Human Rights

knowledge-is-powerAs part of our commitment to the continuous improvement of our corporate social responsibility efforts, we are constantly monitoring the development of new standards and good practices. We have drawn upon the key questions and guidance in the 2015 UN Guiding Principles Reporting Framework for the preparation of the human rights section of this year’s report. quote-humanrights

Part A: Governance of respect for human rights

A1:  What does the company say publicly about its commitment to respect human rights?

  • Human rights have always been important to Nevsun and to our operations at the Bisha Mine in Eritrea. A variety of human rights provisions were included in the core policies developed for the Bisha Mine from the outset of operations.[1]
  • As part of our implementation of the UN Guiding Principles on Business and Human Rights, Nevsun has adopted a stand-alone Human Rights Policy and integrated a section on human rights in the Nevsun Code of Ethics in December 2014.
  • The Nevsun Human Rights Policy makes a series of commitments to ongoing human rights due diligence, in line with the UN Guiding Principles and to respecting human rights in the workplace and in communities in which we operate.
  • In terms of governance, the mandate of our Safety, Health & Environment Committee includes oversight of the implementation of our Human Rights Policy and addressing concerns raised through the Whistleblower Policy.
  • The Nevsun Human Rights Policy, the Code of Ethics and related policies relevant to human rights at Nevsun and the Bisha Mine are available our website.

A2:  How does the company demonstrate the importance it attaches to the implementation of its human rights commitments?

  • The Vice President, Corporate Social Responsibility leads in the implementation of our Human Rights Policy and provides guidance to subsidiary management and each of the inter-departmental corporate social responsibility working groups at the operational level.
  • One of the requirements of our Human Rights Policy is for each of our subsidiaries to respect, promote, and support human rights in its operations. In 2015, we have continued to work with BMSC on a variety of human rights initiatives, including the development of a stand-alone Workers’ Rights Policy and an inter-departmental working group to help embed respect for human rights at the operational level.
  • The Board of Directors of BMSC is comprised of senior leaders from Nevsun and ENAMCO. At board meetings, a variety of human rights issues are regularly discussed. In particular, the Board has discussed the findings and recommendations from the 2015 HRIA Audit, including emerging issues related to exploration, road safety, staff turnover and security. Moreover, there is ongoing dialogue about developing the local workforce and supply chain for the Bisha Mine while ensuring that the prohibition against forced labour is fully respected.
  • Employees and contract workers are made aware of the importance of human rights through human rights training that has been included in our induction training for new employees and through specialized training for specific departments. In 2015, we focused on training on human rights and the Voluntary Principles for the BMSC security department and our private security department. Moreover, many of our managers and employees have participated in the on-going human rights impact assessments that have been conducted at site, which contributes to their awareness and discussion on human rights issues. In 2016, we will continue to build awareness about human rights at site, through the roll-out of the BMSC Workers’ Rights Policy and further training initiatives.
  • In our business relationships, we emphasize the importance of human rights in a variety of ways: by including contractual provisions and conducting screening and audits of contractors; by conducting human rights training for private security guards; and by ongoing dialogue with managers of Eritrean contractors and suppliers, our partners on the BMSC Board of Directors, as well as with Eritrean government officials involved in the regulation and monitoring of the mining sector.
  • Lessons learned in the reporting period:
    • Enthusiasm about specialized training for specific departments – e.g. of VPs training
    • The development of new standard operating procedures is a key focus for embedding, but it takes time to develop them in an effective and participatory manner and to train a full department
    • Balance between independent auditing and assessment and need to support managers in implementation

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Part B: Defining the focus of reporting
  • The geographical focus of our reporting is the Bisha Mine in Eritrea. In line with the commitment in our Human Rights Policy, Nevsun also considers human rights as part of our due diligence process in evaluating for potential acquisitions opportunities in other countries. Nevsun evaluated a number of acquisition opportunities in 2015 but did not complete any acquisitions.
  • We have taken a comprehensive view of the human rights issues that are relevant to our operations and business relationships in Eritrea as evidence by the human rights impact assessment (HRIA) of the Bisha Mine that was published in 2014 and the follow-up Audit that was published in 2015.
  • The issues addressed and publicly reported in the HRIAs include:
    • Freedom from forced labour
    • Safe and healthy working conditions
    • Just and favourable working conditions
    • Freedom of association
    • Non-discrimination
    • Freedom from harassment
    • Freedom from child labour
    • Human rights and the environment, particularly the right to water
    • Support to human rights through community development initiatives
    • Cultural heritage
    • Security and human rights
    • Grievance mechanisms
  • In 2015, the latest HRIA Audit of the Bisha Mine identified some emerging issues related to potential human rights impacts that we are addressing proactively:
    • Exploration (land rights, economic rights, right to food, and cultural rights)
    • Staff turnover (labour rights)
    • Road safety (right to life, right to safe and healthy working conditions, right to health and children’s rights)
    • Security and human rights (right to life, liberty and security of the person, right to safe and healthy working conditions, and civil and political rights).
  • While our approach to human rights due diligence and reporting will remain comprehensive, we have maintained a constant focus on freedom from forced labour over the years, as one of the salient issues related to our business partners and local supply chain in Eritrea.
  • There are no additional severe impacts that have not been reported here or in the publicly-available HRIA reports.
  • In terms of the stakeholder engagement related to our human rights efforts, there has been extensive and focused engagement with affected stakeholders about human rights over the past three years that builds upon our ongoing dialogue. This has been undertaken by the independent experts that have conducted our HRIAs and supported the implementation of related risk assessments for the Voluntary Principles on Security and Human Rights. In addition, we have engaged extensively with other stakeholders in Eritrea and internationally about human rights issues and due diligence at the Bisha Mine, including with Parliamentarians, government officials and ambassadors, UN officials, civil society organizations, academic and policy institutions, and journalists.

[1] These include the BMSC Environmental Policy, Health and Safety Policy, Social Responsibility Policy, Employee Policy, Security Policy and Code of Conduct. These policies are available on our website.

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Voluntary Principles in Human Rights and Security Training

Since late 2015, the Company has used an external expert/trainer, Mr. Karim Laz (formerly with the Canadian military whom

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Part C: Management of human rights initiatives/goals

Detailed information about the management of human rights at the Bisha Mine has been published in the comprehensive HRIAs of the Bisha Mine. The following table summarizes the key findings of the 2015 HRIA Audit as it pertains to the specific policies, stakeholder engagement and ongoing due diligence that we are implementing in relation to human rights.

We are committed to managing human rights in a coordinated and systematic manner, and are investing in the refinement of our overall system of human rights due diligence at the Bisha Mine. This includes ongoing human rights training initiatives, integration of human rights considerations into our environmental and social management plans and standard operating procedures, regular human rights assessments and targeted auditing activities, and ongoing dialogue about human rights with our business partners [1]. In this regard, we will continue to integrate and act upon the findings and recommendations of our HRIAs; we will track our human rights performance; and we will communicate externally in our annual CSR reports and in stand-alone reports.

[1] For more information, see the section on the “Evolution of Human Rights Due Diligence at the Bisha Mine” at pp. 61-66 of the 2015 HRIA Audit.

OUR HUMAN RIGHTS INITIATIVES/GOALS [2] SPECIFIC POLICIES AND PROCEDURES OUR ACTIONS IN 2015
Freedom from forced labour
(see pp. 42-44 of 2015 HRIA Audit)
  • BMSC Social Responsibility Policy and BMSC Employee Policy
  • Screening procedures to verify that all employees and contract workers at Bisha have been cleared from national service
  • Ongoing dialogue with BMSC workers, contractors’ workers and managers and the National Confederation of Eritrean Workers
  • Ongoing screening of all new employees and contract workers at Bisha
  • Independent audits and dialogue on human rights with key Eritrean suppliers
Safe and healthy working conditions
(see pp. 44-46 of 2015 HRIA Audit)
  • BMSC Health and Safety Policy and Code of Conduct
  • Health and safety program covering PPE, task-specific standard operating
    procedures and ongoing safety training
  • Ongoing dialogue and training with workers
  • No fatalities or occupational diseases reported
  • One minor lost time injury occurred (fractured foot)
  • Continuous learning and improvement from safety incidents or near-misses
Just and favourable working conditions
(see pp. 47-48 of 2015 HRIA Audit)
  • BMSC Employee Policy
  • Human resources policy framework that respects Eritrean labour law and international standards and ensures fair benefits, entitlements and remuneration
  • Ongoing dialogue between our human resources managers and employees about wages and benefits
  • Monitoring of wages and benefits for other employers in Eritrea to remain an employer of choice
  • This issue is being proactively monitored and discussed in response to a recent increase in staff turnover
Freedom of association
(see p. 49 of 2015 HRIA Audit)
  • There is no specific BMSC policy on freedom of association; however, the right is protected under Eritrean labour law
  • Ongoing dialogue at the BMSC Board level.
Non-discrimination
(see pp. 49-51 of 2015 HRIA Audit)
  • BMSC Social Responsibility Policy and Employee Policy
  • Commitments to the hiring and advancement of Eritrean workers and female employees through specialized training programs offered at our Training Centre
  • Ongoing efforts to recruit and promote Eritrean workers and female employees
  • Continued attention to ensuring that there is respect and cultural sensitivity between Eritrean and expatriate workers
Human rights related to the environment, particularly the right to water
(see pp. 52-54 of the 2015 HRIA Audit)
  • BMSC Environmental Policy and Social Responsibility Policy
  • Specific environmental management plans and standard operating procedures related to water consumption, treatment, recycling and monitoring
  • Launch of a new hydrological study to gather information about potential waterrelated impacts
  • Commissioning of a new water treatment plant to increase water recycling capacity and diminish water consumption from the regional aquifer.
  • Community assistance projects supporting access to water
Support to human rights of local communities through community development initiatives
(see pp. 54-55 of the 2015 HRIA Audit)
  • BMSC Social Responsibility Policy and Code of Conduct
  • BMSC’s Community Assistance Plan (CAP) sets out the strategy and process for developing community development initiatives in consultation with local communities and government authorities
  • Two pilot projects launched related to enhancing access to water for the Tekreret and Aderat communities
  • Budgets have been secured and planning has commenced for future CAP projects in 2016
Respect for cultural heritage
  • BMSC Social Responsibility Policy and Code of Conduct
  • BMSC also has a Cultural Heritage Management Plan
  • Ongoing monitoring and collaboration between the Exploration Department, Environmental Department and Community Liaison officers to ensure that exploration activities do not have negative impacts on
    cultural heritage
Security and human rights
(see pp. 57-58 of the 2015 HRIA Audit)
  • BMSC Security Policy
  • Implementation of the Voluntary Principles on Security and Human Rights
  • Development and delivery of specialized training modules on human rights and the Voluntary Principles for the BMSC Security Department and Binae security guards
  • Updating the risk assessment for the Voluntary Principles
  • Updating the standard operating procedures for the Security Department
Grievance mechanisms
(see pp. 58-60 of the 2015 HRIA Audit)
  • BMSC Social Responsibility Policy, Employee Policy and Code of Conduct
  • BMSC Stakeholder Engagement Plan includes a community grievance mechanism
  • Nevsun’s Whistleblower policy is open for complaints on non-financial matters including human rights concerns
  • The community grievance mechanism is being updated to reflect evolving good practice
  • There has been a campaign to promote the Whistleblower mechanism at site
  • Ongoing efforts to promote a dedicated grievance mechanism for the workers of Eritrean contractors and suppliers

[2] While our HRIA reports also cover issues related to child labour and freedom from harassment, there have been no findings or allegations related to these issues. Therefore, we do not consider these to be salient issues for the purposes of this report. Nonetheless, we will continue to monitor these issues through future human rights assessments, ongoing engagement with workers, suppliers and community members and our grievance mechanisms.

2016 Priorities
  • rolling out a stand-alone BMSC Workers’ Rights Policy to consolidate and strengthen the existing commitments to human rights at site
  • further training and implementation of the Voluntary Principles on Security and Human Rights for the Security Department and Binae Security
  • supporting our managers, workers and contractors in adopting human rights due diligence as required as we transition from the copper to zinc phase of operation
  • ongoing audits and dialogue on human rights with Eritrean contractors and suppliers