Mine-site reporting of this document.

Topic 14.4 Biodiversity

Page 12 of 26

376

Topic 14.5 Waste

377
378
379
380

A few respondents indicated mine-site level reporting being critical for the topic of waste. Specifically,
the breakdown of the composition of waste by rock waste and tailings included in recommendations
14.5.4, 14.5.5, and 14.5.6, as well as the amount of waste generated, were seen as crucial data
points to understanding local impacts from waste.

381

GSSB response:

382
383
384
385

Recommendations to disclose information at the site level were included in the quantitative
disclosures 306-3 Waste generated, 306-4 Waste diverted from disposal, and 306-5 Waste directed
to disposal. This information is commonly collected by organizations at the site level in order toproduce an aggregate figure and is not expected to pose a major challenge for mining organizations.

386

Topic 14.6 Tailings

387
388

Tailings was one of the most commented topics, prompted by two dedicated questions in the PCPquestionnaire.

389
390
391

Some respondents urged closer alignment with the Global Industry Standard on Tailings Management(GISTM) as the internationally recognized best practice.8 This was also pointed out as a benefit inaligning with the SASB Metals and Mining Standard, which similarly relies on GISTM.

392
393
394
395

Proposed GISTM-based additions included new metrics, such as the construction method of thetailings facility, frequency of risk assessments, and disclosure of its findings. One respondent notedand suggested including a clarification that where a tailings facility is deemed to be in a state of safe
closure, the GISTM does not apply.

396
397
398

Some respondents requested to modify recommendation 14.6.1 to refer to other internationallyrecognized frameworks for tailings management besides GISTM, such as Toward Sustainable Mining(TSM), which many industry associations have adopted and are implementing.

399
400
401

One respondent raised concerns over recommendation 14.6.1 to report actions taken to ‘manage
impacts from tailings facilities, including during closure and post-closure; and prevent catastrophic
failures of tailings facilities’ being too generic, open-ended, and not producing comparable data.

402
403
404

A few respondents suggested including reporting disclosures on site-specific emergency
preparedness and response plans (EPRP). It was raised that GISTM, SASB, and TSM include
recommendations and disclosure requirements for EPRPs for each site.

405

GSSB response:

406
407
408
409
410
411
412
413
414

Tailings is a new topic to the GRI Standards system, and does not have a corresponding GRI Topic
Standard. Given the importance of this topic in the mining sector, it was seen as critical to align withother reporting frameworks, specifically the multi-stakeholder-developed Global Industry Standard on
Tailings Management (GISTM). In the effort to further align with the requirements included both in
GISTM and SASB Metals and Minerals Standard, additional data points were included inrecommendation 14.6.3, including the construction method of the tailings facility, the frequency of risk
assessments and summary of its findings, and the implementation of mitigation measures resulting
from the technical reviews. It was also clarified that these disclosures apply only to those tailings
facilities ‘not confirmed to be in a state of safe closure’.

415
416
417
418
419
420
421

The exposure draft included a recommendation under Disclosure 3-3 Management of material topics(14.6.1) to report the organization’s ‘compliance or commitment to comply with GISTM’ (14.6.1).
Based on feedback and further research, TSM was identified as an additional legitimate management
tool with broad implementation through national mining associations. The recommendation 14.6.1
was modified to ask for ‘compliance, or commitment to comply, with recognized international
standards on tailings management’, including a footnote specifying this could be, for example, GISTM
or TSM.

8 International Council on Mining & Metals (ICMM), United Nations Environmental Programme (UNEP), Principles

for Responsible Investment (PRI), Global Industry Standard on Tailings Management, 2020.

Page 13 of 26

422
423
424
425
426
427
428
429
430
431

The second recommendation under Disclosure 3-3 Management of material topics (14.6.1) asked
organizations to ‘describe actions taken to manage impacts from tailings facilities, including during
closure and post-closure’. Upon deliberation of PCP feedback, this was considered to be sufficiently
covered by Disclosure 3-3 Management of material topics, specifically by requirement GRI 3-3-dDescribe actions taken to manage the topic and related impacts. The second part of therecommendation (14.6.1 in the exposure draft) asked for a ‘description of the actions taken to prevent
catastrophic failures of tailings facilities’. Both this recommendation, as well as further feedback to
include emergency preparedness and response plans, were included under Topic 14.15 Criticalincident management. This is aligned with the reporting practice of mining organizations, which often
have a single EPRP for all their assets.

432
433
434
435

In summary, organizations’ tailings disclosures fall under three different topics:• The total amount of tailings generated is reported under Topic 14.5 Waste;• Management of tailings facilities is reported under Topic 14.6 Tailings;• Emergency and response plans are reported under Topic 14.15 Critical incident management.

436

Topic 14.7 Water and effluents

437
438
439
440
441
442
443

Some respondents indicated mine-site level reporting being critical for the topic of water. Reasons toinclude disaggregated data by mine site included mitigating the risk of obscuring material information
for information users and affected stakeholders about the organizations’ impacts at a local level, thelack of awareness by organizations whether they are operating in water-stressed areas; and criticalityof site-level information for the public sector and researchers to determine the impact of mining on
groundwater basins. It was also raised that different performance frameworks in the sector requirewater-related information by mine site and would not be a major reporting burden for organizations.

444

GSSB response:

445
446
447
448
449

While GRI 303: Water and effluents 2018 recommends reporting information at the facility level forareas with water stress, a sector-specific recommendation was added to disaggregate information bymine site to the quantitative disclosures 303-3 Water withdrawal, 303-4 Water discharge, and 303-5
Water consumption. Water data is commonly collected by organizations at a site level in order toproduce an aggregate figure and is not expected to pose a major challenge for mining organizations.

450

Topic 14.8 Closure and rehabilitation

451
452

Topic 14.8 Closure and rehabilitation was one of the most commented topics, prompted by two
dedicated questions in the PCP questionnaire.

453
454
455
456
457

A few respondents requested clarifications for the terms included in the additional sector disclosure
on financial provisions made by the organization for closure and rehabilitation of its sites (14.8.7),
arguing the current wording could lead to imprecise and non-comparable reporting. One respondent
proposed expanding this disclosure to include reporting of the financial surety tools used to guarantee
these financial provisions.

458
459
460
461
462

A few respondents proposed to include quantitative metrics on area disturbed and rehabilitated by theorganization, noting that while the reporting section contained several social and economic reporting
disclosures, it was lacking metrics on environmental management of mine closure. Respondents
claimed this information is commonly reported by mining organizations and would not add asignificant reporting burden.

463

GSSB response:

464
465
466
467

Closure and rehabilitation does not have a dedicated GRI Topic Standard, but lists two applicable
Topic Standard disclosures that cover labor aspects. The reporting section additionally includes
sector-specific disclosures that focus on community impacts and the financial preparedness of theorganization to cover the financial implications of closure. With the aim to clarify the concepts on

Page 14 of 26

468
469

financial assurances (14.8.8), the disclosure was revised to more closely align with widely-acceptedguidance documents related to closure.9 As a result, the closure asks to report:

470
471
472
473
474
475

•

476
477

In the absence of a GRI Topic Standard, the description of the topic was also expanded to elaborateon the expectations and provide further guidance for reporters.

478
479
480
481
482
483

An additional sector disclosure was developed (14.8.6) to capture the quantitative data on the
progress of rehabilitation (hectares of land disturbed and not yet rehabilitated, and land disturbed andrehabilitated). This metric is widely disclosed by large mining organizations, and not considered
controversial or burdensome for mining organizations to report.10 This quantitative reporting is also inline with the revised Topic Standard for Biodiversity that requires reporting the size of natural
ecosystem converted in Disclosure 101-6 Direct drivers of biodiversity loss.

484

Topic 14.9 Economic impacts

485
486
487

A few respondents raised concerns on the sector recommendation 14.9.2 to provide disaggregateddata for Disclosure 201-1 Direct economic value generated and distributed by mine site, stating theinformation is commonly not collected at the site level and would be burdensome to report.

488
489
490
491

A few respondents raised concerns on the sector recommendation 14.9.3 to report information aboutcommunity needs assessments to determine infrastructure investments and services supported,which supplements the Disclosure 203-1 requirements. Respondents claimed this would be too
burdensome to report, with results sometimes only manifesting after years of the program running.

492
493
494
495

A few business respondents raised concerns on the sector recommendation 14.9.4, specifically withregards to reporting ‘the extent to which the [education and skills programs deployed for workers who
are not employees] have been effective’, claiming tracking the effectiveness of such programs goesbeyond what many organizations do and therefore would be challenging to report.

496

One respondent asked for gender disaggregated data for sector recommendations in this topic.

497

GSSB response:

498
499
500
501
502

While acknowledging the potential challenges of reporting all requirements under Disclosure 201-1
Direct economic value generated and distributed by mine site, it was regarded as critical to report
information on community investments at the site level, whereas other economic value metrics would
be appropriate to report on a community/regional/national level. Therefore, recommendation 14.9.2
was modified to ask site-level information for community investments only.

503
504

Recommendation 14.9.3 was revised to reflect whether and how community needs assessments
informed the infrastructure investments/services supported.

505
506

Reporting the effectiveness of programs reported in recommendation 14.9.4 was removed due tofeasibility issues to report this information.

507
508
509

Recommendation 14.9.6 was expanded to include a gender breakdown of the data on workers hiredfrom the local community at the site level. This information is commonly available to organizations andtherefore does not pose additional burden to report.

•••

the total estimated closure cost, and whether financial provisions made by the organization cover
the full amount of the current estimated cost,
whether they are in line with the applicable regulatory requirements;
methodologies used to calculate the estimated closure cost;financial instruments used or developed to guarantee adequate financial provisions for closureand rehabilitation.

9 International Council on Mining and Metals (ICMM), 'Financial concepts for mine closure’, 2019; andIntergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), ‘Global Review:
Financial assurance governance for the post-mining transition’, 2021.
10 This disclosure was reported under frameworks such as GRI G4 Mining and Metals Sector Disclosures.

Page 15 of 26

510

Topic 14.10 Local communities

511
512
513

A few respondents from the business constituency raised concerns over the sector recommendation
to list vulnerable groups identified within the local community at each mine site (14.10.1). It wasargued that these groups could potentially find the categorization inappropriate or disrespectful.

514
515

One respondent flagged the recommendation to ensure safe and equitable gender participation whenengaging with the local community (14.10.1) was beyond the organization’s remit and scope of action.

516
517
518
519

A few respondents proposed additions or modifications to additional sector recommendation ongrievance mechanisms (14.10.4), such as including the grievance mechanism in place (not only thepercentage of them that got resolved), and the channels that affected community members have to
file complaints.

520

GSSB response:

521
522
523

Local communities are one of the most important stakeholders in the mining sector, both as recipientsof impacts and to acquire a social license to operate. The importance of accounting for community
impacts was acknowledged in the PCP questionnaire with dedicated questions. 11

524
525
526
527

To embody a more inclusive approach to how an organization considers vulnerable groups, therecommendation to list vulnerable groups was reformulated and merged with the firstrecommendation in 14.10.1 (in the exposure draft), to ‘describe the approach to identifying
stakeholders, including vulnerable groups, within local communities’.

528
529
530
531
532
533
534
535
536
537

The recommendation to ensuring safe and equitable gender participation when engaging with local
communities was modified to ask ‘how the organization supports safe and equitable genderparticipation’. There are many reasons that could prevent gender equality among the representativesof the local community (such as strong gender norms or traditional structures of selection) that are
beyond the organization’s control. Therefore, in line with sector-recognized guidelines12, theorganization should work toward creating the conditions for women in the local community toparticipate in the stakeholder engagement process even if they cannot guarantee it. This
recommendation was updated across all topics with expectations on gender considerations instakeholder engagement (Topic 14.11 Rights of Indigenous Peoples and Topic 14.12 Land andresource rights).

538
539
540
541
542
543

The additional sector recommendation (14.10.4) asks for information about the number and types ofgrievances from local communities, the percentage of which were addressed and resolved, and thepercentage resolved through remediation. However, broader reporting on the organization’s grievancemechanisms is covered by Disclosure 2-25 Processes to remediate negative impacts, in GRI 2:
General Disclosures 2021. Therefore, an elaboration was not deemed necessary to include in the
additional sector recommendation.

544

Topic 14.11 Rights of Indigenous Peoples

545
546
547
548

A few respondents from the business constituency raised concerns over the confidentiality andsensitivity of information related to sector recommendation 14.11.2 , which asks to describe theviolations of rights of Indigenous Peoples, as well as 14.11.4, which asks to describe anorganization’s processes to seek for free, prior, and informed consent (FPIC).

549
550
551
552

One civil society respondent on Indigenous issues asked for the disclosure on FPIC (14.11.4) to be
mandatory and not a recommendation, claiming FPIC is not a right that is optional for mining
companies to respect; it is required under authoritative international human rights declarations,principles, and instruments.

11 Impacts on communities are outlined across several topics in this exposure draft (apart from the topic Local

communities): Economic impacts; Rights of Indigenous Peoples; Land and resource rights; Closure andrehabilitation; Security practices; and Critical incident management.
12 Organisation for Economic Co-operation and Development (OECD), Due Diligence Guidance for Meaningful
Stakeholder Engagement in the Extractives Sector, 2015.

Page 16 of 26

553

GSSB response:

554
555
556
557
558

Recommendation 14.11.2 and additional sector disclosure 14.11.4 ask for information that can beconsidered sensitive or confidential. An organization could, in good faith, opt not to report thisinformation, as sector disclosures are not mandatory reporting in accordance with the GRI Standards.
Reasons for omission,13 which include confidentiality constraints, can also be used if the organization
cannot report information required by the Topic Standard disclosure.

559
560
561
562
563

Within the GRI Standards system, sector-specific reporting is not required when reporting inaccordance with the GRI Standards. However, elaboration on the importance of FPIC, and the needto seek it throughout the project lifecycle, was included in the description of the topic. The feedback
on FPIC and its criticality to Indigenous rights will also be evaluated as part of the revision of the GRI
413: Local communities 2016 and GRI 411: Rights of Indigenous Peoples 2016 Topic Standards.14

564

Topic 14.12 Land and resource rights

565
566

A few respondents urged to align reporting on the topic with authoritative instruments for managing
impacts related to land acquisition and resettlement, such as the IFC Performance Standards.

567
568

One respondent supported the inclusion of reporting on monitoring the welfare status of theindividuals subject to involuntary resettlement as essential information.

569
570
571

A few respondents supported the inclusion of reporting the number of individuals resettled, andadding a gender disaggregation when reporting on remediation to local communities or individuals
subject to involuntary resettlement, as women and girls are more severely affected by displacement.

572

GSSB response:

573
574
575
576
577
578
579

The topic of land and resource rights does not have a dedicated Topic Standard, and therefore lists
sector-specific recommendations for reporting. To increase synergies with existing expectations forresponsible business conduct for mining organizations, the reporting section is closely aligned with
the IFC Performance Standard 5 Land Acquisition and Involuntary Resettlement, which is a primaryreference for the sector. The topic lists reporting on the provision of compensation for loss of assets,
improvement and restoration of the livelihoods of displaced persons, as well as monitoring andtracking these activities.

580
581

A new sector recommendation was included under GRI 3-3 to report details on the effectiveness ofremediation actions related to resettlement, including how this is monitored.

582
583
584

The additional sector disclosure 14.12.2 was expanded to include reporting the number of persons
displaced, with a breakdown by gender. This will strengthen transparency around the gendered
impacts of loss of land and livelihoods, which are found to affect women more severely.15

585

Topic 14.13 Artisanal and small-scale mining (ASM)

586
587

Artisanal and small-scale mining (ASM) was the topic that received the most comments, prompted by
its novelty to the GRI Standards16 and dedicated questions in the PCP questionnaire.

588
589
590

A few respondents raised concerns over the terminology used in the sector recommendation to 3-3(14.13.1), to describe the approach to engaging with legitimate ASM operators, and the process used
to determine whether they are legitimate.17 Identifying and determining which ASM operators are

13 As outlined in ‘Reporting in accordance with the GRI Standards: Requirement 6’, in GRI 1: Foundation 2021.
14

A revision project for these Standards is scheduled in the GSSB work program for 2025.

15 Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) Global Review:Integrating Gender Into Mining Impact Assessments, 2022.
16 The topic focuses on the impacts related to interactions between mining organizations and ASM, but does not
explicitly address impacts from ASM activities, which is not considered a primary target group for GRI 14.
17 ASM operations often lack a legal status. According to the OECD, ASM can be considered legitimate (despite
it being not legal), when is consistent with applicable legal frameworks, or when acting in good faith to operate
within those or pursue opportunities for formalization (OECD Due Diligence Guidance for Responsible Supply
Chains of Minerals from Conflict-Affected and High-Risk Areas, 2016).

Page 17 of 26

591
592

legitimate was seen as beyond the organization’s remit. Other respondents noted the lack ofconsensus on the terminology when discussing ASM.

593
594
595
596

A few respondents from civil society organizations expressed support for adding genderdisaggregation to the sector recommendation to report programs in place to enhance positive impacts
or mitigate negative impacts involving ASM (14.13.1), due to the higher presence of women in ASM incomparison with (large-scale) mining organizations.

597
598

A few respondents proposed to include reporting on business relationships between mining
organizations and ASM, and the control systems in place to manage those interactions.

599

GSSB response:

600
601
602
603
604
605
606
607
608

While it is challenging to define legitimate ASM due to the myriad circumstances in which ASM takes
place, the OECD considers it as ‘mining that is consistent with applicable laws’ and, where a legal
framework is absent or not enforced, consideration is given whether the ASM operator engages informalization opportunities. However, limiting engagement with ASM to those considered as‘legitimate’ could disincentivize companies from engaging with other types of ASM. Further,formalization of ASM is increasingly seen as a joint effort between governments, ASM, mining
organizations and other relevant stakeholders. The sector recommendation (14.13.1) was accordingly
revised to include a description of the approach taken by the organization to support ASM
formalization and professionalization efforts, without limiting engagement to ‘legitimate’ operators.

609
610
611
612
613
614

Gender considerations were included in recommendation 14.13.1, which asks about programs toenhance positive or mitigate negative impacts involving ASM. Women represent around 30% of ASM
workers, and often face discrimination and economic challenges resulting from the lack of access to,use of, and control over land, licenses, and finance.18 Understanding the organization’s efforts toincorporate gender considerations in their programs to mitigate negative impacts involving ASM wasseen as appropriate to include.

615
616
617
618
619
620
621
622

ASM is often associated with major negative environmental and social impacts, which mining
organizations would be involved with by their business relationships when sourcing from ASM. Whilebusiness relationships between mining organizations and ASM are not yet widespread, they are
expected to increase in the coming years due to the growing demand for certain minerals to support
the energy transition, such as cobalt, where a significant amount of supply comes from ASM. This
warranted the development of an additional sector disclosure under 3-3 (14.13.1) to disclose
information on the policies in place and the processes used to identify and assess actual and potential
negative impacts when sourcing from ASM.

623

Topic 14.14 Security practices

624
625
626
627

A few respondents raised concerns about the sector recommendation 14.14.1 to report the ‘approachto ensuring respect for human rights by public and private security providers’. The expectation toensure respect for human rights by public security providers was seen as unattainable due to the lackof control over public third-party security providers.

628
629
630

A few business respondents raised concerns over the feasibility of committing to implement theVoluntary Principles on Security and Human Rights (VPSHR), when, for example, the country of theiroperations has not joined the Voluntary Principles Initiative.

631

GSSB response:

632
633
634
635

Sector recommendation 14.14.1 was modified to ask for a description of how the organization seeks
to prevent or mitigate potential negative impacts from the use of public and private security providers.
This level of influence over third-party providers aligns with expectations for organizations on security
and human rights as laid out in the VPSHR.19 Due to the lack of direct influence over public or state-

18 Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), Women in

Artisanal and Small-Scale Mining: Challenges and opportunities for greater participation, 2018.
19 The Voluntary Principles on Security and Human Rights (VPSHR) is a multi-stakeholder initiative guidingorganizations in providing security for their operations while respecting human rights.

Page 18 of 26

636
637

owned security providers, the organization is expected to leverage its position to engage with them inrespecting human rights through, for example, sharing training or good practice.

638
639
640
641
642
643

Regarding concerns over the potential adoption of VPSHR, the Principles can be implemented by anyorganization, regardless of whether or how their host country is implementing them at a national level.
Recommendation 14.14.1 was retained and divided in two to ease readability. The recommendationon the commitment to implement the VPSHR was broadened to ask whether the organization is
implementing the VPSHR to foster reporting on the actual adoption and implementation of the
Principles, rather than reporting policies and plans to do so.

644

Topic 14.15 Critical incident management

645
646

A few respondents raised concerns over the lack of definition for ‘critical incidents’, which could
potentially lead to subjective interpretations of the topic and hinder meaningful reporting.

647

One respondent proposed reporting on testing of emergency preparedness and response plans.

648

GSSB response:

649
650
651
652

Critical incident management does not have a dedicated Topic Standard, listing one applicable Topic
disclosure: 306-3 Significant spills. Existing sector-specific recommendations, building on contents
developed for existing Sector Standards GRI 11: Oil and Gas Sector 2021 and GRI 12: Coal Sector
2022, cover aspects related to emergency preparedness, response, and critical incidents.

653
654
655
656

There is no universally accepted definition of a ‘critical incident’. The topic description in GRI 14
explains the scope of critical incidents in the Standard as ‘incidents that can lead to fatalities, injuries
or ill health, environmental impacts, and damage to local communities and infrastructure’. A glossary
term for critical incidents will be considered in a future Topic Standard project.20

657
658
659
660
661
662

The sector recommendation to report information on emergency preparedness and response plans(EPRPs) (14.15.1) was aligned with expectations set out by other sector reporting frameworks, suchas SASB Metals and Mining and GISTM to ensure sufficient reporting on impacts.21 The
recommendation was expanded to report the frequency of testing emergency preparedness andresponse plans; and clarified ‘local stakeholders’ as comprising local communities, workers, public
sector agencies, first responders, and local authorities.

663

Topic 14.16 Occupational health and safety

664
665
666

A few respondents proposed to include reporting on the provision of gender-appropriate personal
protective equipment (PPE), as women workers are frequently not provided appropriate safety
apparel, increasing work-related hazards.

667

A few respondents supported including reporting on gender-based violence in the sector.

668

GSSB response:

669
670
671
672

A sector recommendation to report how the organization ensures the provision of gender-appropriate
personal protective equipment for workers was included under Disclosure 403-2 Hazard identification,risk assessment, and incident investigation (14.16.3). This addition was supported by evidence andexisting responsible mining performance expectations in the sector.22

20 A Topic Standard project for Pollution is scheduled in the GSSB work program to start in 2024, which willconsider critical incidents.
21 SASB Metals and Mining Standard, EM-MM-540a.3. Approach to development of Emergency Preparedness
and Response Plans (EPRPs) for tailings storage facilities. 2.1.1 The entity’s approach to engaging with
employees, contractors, public sector agencies, first responders, and local authorities and institutions inaccordance with Requirements 13.1 and 13.2 of the GISTM; and 2.1.2 The entity’s frequency of emergency
response plan tests and evacuation exercises to minimize consequences of a potential failure.
22 7 out of 38 mining organizations assessed in the RMI Report 2018 provided gender-appropriate PPE or

facilities. Expectations to provide appropriate PPE is also codified in the IRMA Standard 2018, RMI Framework
2022, TSM Safe, Healthy, and Respectful Workplaces Protocol and ILO Guidelines for Gender Mainstreaming in
Occupational Safety and Health.

Page 19 of 26

673
674
675
676

In addition, and with the aim to draw more attention to women’s disproportionate rate of work
harassment in the sector23, and building upon raising expectations on transparency on this topic, a
new sector recommendation (14.16.3) was included to describe the processes used to identify workrelated incidents due to sexual and gender-based violence, and to determine corrective actions.

677

Topic 14.17 Employment practices

678
679
680
681
682
683

A few business representatives raised concerns with the sector recommendation to report ‘benefits
provided to employees that are not provided to workers who are not employees and whose work andworkplace are controlled by the organization’ (14.17.4). The high volume of suppliers and contractors
was seen as an impediment to report on the issue. It was also pointed out that contractors can be
widely divergent, and the differences in benefits as compared to employees do not illuminate theimpact of the organization due to the dependence on specific circumstances.

684
685
686

One respondent supported including gender disaggregation of data and a recommendation to reporton gender-based violence. Another respondent proposed including reporting on working hours to
draw attention to the impacts of rotating shifts and long working hours in the sector.

687

GSSB response:

688
689

Recommendation 14.17.4 was removed from the Standard, acknowledging the practical challenges tolarge mining organizations and the lack of sector-specificity of reporting.

690
691
692

A sector recommendation on gender-based violence was developed. The disclosure was seen as
appropriate to include under Topic 14.16 Occupational health and safety (recommendation 14.16.3),
where it fits in the context of work hazards.

693
694
695
696

The feedback received on working hours, which is partially addressed by Disclosure 403-9 Workrelated injuries24, was included in the topic description. However, due to the lack of sector-specificity,
the feedback on the need for a disclosure addressing working hours was communicated to theongoing Topic Standards Project for Labor.

697

Topic 14.20 Freedom of association and collective bargaining

698
699
700

One respondent from an investment institution proposed including a new disclosure on the number ofstrikes, how long they lasted, how many workers participated, and the percentage of employees
covered by collective bargaining agreements.

701

GSSB response:

702
703
704
705

A new sector recommendation to report strikes and lockouts involving 1,000 or more workers was
included (14.20.3), aligning closely with the SASB Standard on Metals and Mining. This, inconjunction with the General Disclosure 2-30 Collective bargaining agreements, is considered as a
useful signal related to worker-management relations and conflict with workers.

706

Topic 14.21 Non-discrimination and equal opportunity

707
708
709

A few respondents supported the expansion of the recommendation on gender equality plans(14.21.5) to also encompass gender equity plans. One respondent raised concerns over therecommendation to report on the ‘progress made in implementing the plan’.

710
711

One respondent supported the inclusion of gender disaggregation to Disclosure 202-2 Proportion ofsenior management hired from the local community.

712
713

One respondent opposed the inclusion of the mine-site recommendations to Disclosure 405-2 Ratio of
basic salary and remuneration of women to men (14.21.6).

23 International Labour Organization (ILO), Women in Mining: towards gender equality, 2021.

24 Requirements 403-9-a-v and 403-9-b-v ask for ‘the number of hours worked’ for all employees, and for all

workers who are not employees but whose work and/or workplace is controlled by the organization.

Page 20 of 26

714

GSSB response:

715
716
717
718

Gender equity plans were included in the recommendation 14.21.5, allowing organizations to reporton either gender equality or gender equity plans. Reporting the summary of the plan and progress
made in its implementation were retained in the recommendation, as disclosing the existence of aplan would not be sufficient to understand its effectiveness.

719
720
721

A recommendation to disaggregate the proportion of senior management hired from the local
community by gender was added, as gender imbalance is a persistent challenge for the sector.
Organizations commonly collect this data and reporting it should not pose a burden.

722
723
724
725
726

The site-level recommendation to report the ratio of basic salary and remuneration of women to men,as well as other indicators of diversity, was retained. Aggregated ratios of women to men at thecorporate level do not allow a sufficient understanding of the disparities women or other groups canface in remuneration, given the diverse circumstances and regional contexts of mining operations.
Reporting organizations already collect this data, and reporting it should not pose a burden.

727

Topic 14.22 Anti-corruption & Topic 14.23 Payments to governments

728
729

A few respondents urged the Mining Standard to align the additional sector reporting with the recently
updated Extractive Industries Transparency Initiative (EITI) EITI Standard 2023.

730

GSSB response:

731
732
733
734
735
736

The reporting sections of Topic 14.22 Anti-corruption and 14.23 Payments to governments in the
exposure draft were closely aligned with the EITI Standard 2019, which is a widely adopted Standard
by many resource-rich governments, focusing on natural resource management and transparency inthe extractives sector. The final Mining Standard, including the references and bibliography, has been
updated to reflect the revised EITI Standard 2023. Significant changes were implemented to thedisclosures on beneficial ownership (14.22.6) and project-level payments (14.12.7).

737

14.24 Public policy

738
739
740
741
742
743

One respondent raised concerns with the second sector recommendation under 3-3 (14.24.1), whichasks to report differences between the organization’s stated policies, goals, or other public positions
on significant issues as well as the positions of the representative associations or committees ofwhich it is a member. It was argued that many organizations do not have the resources to track thissystematically. Another respondent requested guidance on the type of memberships and thresholds
intended.

744

GSSB response:

745
746
747
748
749
750

The recommendation on membership associations (14.24.1) was retained, given the prevalence of
public advocacy efforts through industry associations in the mining sector. The recommendation is
expanding Disclosure 2-28 Membership associations, which already requires information on ‘industry
associations, other membership associations, and national or international advocacy organizations inwhich [the organization] participates in a significant role’, and should not pose a major additionalburden for reporters.

751
752
753

A footnote was included in the recommendation (14.24.1) to direct reporters to seek further guidanceon thresholds and membership associations from GRI 415: Public Policy 2016 and Disclosure 2-28 in
GRI 2: General Disclosures 2021.

754
755
756
757
758
759

The sector recommendation to report the ‘organization’s stance on significant issues that are thefocus of its participation in public policy development, and differences between these positions and its
stated policies and goals’(14.24.1) was seen as mostly linked to climate change and lacking sectorspecificity. In the exposure draft of the Topic Standard project for Climate Change, a disclosure isincluded to report how the organization’s public policy and lobbying activities are consistent with its
transition plan. The sector recommendation was, therefore, removed from the final Mining Standard.

Page 21 of 26

760

Topic 14.25 Conflict-affected and high-risk areas

761
762

Conflict-affected and high-risk areas was one of the most commented topics of the PCP, partly driven
by dedicated questions in the PCP questionnaire and the novelty of the topic to the GRI Standards.

763

A few respondents asked for clarification on the terminology used in the reporting section (14.25.2).

764
765
766
767
768
769

A few respondents raised that a due diligence 5-step report is not always produced by mining
companies (recommendation 14.25.2 in the exposure draft), especially if they follow anotherframework that nevertheless covers similar expectations as the OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. One respondent
pointed out that an impact assessment is not the same as a 5-step report and should be separated as
its own recommendation.

770

GSSB response:

771
772
773
774
775

Conflict-affected and high-risk areas (CAHRAs) is a new topic in the GRI Standards, focusing on theimportance of conducting robust due diligence when operating or sourcing from conflict-affected andhigh-risk areas, which presents a heightened risk for severe human rights abuses and illicit financial
flows. Lacking a GRI Topic Standard, the reporting primarily draws from the OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

776
777

With the aim to add further clarify the terminology used and direct reporters to authoritative resources,a footnote was added to recommendation 14.25.2 pointing to the OECD Due Diligence Guidance.

778
779
780

As there are several frameworks and standards in the sector that reference or build on the OECD Due
Diligence Guidance with which mining organizations comply with, the clause to provide a link to a 5step report based on the OECD Guidance was removed.

781
782
783
784

Additional sector recommendation on impact assessments (14.25.2) was rephrased to focus on actualand potential negative impacts on workers and local communities, including actions to prevent or
mitigate impacts. The existence of impact assessment was seen as sufficiently covered by thedescription of the organization’s due diligence process, reported in 14.25.3 in GRI 14.

Page 22 of 26

Appendix 1. Participation in events
and webinars
Table 2: list of events and webinars held during the public comment period
Event

Date

Number of attendees

Global webinar (1)23 February

972 registrations, 386 attendees

Global webinar (2)2 March747 registrations, 284 attendees

Workshop for South Africa, Alternative
Mining Indaba (Cape Town)

8 February~30 attendees

Workshop for Spanish-speaking Latin
America

14 March

126 registrations, 40 attendees

Webinar for Brazil

15 March

143 registrations, 71 attendees

Workshop for Southeast Asia

4 April

107 registration, 55 attendees

Webinar for Greater China

18 April

143 registrations, 71 attendees

Workshop for South Asia

18 April

104 registrations, 28 attendees

Briefing with North American Mining
Association (NMA)

1 February~30 attendees

Briefing with Brazilian Mining Association(IBRAM)

2 March~50 attendees

Briefing with Australian Minerals Council(AMC)

3 April

56 attendees

Briefing with Gremial de Recursos
Naturales, Minas y Canteras (GRENAT),
Guatemala26 April46 attendees

Webinar with AIDIS and Cámara Argentina
de Empresarios Mineros (CAEM)

20 April

231 views

Attendance to Mining Indaba

6-9 February-

Attendance to PDAC

5-8 March-

Attendance and public speaking at ELAMI

28-31 March

50 attendees

Attendance and partner sesión hosting at
OECD Forum on Responsible Mineral
Supply Chains25-27 April~75 attendees

Page 23 of 26

Appendix 2. Overview of respondents
Table 3. Overview of the public comment respondents.
Representation

Name

RegionStakeholder
constituency25

Individual

Jesus Antonio Mena Rodriguez

Latam

Mediating institution*

Individual

Caio Gouvea

Latam

Mediating institution*

Organizational

Quantum Energy, Inc.

North America

Mediating institution*

Individual

JUNJI BAN

AsiaMediating institution*

Organizational

ESG Broadcast

Asia

Business

Individual

Trevor Hughes

EuropeMediating institution*

Organizational

FBRH Consultants Ltd

EuropeMediating institution*

Individual

Judy Auld

Oceania

Mediating institution*

Individual

Fernando Cando

LatamBusiness

Individual

Benedicta Akesse Annan

AfricaMediating institution*

Individual

Farheen Khanum

Asia

Mediating institution*

Organizational

Energy37 Consulting Inc.

North America

Mediating institution*

Individual

Marcia Bellotti

Latam

Mediating institution*

Individual

Raymond Philippe

EuropeMediating institution*

Individual

Pamela Duran Diaz

EuropeMediating institution*

Organizational

CEDLA

Latam

Mediating institution*

Organizational

El Derecho a No Obedecer

Latam

Civil society*Individual

Dimitris Ballas

EuropeMediating institution*

Organizational

Stockholm Resilience Center

EuropeMediating institution*

Organizational

Latam

Mediating institution*

Organizational

Fundación Ideas para la Paz(FIP)
Grupo de Diálogo Minero

Latam

Mediating institution*

Organizational

Institute for Global Developme

Asia

Civil society*

Organizational

Nordkalk Corporation

EuropeBusiness

Organizational

Asia

Business*

IndividualIndonesian Mining Association(IMA)
Michael Proulx

North America

Mediating institution*

Organizational

S&P Global Sustainable

EuropeInvestment institution*

Organizational

EuropeCivil society*

Organizational

Women’s Rights and Mining
Working Group
RMI

EuropeMediating institution*

Individual

Bernie Napp

Oceania

Mediating institution*

Individual

Rahul Basu

Asia

Civil society*

Organizational

Seylan Bank PLC

Asia

Investment institution*

25 Stakeholder constituencies marked by an asterisk have been reclassified from the option marked byrespondents in the PCP questionnaire, which included more granular options (Academic / Assurance provider /Business / Consultant / Government / Investor / Labor representative / Market regulator / Non-governmentorganization / Rating agency / Standard setter / Stock exchange / Student / Trade or industry association / Other)

Page 24 of 26

Organizational

Latam

Mediating institution*

Organizational

The Alliance for Responsible
Mining (ARM)
Ekama Development Foundation

AfricaCivil society*Individual

Sebastian Alvear

Latam

Investment institution*

Organizational

AGS Action BD Ltd.

Asia

Mediating institution*

Individual

Namita Asnani

Asia

Mediating institution*

Individual

Jorge Jauregui

Latam

Business*

Individual

Sushil Pattanaik

Asia

Mediating institution*

Organizational

Asia

Mediating institution*

Individual

BAIID auto technologies private
limited (Lipongroup)
Bárbara Gómez Delgado

EuropeBusiness

Individual

Rodent Kayumba

AfricaBusiness

Individual

Stephen Northey

Oceania

Mediating institution*

Individual

Alejandra Rodriguez

Latam

Mediating institution*

IndividualJose Manuel Martinez Cue

EuropeMediating institution*

Individual

Oscar Julián Soto Gil

Latam

Mediating institution*

Organizational

Rio Tinto

Oceania

Civil society*Individual

PN Parameswaran Moothathu

Asia

Mediating institution*

Organizational

Ecovadis

EuropeInvestment institution*

Individual

Kene Onukwube

AfricaCivil society*

Organizational

Zijin Mining

Asia

Business

Individual

Nizar SDIRI

AfricaMediating institution*

Individual

Hugo Rainey

North America

Civil society*

Organizational

North America

Mediating institution*

Organizational

International Cyanide
Management Institute
Australian Red Cross

Oceania

Civil society

Organizational

J M Environet Pvt Limited

Asia

Mediating institution*

Organizational

Nizmonia

Asia

Business

Individual

Eddie SmythEuropeMediating institution*

Organizational

South32

Oceania

Business

Organizational

EuropeCivil society*

Organizational

Partnership between DCAF –The Geneva Centre for Security
Sector Governance and theInternational Committee of the
Red Cross (ICRC)
Impala Platinum

AfricaBusiness

Organizational

Sustainalytics

North America

Investment institution*

Organizational

Minviro Ltd

EuropeMediating institution*

Organizational

EuropeMediating institution*

Organizational

POLVAL - Polish Association of
Mineral Asset Valuators
ACM

Latam

Business

Organizational

Vale

Latam

Business

Organizational

Oxfam

North America

Civil society*Individual

Margarita Ferat

Latam

Mediating institution*

Organizational

GrenatLatam

Business

Organizational

Mastercube IoT LLP

AsiaMediating institution*

Organizational

ERG

EuropeBusiness

Page 25 of 26

Individual

Diego Murguia

Latam

Mediating institution*

Organizational

Cornish Lithium

EuropeBusiness

Organizational

Asia

Mediating institution*

Organizational

TÜV SÜD Certification andTesting (China) Co., Ltd
BMO Global Asset Management

North America

Investment institution

Organizational

ETA Operations

AfricaMediating institution*

Organizational

Newmont Corporation

North America

Business

Organizational

World Benchmarking Alliance

EuropeMediating institution*

Organizational

Engineers Without Borders
CanadaGIZ

North America

Civil society*

Latam

Mediating institution*

Oceania

Mediating institution*

Organizational

AASB Australian AccountingStandards Board
C.C.Sustainable Consultancy

Asia

Mediating institution*

Organizational

ILO

GlobalLabor

Individual

Jon Ellermann

North America

Mediating institution*

Organizational

Oceania

Business

Latam

Mediating institution*

Organizational

MCA Minerals Council ofAustralia
SIS Sustainable Inclusive
Solutions
TSM

GlobalMediating institution*

Organizational

World Gold Council

GlobalBusiness

Organizational

Jean-François Jenni

EuropeMediating institution*

Organizational

Sibanye Stillwater

AfricaBusiness

Organizational

ICMM

GlobalBusiness

Organizational

BHP

Oceania

Business

Organizational

Responsible Critical Mineral
Initiative (RCI) & China Chamberof Commerce of Metals,
Minerals & Chemicals Importers& Exporters (CCCMC)
SyntaoAsia

Business*

Asia

Mediating institution*

Organizational
Organizational

Organizational

Organizational

Page 26 of 26