The rocketing demand for battery minerals poses a great contradiction: the tools we need to decarbonise the global economy are leading to more extraction of natural resources. One silver lining is that the mining industry is increasingly held to account.

Buyers want to ensure raw materials are sourced in a more socially and environmentally responsible way to comply with new regulations, such as the EU Corporate Sustainability Due Diligence Directive, which mandates certain expectations across the value chain.

The Initiative for Responsible Mining Assurance (IRMA) has developed a standard to provide what it calls "one-stop coverage" of the impacts of industrial-scale mines.

Its members include miners such as Albemarle and Anglo American, buyers such as Ford and Microsoft, labour groups, communities, NGOs, and expert associations.

Kallanish has interviewed Aimee Boulanger, IRMA's executive director, to better understand how the organisation works and what benefits it provides to participating companies.

 

➡️ What is the IRMA standard?

It is the world's most rigorous standard for mining in that it’s not just taking status quo, but it seeks to define the best practice already being implemented around the world today. It’s practical – it's all things we do know how to do, trying to create an expectation that we will do the best to protect environmental and social values where we mine. It's also the globe's only standard equally governed by NGOs, mining-affected communities, labour unions, working across the table from mining companies, their customers who buy mined materials – such as carmakers, jewellers, wind turbine makers, electronics companies – and then also finance and investment companies. Six houses equally govern IRMA: miners, their customers, the investors, the NGOs, the communities, and labour unions. They all have veto authority against the others: while all six of those houses have two seats each on our governing board, if you have two no votes from the same house, it blocks a decision.

 

➡️ How did IRMA start?

It didn't come out of either just one NGO or a mining industry trade association. More than 15 years ago, when IRMA was first conceived, the jewellery sector saw more and more criticisms of the mine level pushing up to the jewellery level. They reached out to civil society groups, including groups that were campaigning for mining reform, saying they wanted to work together, be held to account and be part of the solution.

When they sat down to have that conversation, civil society and the end brands looked at the Forest Stewardship Council or the Marine Stewardship Council, which have multi-stakeholderism at the base. That’s bringing in the mining industry, labour, Indigenous rights leaders and other affected communities, talking about how we can create market value for greater environmental and social responsibility. That's the theory of the IRMA system today, to have something which is trusted by all, but encourages companies to go beyond just what the law is – at least they should meet the law, and that's why that's chapter number one in the IRMA standard – but beyond that, to do more to protect environmental and social responsibility. It's a bit of trying to give each sector its own power, but also ensure that all are also buying into that process of bringing people together who are committed to collaborating, because IRMA really isn't going to work if they all come in and just decide to argue with one another. If you come to the IRMA table, you're going to have to accept that there's not a private sector domination, it really is equal for all sectors there.

 

➡️ Does the standard get updated over time?

Yes, and we're in the middle of that right now, because the first draft of the standard came out in 2014 for public review, and there were comments, working groups and debates on the potential metrics of responsible mining. In 2016, a revised version was put out for more debates, more working groups across stakeholder sectors. Then we went to Zimbabwe to test it in one place, to Montana to test it in a different context. And then the 2018 standard came out, and that is the one that mines are being measured against now. However, we're in the middle of revising that right now. For more than a year, a new draft has been out in the world, with more working groups across stakeholder sectors – which people just volunteer themselves to come into.

 

➡️ What changes have you observed in the sector since you joined IRMA in 2011?

One of the most powerful changes is the progression of climate change and the need for materials associated with energy transition. In IRMA's early days, the jewellery sector was a leader in seeing that their materials at an end brand were directly connected to what was happening at the mine level. But most other sectors were not looking at that, most carmakers or electronics makers would say to take problems to the mining companies, stressing their supply chains are very complicated even 10 levels between the mining company and the sheet metal or the battery they buy.

But that has changed dramatically over the last 10 years, especially over the last two years. Due diligence legislation and its increasingly mandatory expectations legally, whereby end brands should map and understand their supply chain, their influence and responsibility, are influencing them to be more active. It's creating more daylight on who are mining companies. We know who sells us our phones or our cars, but we don't usually know the names of mining companies. But more and more are being brought out into the sunlight, which helps to hold them accountable.

Moreover, EV makers already understood that part of what they're doing is responsive to a global need for more responsible practices, with the energy transition at the base. They know that, when touting greenhouse gas emissions reductions of EVs, if there are contaminations of drinking water or human rights abuses in their supply chain, it looks like it's in direct conflict with the whole purpose of their product. We didn't have to do a lot to convince them to join IRMA. And that has really pushed the whole supply chain to lean into that. Of course, the energy transition is also bringing an ironic, big demand for new and more extraction. Normally, what we would really want to see in an industry that has as much impact as industrial-scale mining does, is the reduction of this extractive behaviour. But because we need these materials, we're looking at how to still come up with that idea of reducing impact. Is it through making products that are more durable? Is it through increasing the circular economy – building things that can be disassembled, recycled and put back in the chain? Is it dealing with the equity issues that some parts of the globe are using and often wasting far more materials than others? And often the countries which are not consuming as much are where the materials are being extracted and the impacts are felt.

 

➡️ Is the circular economy part of the standard?

It was not part of the 2018 standard, because we were really focused on how you take mining companies and make them be more responsible. We're looking now, though, at how the new standard can value for companies which see themselves as materials companies, rather than just new extraction. Honestly, there's still a question in our minds of how to go about that.

The recycling sector has a whole bunch of its own challenges and has been operating in the dark. Many of us feel virtuous about recycling our materials so they don't go to the landfill, but recycling produces a lot of greenhouse gas emissions. When you think about young children running over scraps heaps in Asia for electronics materials, it has all kinds of risks to health and labour issues, so it needs a whole set of special requirements there. We're definitely looking with other groups about not only how you drive more recycling, but how you drive more responsible recycling as part of it. There are mining companies doing that already. Sibanye-Stillwater is putting out as much material from recycling catalytic converters, and taking the platinum-palladium out of them, as it is extracting new material. We're looking at how to make sure we give them credit when they do their IRMA audit.

 

➡️ In addition to the new standard, is there anything else on the horizon?

A few different ideas. One is to ensure that we have many more mining companies coming in. We're amidst our first 20 audits, so it took us more than 15 years to have a standard that was agreed upon and trusted enough by civil society and industry. Now we need to scale up so many more mines come in, and then we can begin to look at how to create value for them to improve. It's not a pass-fail standard. We don't hand out a certificate that says you passed, you're a responsible mine.

Instead, we're measuring against a score of 100% and in each of these different areas, social, environmental, responsible business practices. We're really trying to get them to come in, be transparent, and see them improving. And we want to do that without losing the credibility of the communities where this happens. Another issue is that it is estimated that about half of the materials associated with energy transition are going to come from Indigenous people's lands, and many Indigenous people have had a relatively negative experience with extraction to date. If we're relying on these materials, it is essential the companies work directly with Indigenous communities to reverse that whole narrative of 500 years of colonial extraction on Indigenous lands. How do you create reassurance that it's not going to be a destruction of cultural heritage? It's not going to be short-term profits for the loss of clean drinking water and community safety. How can you say this is really going to be with free, prior, informed consent of Indigenous people and clear benefit-sharing so they're not trading one value against another? That's really a key next frontier, which will benefit all communities where mining happens, not just those where the Indigenous people live.

 

➡️ Why should a company apply for this standard?

There are a few different “whys”, one is the mining. Mined materials come from dozens of different countries around the globe. The laws governing how those materials are extracted change based on the location. If you are buying the raw materials, you do not necessarily have confidence that if your suppliers are following the law, that's enough. Often, it's not enough. We know that significant harm is happening at mine sites around the world, so one reason to apply for the standard is to reassure ethically that the products we're each using each day are not being sourced with significant harm, especially when that's not necessary. We know right now how to mine in much better ways; we don't need 20 years of research to figure it out – but we need to create an incentive for that.

IRMA is a way for those end brands to create incentives for their suppliers to provide raw materials that are not sourced with harm. And we're in a moment now where those end brands can be asking for the same thing that NGOs, affected communities, Indigenous rights leaders and worker advocates are all asking for. And when they, in unison, turn back to the mining industry and say, “This is what we expect and demand, and we're willing to pay for this,” that's a powerful market shift. The standard also supports governments – which have been pressured to look away and just take the tax revenue or whatever other payments are coming in – it pressures them to step up and set up a rigorous regulatory structure.

 

➡️ Which sectors can apply for the standard?

At this moment it's just mining companies. The new standard that comes out at the end of the year will also allow standalone mineral processing companies, such as smelters and refiners. By year-end, buyers can use IRMA as a chain of custody standard. If a carmaker prioritises buying from companies who've been transparent and being audited against the IRMA standard, and then meeting these levels of achievement, they can demonstrate their purchase choices. They can track back in a chain of custody, proving they're actually buying from those mines.

 

➡️ Are the smaller companies slightly more reluctant to apply?

Not always. While Anglo American and ArcelorMittal both sit on our board of directors for the mining sector and they are large companies, when you look at who's doing auditing right now, you have the French company Eramet, which is not a huge company, Albemarle, SQM, Gerdau... These are smaller companies. A smaller company may have less infrastructure around it. And are they daunted when they look at IRMA's 25 chapters? Yes, they are. Theyoften ask whether they will need to hire consultants. But a lot of what's in the IRMA standard is what the world is already asking them to do. For some of it, they will be able to take quite a bit of credit for what they already do.

In some cases, big companies have a challenge, because some of them have already been telling the world they are operating according to best practices. And that can create anxiety if they are not audited as top performers. If you are looking at an Anglo American, a Rio Tinto, a Barrick, or a Newmont, you may expect that they should be performing at the top because they're large and affluent, and that's not always the case. Many of them own sites that have been operating for decades, with a whole set of challenges from being constructed at a time when the latest technology was either not available or not incentivised for them to use – which can feel like a reputational risk. In some ways, this can be a place for smaller companies to distinguish themselves, be globally known for their effort to step up and lead.

We have very strict rules to protect on competition and antitrust, but companies can share tips on how to address certain chapters of the standard. Companies also come to IRMA for help because we don’t charge them for our time.

 

➡️ How long does it take between applying for the standard and actually obtaining it?

It depends on the mining company. The self-assessment process could be done in a couple of weeks, but most companies take months. The following step is selecting one of three audit firms, the only ones we've approved globally. We've spent a lot of time training them, because the quality of an audit is not only on the standards. Then the auditors analyse the data, contact the company if they need more, then schedule an on-site visit, which is usually four to seven auditors on a site for somewhere from four to eight days, walking the ground and looking at the site systems, talking to staff, talking to workers and the community without management in the room.

They also talk to any NGOs interested in participating. Most mining companies are taking up to a year to go through that process. Then we allow them something which is unique: when their audit report comes back to them, they can release and go public, or they can take up to one year to improve a shortlist of scores, to be verified again by the auditors. Thus far, every single mining company has taken that opportunity. They've taken their optional one year to make improvements and then put out the report.