Governance and CSR Management

HUMAN RIGHTS AT OUR OPERATING MINE

We continually refine our activities to meet the highest ethical standards, including the fair treatment of all stakeholders associated with our operations. Our policies and procedures are regularly updated to reflect this commitment.

As 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. For the second year in a row, 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 report.

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.
  • Nevsun’s 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 on 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 2016, we have continued to work with BMSC on a variety of human rights initiatives, including the formal adoption of a Worker Rights Policy by the BMSC Board. For our new Timok Project in Serbia, we have commissioned an HRIA that will be coordinated with other environmental and social impact assessment processes. The HRIA will be completed and published in 2017.
  • The BMSC Board is comprised of senior leaders from Nevsun and ENAMCO. At board meetings, a variety of worker rights issues are regularly discussed in follow-up to the recommendations in prior HRIA reports. The Board of Directors has commissioned another independent HRIA Audit to be conducted in 2017.
  • 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 2016, we completed the training on human rights and the Voluntary Principles for all the security guards at Bisha.  This was an intensive 3-day training course facilitated by an external security and human rights expert. Currently we are updating our induction training for visitors and new employees to continue the roll-out of the BMSC Workers’ Rights Policy.
  • 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, as well as with Eritrean government officials involved in the regulation and monitoring of the mining sector.

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 has commissioned a HRIA for the Timok Project.
  • We have taken a comprehensive view of the human rights issues that are relevant to our operations and business relationships in Eritrea, as evidenced 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. Follow-up work on the HRIA’s recommendations has continued throughout 2016 and another independent HRIA Audit will be published  in 2017.
  • 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
    – Grievance mechanisms
    – Exploration (land rights, economic rights, right to food, and cultural rights)
    – Staff turnover (labour rights)
    – Transportation and 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, as well as our international stakeholder community.
  • 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 four years as part of our HRIA process. We have continued to engage extensively with 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.

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 our last 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, social management plans, standard operating procedures, regular human rights assessments and targeted auditing activities, and ongoing dialogue about human rights with our business partners. 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.[2]

SUMMARY OF 2016 HRIA AUDIT FOR BISHA OPERATING MINE

OUR HUMAN RIGHTS INITIATIVES/GOALS SPECIFIC POLICIES AND PROCEDURES OUR ACTIONS IN 2016
Freedom from forced labour
  • Worker Rights Policy, Social Responsibility Policy and 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, managers and the National Confederation of Eritrean Workers
  • Ongoing screening of all new employees and contract workers at Bisha
Safe and healthy working conditions
  • Worker Rights Policy, 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
  • Continuous learning and improvement from safety incidents or near-misses
Just and favourable working conditions
  • Worker Rights Policy and 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
  • Worker Rights Policy
  • Ongoing dialogue at the BMSC Board level and with the National Confederation of Eritrean Workers (NCEW)
Non-discrimination
  • Worker Rights Policy and 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
Security and Human Rights
  • Worker Rights Policy and Security Policy
  • Commitment to implement the Voluntary Principles on Security and Human Rights
  • Intensive training course on human rights and VPs completed for all BMSC Security Department and Binae security guards
  • Standard operating procedures related to VPs have been developed for BMSC Security Department
Community
  • Worker Rights Policy
  • Hydrological studies were conducted to assess potential impacts on local water sources
  • Community projects related to water and agriculture have been completed in Tekeret and are advancing in Adarat and Ad Ibrahim

[2] 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.

2017 HUMAN RIGHTS PRIORITIES FOR BISHA OPERATING MINE

  • Continue to roll out the BMSC Workers’ Rights Policy through engagement with and training for our workers.
  • Continue to apply screening procedures (to uphold the prohibition against national service workers in the mining sector) to all employees, contractors and suppliers that work at the Bisha Mine.
  • Continue to conduct audits and engage in dialogue with our contractors and subcontractors about workers’ rights issues.
  • Continue to refine and promote different grievance mechanisms to encourage the early resolution of any concerns from workers, contractor workers or community members.
  • Continue to implement the Community Assistance Program with a focus on water and agricultural projects for local communities.
  • Ensure that BMSC’s environmental, social and worker rights policies are respected in relation to expanded exploration survey work around the Bisha Mine.
  • Develop and implement site-level action plans for human rights due diligence and the VPs under the remit of the Inter-departmental Working Group.
  • Commission an independent HRIA Audit to monitor and report on progress and emerging issues in 2017.
  • Continue to make the results of our engagement and audit activities publicly available through our CSR Reporting process.