5.4 A Note on Communication and Transparency
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Stakeholder consultation, information sharing and dialogue should occur throughout the TSF design, operation and closure phases, so viewpoints, concerns and
expectations can be identified and considered. Regular, meaningful engagement
between the company and affected communities is particularly important for developing trust and preventing conflict.
It should be noted that the term “consultation” is only one aspect of a meaningful
communication program by a company. According to The International Association
for Public Participation (IAP2), community engagement consists of a spectrum of
approaches described as follows:
• inform (provide information);
• consult (obtain feedback);
• involve (act on what we hear);
• collaborate (public participates in decision-making process but company makes
the final decision);
• empower (public decides).
The fourth level, “collaboration”, closely parallels one of MAC’s “leadership”
level requirements as part of its “Towards Sustainable Mining” initiative. In its Aboriginal and Community Outreach Protocol (MAC Outreach 2015) one of the requirements at their leadership level is that formal mechanisms are in place to ensure that
the public “…can effectively participate in issues and influence decisions that may
interest or affect them”.
Meaningful communication also requires that a company demonstrate its commitment by making its assessment protocols and results publicly available. In addition
to helping to drive internal improvement, this practice will go a long way towards
earning public trust by showing the comprehensive nature of the standards of practice
being used and the efforts being made to ensure that they provide ongoing protection
for the public and the environment.
To foster meaningful communication and engagement leading practice requires
that the public is adequately informed of the nature of the risks relating to proposed
and existing tailings facilities and can effectively participate, in a collaborative manner, in decisions that may interest or affect them. Leading practice also requires that
a company make its assessment protocols and reports available to the public to foster
transparency.
5.4.2 Transparency and NI43-101
To convince the government and the public beyond a reasonable doubt that the
proposed site selection and deposition method provides an acceptable level of risk
protection, a company must fully disclose the nature of the risks and demonstrate that
its risk management strategies and its commitment to a strong governance framework
will adequately address their concerns (Oboni and Oboni 2019).
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