The International Council on Mining and Metals (ICMM) has published an updated version of a manual produced in 2009 that sets out grievance procedures within the mining industry.

ICMM is a private sector organisation “dedicated to a safe, fair and sustainable mining and metals industry.” It brings together 27 mining and metals companies and 36 regional and commodities associations. It is based in London and has the UK-quoted Anglo American as a founder member.

It has developed and authored various publications aimed at improving the sustainability of extractives. The new publication is over twice as long as that of 2009, mostly because it has added numerous empirical examples to the first version. None of the examples contain documentation but they do contribute to making the account more vivid.

As before, the new version uses the eight effectiveness criteria of the UN Guiding Principles on Business and Human Rights to guide its prescriptions, with many real-life examples that illustrate how and why the issue is important. The document was released on Human Rights Day to focus the attention of investors on the importance of these procedures in achieving good human rights-sensitive business behaviour. According to a study published by consultancy Ernst & Young (EY) in October, almost half of the global mining and metals executives it interviewed believe that loss of social support (or the social licence to operate) is the main risk the industry now faces.

The ICMM methodology emphasises the right points. Dialogue and listening are important, it says. “Legitimacy encompasses the basic notions of trust, accountability and fairness that are essential for satisfactory dispute resolution and as such is the first and overarching criterion for effective grievance mechanisms.” (p.16). There is equal emphasis on the internal processes of the company, “which need to produce adequate buy in and resources from senior management and cooperation across sectors.” To be effective on the ground, grievance mechanisms need senior management support. “This support ensures there is operational responsibility for the mechanism as well as sufficient human and financial resources for its day-to-day running (p.46).”

The document recommends early attention to possible grievance-causing issues, arguing that “Involving communities in the design and implementation of a grievance mechanism is both a rights-based approach and a pragmatic approach.” (p.16).