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Human rights and anti-corruption risk assessments for leading gold producer

GoodCorporation has conducted human rights and anti-corruption risk assessments for one of the world’s top 10 gold producers. The risk assessments were carried out as part of the company’s commitment to the World Gold Council’s Responsible Gold Mining Principles (RGMPs), which sets out clear expectations as to what constitutes responsible gold mining.

The World Gold Council places an obligation on companies adopting its principles to undertake both a human rights and anti-bribery and corruption (ABC) risk assessments, or update any it may already have undertaken. For a leading gold producer, that had signed up to the RGMPs, GoodCorporation has carried out both risk assessments, looking at the company’s global operations, with a focus on its three largest mines.

Risk assessment preparation

Prior to conducting each risk assessment, GoodCorporation conducted interviews with a cross section of key stakeholders to gain insights into the levels of understanding of these specific risks. Desktop research was also carried out to ensure that all human rights and ABC risks had been identified and could be included in the relevant risk assessment frameworks.

In addition, sectoral trends and best practice for the management of human rights and ABC risks were also considered, to ensure the company would be evaluated against the latest and highest industry standards. All relevant documentation was reviewed, including policies, procedures, records, audits, ESG roadmaps, etc.

Once all detailed preparation had been concluded, preliminary lists of human rights and corruption risks were prepared.

Human rights and ABC risk assessments

The human rights risk assessment comprised site visits to three of the largest mines by GoodCorporation consultants. In addition, workshops were carried out with the management teams of the three identified mines and the different regional offices. The ABC risk assessment comprised workshops with the management team of each of the three largest mines and with regional offices.

Once the site visits and workshops had been completed, all data from the desktop research, document reviews, stakeholder interviews, site visits and workshops was consolidated. This consolidated data was used to draft informed risk registers for human rights and ABC, together with associated action plans and prioritised recommendations for both risk areas.

Once each risk register had been drafted, further workshops were carried out with the respective project managers and relevant business functions at group level. This enabled feedback from the company to be gathered and incorporated into the final human rights and ABC risk registers and action plans.

Commenting on these risk assessment projects, Gareth Thomas, GoodCorporation director and head of ESG said; “The World Gold Council is to be commended for requiring those companies that sign up to its Responsible Gold Mining Principles to obtain external, third-party verification of the principles signed up to. Such independent verification is necessary to build confidence amongst stakeholders that responsible business practices are being taken seriously in practice.

"Understanding the risks where human rights abuse or corruption might occur is vital, so mandating this first step is a good way of raising standards in gold mining by providing independent assurances that gold has been responsibly sourced and mined.” 

Understanding the risks where human rights abuse or corruption might occur is vital, so mandating this first step is a good way of raising standards in gold mining by providing independent assurances that gold has been responsibly sourced and mined.

Gareth Thomas

DIRECTOR and head of ESG, GoodCorporation

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