Sustainability assurance
Xstrata’s sustainability and risk assurance processes are the key
measures used to provide Xstrata Board and management with
assurance that the Group’s Business Principles, policies and standards
are being met and that material risks are being identified and managed
effectively. Audits, incident investigations and routine reporting provide
management with information and data to monitor the performance
and effectiveness of the SD systems that are in place.
Xstrata’s SD assurance programme is characterised by:
- External third party audits against the SD Framework:
Regular third party audits against Xstrata’s SD Policy and Standards
at all managed operations and projects, supplemented by more
frequent internal management and risk/hazard focused audits;
- Focus on performance as well as systems:
Audits that review
systems and, importantly, performance against systems, including
interviews with site personnel at all levels, from management
to operator;
- Detailed SD improvement plans:
Regardless of the audit score
and in line with our commitment to continuous improvement, each
audit identifies potential improvements and summarises the actions
site management can take to further improve SD performance in a
SD improvement plan; and
- Specialist SD risk audits:
In addition to audits against our SD
Framework, in-depth SD risk audits are conducted by Group
Internal Audit utilising appropriate specialists to assess specific
SD risks at the sites or region that have been identified in each
business’s annual risk reviews.
2010 review of sustainable development
assurance process
Since the inception of the Group HSEC Standards Audit in 2005,
and its subsequent evolution into the Group SD Standards Audit,
regular feedback has been sought on how the assurance programme
could be improved. In keeping with this continuous improvement
approach, Xstrata conducted a thorough review of its SD assurance
processes in 2010.
A number of changes and improvements emerged from this review,
most notably:
- Each managed operation will undergo a third party SD Standards
audit at least once every three years using updated audit protocols,
including the creation of separate audit protocols for the pre-approval
and post-approval phases of major project developments;
- An increased number of trained, independent audit resources
will be made available through the creation of a pool of qualified
independent third party SD auditors, approved at the Group level;
- Xstrata’s commodity businesses will report consolidated reviews
on the implementation and effectiveness of site and project SD
improvement plans to the Group Executive Committee and Board
HSEC Committee. The plans address the findings of the audits
together with the outcomes of other internal reviews of the site’s
SD management systems and performance, and detail the actions
required to implement and maintain Xstrata’s SD Framework; and
- The SD risk audit process has been incorporated into Xstrata’s
internal audit programme.
In particular, the incorporation of the SD risk audit process into the
Internal Audit programme has removed duplication, improved efficiency
in our audit processes and further embedded SD into our operational
and business decision making. In 2010, Group Internal Audit visited 29
Xstrata sites in eight countries as well as visiting four divisions and Group.
In total, they audited 34 different SD risks, including community relations,
vertical openings, contractor management, aviation, furnace eruptions,
resettlement, mine closure and tailings storage.
Each commodity business supplements Group-mandated SD Standards
and risk audits with a range of additional, regular SD audits that include
major hazard audits, legislative compliance audits, and specialist audits
in areas such as electrical, lifting and loading, and tailings dam integrity.
The commodity businesses review their SD improvement plans and
monitor progress. A consolidated progress report is submitted
annually to each commodity business Audit Committee, and the
Board Audit and HSEC Committees.
In 2010, Xstrata’s commodity businesses each submitted a comprehensive
review of progress against its sites’ SD improvement plans. This exercise
was performed following five years of SD Standards audits to allow sites
to concentrate on closing out actions from these audits and Group SD
time to review and update our audit protocols to reflect leading audit
practice. Third party audits against Xstrata’s SD Framework have resumed
using the updated protocol in 2011.
Risk and crisis management
Xstrata has a value-driven approach to risk management and a structured
and comprehensive risk management framework and system has been
implemented across the Group. An ongoing bottom-up self-assessment
process is in place, with results updated to operational commodity
businesses’ and the Group’s risk registers.
Our risk management policy requires each commodity business and
corporate function to undertake a comprehensive annual risk review
as part of an ongoing process for identifying, evaluating and managing
significant risks including material SD risks. The conclusions of this
review are fully integrated into the annual business strategies and plans
presented for Board approval. Progress against plans, significant changes
in the business risk profile and actions taken to address controls and
mitigate risks including SD risks are reported quarterly to both the
business and Group Audit Committees as well as to the Executive
Committee and the Board.
We regularly review and publicly report the principal risks and
uncertainties that may affect our ability to deliver our business strategy
effectively, the potential impact on our business, and the controls in place
to mitigate these risks. Material SD risks are addressed as an integral part
of this process. More detail is available in Xstrata’s 2010 Annual Report
on principal risks and on risk management processes.
Each commodity business has processes for monitoring and reporting
progress on, and completion of, tasks related to treatment of key risks
and regular risk reviews are carried out by independent consultants and/
or Xstrata’s Group Internal Audit for insurance purposes. We conduct
annual workshops with commodity business risk champions to facilitate
the sharing of risk learnings and consistency of practices. There is
a particular focus on the execution of major projects in the Group
internal audit programme, which has been aligned and integrated
with SD assurance activities.
The Group crisis management plan is supported by crisis
management plans at each commodity business. Xstrata’s SD
Standard for Emergencies, Crises and Business Continuity specifies
the requirement for all sites and commodity businesses to implement
emergency response, business continuity and crisis management
plans in consultation with external emergency agencies. The plans
include clear protocols for when and how to escalate a crisis at the
commodity business level to a Group crisis. They also cover training
for employees and other stakeholders, annual reviews and the
incorporation of lessons learnt from actual emergencies and
simulations into plans.