Using a human rights impact assessment to prepare for IRMA certification

Using a human rights impact assessment to prepare for IRMA certification

Human Rights & Modern Slavery | read time: 4 min

In 2025, GoodCorporation conducted a human rights impact assessment (HRIA) for the Sub-Saharan African affiliate of international mining company Eramet. The assessment was commissioned in part to support the client’s pursuit of an Initiative for Responsible Mining Assurance (IRMA) certification, widely considered to be the most demanding standard on human rights and sustainability in the mining industry. Our HRIA methodology was applied with a specific focus on IRMA requirements, enabling the company to identify and address materials gaps ahead of an IRMA audit in the following months.   

The client also requested particular attention be paid to local communities, due to increasing challenges with dialogue and growing media attention. Community-related topics account for a significant proportion of the IRMA requirements, with a strong emphasis on free and prior informed consent, ongoing engagement, health and safety and the effectiveness of grievance mechanisms.  

Key challenges

There were a number of contextual factors which contributed to the complexity of the HRIA: 

• The region holds cultural and economic significance, with tourism, fishing and horticulture supporting local livelihoods. The affiliate was therefore subject to increased scrutiny by the domestic and international media and the wider population at large.  
• The land tenure arrangements posed an acute challenge. Most local residents occupied land informally, while legal ownership rested with the state; a legacy of mixed land reforms post colonial rule. Due to the size of the operational area, thousands of local community members were relocated. However, informal land ownership arrangements complicated the compensation process, contributing to perceptions of collusion between the client and local government to re-nationalise land held by a minoritised population.  

Scope

While the assessment prioritised impacts on local communities, the scope included all operational sites. The GoodCorporation team consulted over 300 stakeholders as part of the project, including managers at group and affiliate level, employees, on-site service providers, local community members, national and local public authorities, as well as institutions and NGOs.  

Prior to our community consultations, we conducted a comprehensive stakeholder mapping exercise. This allowed us to understand the social terrain and identify interested parties to ensure key stakeholders were included. This also enabled us to provide recommendations which took into consideration any nuances that might render on-the-ground implementation more complex. As with all projects of this nature, we worked closely with our local associates to ensure we were taking a culturally sensitive approach when engaging with local communities. 

The primary method of consultation was through focus groups, although we did conduct ad-hoc interviews with local community members when the opportunity arose, using a carefully semi-structured interview guide to direct our conversations.  

In addition to consultations with communities within the scope of impact, we interviewed national and local authorities as well as important local figures such as village heads and religious leaders. These exchanges were key to building a full picture of the network of stakeholders involved and the impact of the client on the local environment.  

Highlighted findings

Findings relating to direct employees were limited in severity. By contrast, more material risks were identified for contractor and service-provider staff, particularly in relation to pay, employment conditions, accommodation, transport and mechanisms for social dialogue. 

The most salient impacts concerned external stakeholders, notably local communities. Key issues included the adequacy of consultation and engagement, displacement and resettlement practices, compensation and livelihood restoration, access to water, health and safety risks as well as the effectiveness of grievance mechanisms and security.  

Collaboration during and post HRIA

GoodCorporation developed a prioritised action plan to address the findings, reflecting both their severity and the timetable for the forthcoming IRMA audit. The plan emphasised cross-cutting measures aimed at addressing root causes and, where relevant, mapped recommendations to specific IRMA chapters to support implementation.  

Impact and outcomes 

Since completion of the HRIA, the mining company has undergone its first IRMA audit and achieved an IRMA 50 score, one of the higher levels of recognition available under the Standard. 

The IRMA audit report highlighted the credibility, scope and methodological robustness of GoodCorporation’s assessment, noting that the HRIA provided a significantly strengthened basis for the company’s human rights due diligence. Auditors recognised that the HRIA had identified a comprehensive and accurate set of risks, many of which corresponded closely to issues raised during stakeholder interviews conducted independently by the IRMA team. 

The IRMA report also commended: 

• The structure and practicality of the action plan developed by GoodCorporation, including the allocation of responsibilities and the creation of internal mechanisms for tracking progress. 

• Evidence of early corrective actions, such as strengthened community dialogue processes, improvements in worker and contractor oversight, updates to security governance and enhanced training and awareness‑raising activities. 

• Stakeholder validation of the findings, with community members confirming during IRMA‑facilitated dialogues that the HRIA accurately reflected their concerns and priorities. 

As a result, the HRIA has become a reference point for the company’s ongoing human rights management, informing continuous improvements in engagement, grievance handling, land‑related processes, contractor management and community health and safety. 

Conclusion

Human rights impact assessments provide companies with a structured and evidence-based view of their most significant risks. When conducted well, they support better decision-making, strengthen stakeholder trust and enable companies to address emerging issues before they crystallise into operational or reputational harm. In circumstances where harm has already occurred, human rights impact assessments help companies draw up a clear path forward to redress said harm and prevent it from reoccurring.  

Visit our Human Rights Impact Assessments webpage to find out more about our services or contact us to speak to a member of the team. 

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