“Mawson Gold has strong ESG leadership and demonstrates a clear desire to operate in a sustainable manner both now and in the long term” – Digbee Ltd.
In 2021, Mawson completed its inaugural, independent assessment of its ESG policies and management at the corporate and project levels in Finland and Australia.
The assessment report was undertaken by a team of accredited independent ESG experts who have deep experience in mining projects similar to Mawson’s at Digbee Ltd.
Mawson is the first mining company to self-report its Digbee ESG score, achieving an overarching score of ‘BB’. Rajapalot scored the highest and across the business units with a ‘BBB’, and confidence intervals confirmed a ‘AAA’ score is achievable through risk mitigation indicating no red flags.
Mawson is proud to have been the first mining company to publicly publish these scores as we believe it is a demonstration of our commitment to disclosure and transparency as well as strong governance and accountability to the environment, local communities and shareholder value.
We are particularly encouraged by the ‘BBB’ score our Rajapalot project in Finland received.It endorses how deeply embedded ESG stewardship is to everything that Mawson does. Rajapalot is one of the most broadly supported projects in Finland with demonstrative support from local communities, municipalities, reindeer herders, and Lapland’s political and administrative leadership, amongst others.
The ‘BB’ score for our Victorian projects reflects the early-stage nature of our operations and that of the policies, procedures and relations with the local communities that we already have in place.
Mawson has had an active ESG program operating for many years, and we are constantly developing and adding to it as our projects grow and develop. The Digbee assessment helps us identify areas to focus and continue to improve our ESG performance.
Upon the release of Mawson’s inaugural score, Jaime Struass, CEO of Digbee commented: ”We commend Mawson’s initiative in self-reporting their inaugural Digbee ESG Score. ESG is all about transparency and continuous improvement, and we are proud that Digbee’s ESG platform is recognized as an enabler of this within the mining industry. There are billions of dollars of investment capital looking for companies who wholly embrace ESG and can demonstrate real action on the ground to improve conditions across the ESG spectrum. Mawson have demonstrated this today, and as more companies step forward in this way, it will create the transparency and culture of improvement necessary to drive real change.”
• The company is clearly actively aware of sustainability issues and should be congratulated for their approach.
• The senior leadership team includes expert(s) in ESG.
• The CEO is easily contactable via the website and is therefore available for direct feedback.
• Alignment to standards (inclusive of Towards Sustainable Mining) is as appropriate for current activities.
• The company / members of the company are members of relevant organisations such as FIBS (Finnish Business Sustainability Framework) and industry forums where members of the Executive Committee support policy development.
• Evidence submitted to prove the organisation allocates budget to the active management of ESG relevant to current project activities and baseline studies.
• The Board of Directors includes a Nominating Committee which includes diversity as a key consideration with respect to director recruitment. Evidence demonstrates a policy and process is in place to ensure transparency and gender diversity in Board selection processes.
• A majority vote policy is in place should a shareholder not agree with the company’s allocation of remuneration against company interests Good Governance Framework is in place highlighting appropriate representation of ESG on the Executive Committee who are skilled in communicating and consulting with shareholders regarding ESG concerns.
• Proactive communication regarding ESG management via Mawson Gold’s website and social media channels is evident.
• Annual independent audit verification provides site and corporate level compliance assurance to ESG requirements within the organisation.
• Appropriate tools, processes and accountable personnel are in place to manage the risk of exploration permitting compliance and reporting.
• Compliance with the anti-bribery and corruption principles contained within the Audit Committee Charter is verified within the organisation through the annual independent auditing process. This is supported by appropriate training and communication.
• A policy exists to protect sensitive areas through the avoidance/ restriction/ relocation of exploration activities when necessary, acknowledging that this may incur additional costs and increased project timelines.
• A great deal of work is being undertaken to ensure that environmental aspects are considered on a routine basis at all levels of the organisation. Robust engagement with stakeholders, especially within Finland is also evident. The opportunity exists to ensure that good practice exhibited within Finland is utilised across all projects.
• Robust government engagement is in place for the Finland project.
• While appropriate for the current size of the company and the maturity of their projects little evidence was provided to detail leadership ESG capability building within the organisation.
• While evidence was submitted to demonstrate the management of Board skills and capabilities is in place, no specific competencies or diversity requirements related to ESG were documented.
• Gender based diversity is increasingly positive with 29% of project teams and leadership of both Australia and Finland being female, however information submitted did not provide robust insight to diversity beyond that of gender (such as ethnicity, disabilities and diversity of thought).
• No evidence was provided for renumeration being linked to aspects of sustainability performance.
• Whilst the submitted evidence demonstrates that Mawson Gold are aware of and actively managing ESG risks, the evidence did not demonstrate a formalised approach to risk management.
• While the CEO was easily accessible through the website and a free dial in number is being constantly monitored, no information was provided as to how this communication is addressed including the process to ensure that individuals are satisfied with the response and that this input is incorporated into project and company plans.
• With the exception of financial resilience, no evidence was submitted to suggest that a formalised reliance plan is in place nor a process for periodic testing of resilience.
Project positives – Rajapalot
• Rajapalot is located in Finland which is currently (2021) ranked second globally in terms of investment attractiveness.
• The company has been working on this project for a number of years and therefore has a good understanding of the terrain.
• Notwithstanding the global increase in civil unrest, Finland remains very positively ranked with regard to the risk of political, ethical or civil risk of conflict. Whilst currently there is very little civil unrest, a 2020 global assessment identified Finland as a country that is likely to see a significant increase in civil unrest.
• The Government of Finland wants to encourage development and migration of people into the project area with active support for mine development supporting this initiative.
• The majority of the project workforce has been drawn from the local community.
• The project context does not require security and there are no firearms on site.
• At present the project utilises existing forestry roadways and no major impact infrastructure needs to be erected in the near term.
• The project currently makes use of on-grid power supplemented by generators where necessary. It is anticipated to utilise on-grid power in the future where possible.
• No negative impacts to water quality or quantity recorded or observed at this stage of the project; the project uses a very small percentage of the catchment’s water and is thus not likely to be a contributor to water stress.The good quality of water and excess quantity available means it may be feasible for shared value water initiatives to develop in future. The project does not discharge any wastewater into the environment. The actions being taken and as reported represent good practice.
• The project may result in the active mining of Cobalt outside of the Democratic Republic of Congo whilst utilising responsible mining methods, thereby decreasing Finland and global reliance on the DRC.
• The company is active on social media and regularly announces site activity updates, no negative comments regarding the project’s activities have been observed during this scoring exercise.
• A very positive regional survey results indicates positive attitudes of local community members. Nearly 70% of survey respondents indicated support for mining activities in the local community.
• Extensive baseline studies and impact monitoring of current activities is being undertaken. Demonstrated commitment to minimise impact of activities and support local, regional and national conservation efforts. For some areas, baseline data has been collected for more than five years.
• The project has demonstrated recognition of management of ESG and support of biodiversity and conservation. The project is currently embarking on an ESIA for the Project.
• While the project is insufficiently advanced to have fully developed mine and closure plans, there is appetite for gathering stakeholder feedback and incorporating it into mine design.
• Rehabilitation plans have been drafted and a security deposit for rehabilitation has been lodged.
• Annual first aid course and other evidence provided which supports the positive safety culture on site and the maturity of processes in place. No recorded injuries over an extended period of time.
Project negatives - Rajapalot
• While a small portion of the total permit area lies within biodiversity conservation areas (Natura 2000), it should be noted that Mawson is permitted to complete all exploration within these zones.
• Whilst it has not been approved, there is a suggestion submitted to implement a national (Finnish) protection area. This would be within the existing Natura 2000 zone.
• While not yet needed, re-zoning is not fully resolved currently to permit expansion from exploration to mine development. Permitting will need to be undertaken in 2 different municipalities.
• Two mines and two projects are located upstream of this project, potential for cumulative negative impacts associated with mining activities.
• Hydropower and paper pulp industries are active downstream of the project area, cumulative negative impacts could be experienced from the heavily developed catchment downstream.
• There is a lack of gender diversity in the current workforce makeup.
• Land disturbance as a result of drilling reflects a negative consequence of the project, albeit minimal.
• Aquatic environments in the landscape are very sensitive, especially to the cumulative impact of farming and forestry. These in combination with exploration, may pose threats to the biodiversity of the landscape.Evidence provided suggests that this is currently well managed.
• Major impact infrastructure will need to be erected within the area when mine construction and development occurs in the future (e.g. transportation routes).
• As yet, it is uncertain if a tailings storage facility will be required within the mine design. While not needed for a number of years, no evidence as to what type of facility will be constructed was submitted.
• While no evidence of efforts to minimise current air emissions were demonstrated, high-level awareness of potential impacts and mitigation requirements for any future mining operations was clear. For example, reference made to dust and the potential impacts to local reindeer husbandry activities.
Project positives - Sunday Creek
• The project is located in an area which has been an active mining prospect since the 1800s.
• The Project intends to further diversify the workforce in the coming 5 years beyond gender-based diversification.
• The project’s workforce is drawn almost entirely from the local population.
• Security is not required for the project’s context and there are no firearms present on site.
• No community resettlement is required for the project’s current targets and activity levels.
• Local infrastructure (road and rail) is already in place and is sufficient for the project’s requirements, no appreciable impact is associated with current activities.
• Local infrastructure will be sufficient should the project progress to mine development.
• The project intends to utilise on-grid renewable energy to power operations on site in the future as part of Victoria’s State Government’s energy transition plans.
• Current activities utilise a negligible amount of water, and this water is not sourced directly from natural water courses.
• Wastewater is removed from the work areas and then disposed of into licensed facilities and not discharged into local water courses.
• Active social media presence which includes announcements, project updates etc. No negative feedback received via these platforms.
• Broad support for the project exists as evidenced by discussions and feedback from local community stakeholders.
• All necessary permits are in place. The project aligns with the state government’s mineral resources strategy to grow investment and jobs within the sector.
• Easily accessible complaints forum on company website for local community comments and/or grievances to be raised.
• Robust governance processes are in place.
• The project has committed to the Towards Sustainable Mining initiative as part of the Minerals Council of Australia.
• A management plan is in place and active to minimise noise impacts.
• The project has appointed an employee responsible for implementing and running stakeholder engagement and communications.
• The project has voluntarily undertaken a cultural heritage survey with local indigenous groups.
• With the exception of specialist equipment not available locally, procurement is 100% locally sourced.
Project negatives - Sunday Creek
• Downstream of the Project there is a small population centre which has been a growth area since the 1990s. There is potential for further growth and sub-division of rural land due to recent increased demand for regional housing and proximity to Melbourne.
• While the risk-based approach within the jurisdiction (Victorian Governments Earth Resources Dept.) classifies current exploration activities as being "low-risk", for the purposes of this assessment, minimal potential land disturbance as a result of drilling reflects a short-term negative consequence of the project.
• While personnel appear to be highly trained and experienced regarding health and safety, no evidence was provided of the nature or culture created by Health and Safety programs. Referenced document submitted is a government publication as opposed to a site-specific management document.
• The tenement includes sensitive areas such as agricultural and biodiversity land uses however please note that Mawson Gold’s company policy is to avoid areas which contain urban centres, state infrastructure and forests.
• Competing plans for land uses within the tenement include agriculture and exploration activities, these appear to co-exist in this context. Local regulations require land-owner agreement for exploration activities.
• Adjacent to the project, competing land use changes in the future may arise with suburban development. A recent increasing trend of regional migration from cities is seen. The proximity of the project to Melbourne makes the shire attractive as a regional migration destination. With increasing urbanisation and changing demographics there is potential for access constraints.
• The project is located in a water stressed catchment area where sufficient quantities of water can be hard to obtain.
• No evidence was submitted regarding an environmental or social management plan or the implementation of such.
• No evidence was submitted of a rehabilitation plan or procedures for current activities other than the removal of drill cuttings and disposal of waste into licensed facilities.
• No evidence was submitted to support the active management of biodiversity at this phase of the project’s lifecycle.
Project positives - Redcastle & Whroo
• The project is aligned with the Greater Bendigo Shire’s council strategic economic growth plan (ratified in 2020). Government support therefore exists for small scale gold mining in this region, encouraging permit allocation. Mining is currently active elsewhere in the region.
• The above is enhanced by the State government mineral resources strategy in place to grow investment and jobs within the sector which is resulting in a recent resurgence in gold mining in Victoria.
• The projects are located in a production forest, which while this is a state forest and therefore a biodiversity conservation area, provides stability of adjacent land uses.
• Data submitted suggested that land is not occupied by groups such as close proximity local communities, indigenous populations, informal settlements, or farm workers.
• Significant transport infrastructure is already in place (road and rail) and no appreciable impacts associated with current or projected future activities are observed.
• The project’s workforce is gender diverse and sourced from the local community.
• Security personnel are not required in this project context and there are no firearms on site.
• The project intends to make use of the on-grid electricity network which will be increasingly sourced from renewable energies in the future in accordance with state energy strategy.
• Negligible quantity of water is currently required for the project, all of which is not sourced from natural water courses. Wastewater is removed from the work areas and then disposed of into licensed facilities and not discharged into local water courses. Active management is in place and appropriate for the scale of activities on site to minimise the impacts to surface and groundwater quality.
• Active social media presence which includes announcements, project updates etc. No negative feedback has been received to date via these platforms.
• An easily accessible complaints forum exists on the company website for local community comments and/or grievances to be raised.
• Proactive approach to local commitments is observed through the data submitted. Cultural heritage commitments have been made; the project has voluntarily undertaken a cultural heritage survey with local indigenous groups; and an agreement has been signed with indigenous landowners.
• Involvement by the projects in additional community initiatives is deemed to be appropriate for the current phase of the project and include sponsorship of local activities and support for local heritage projects.
• The projects actively support all government activities / commitments e.g. agreement to clean up all litter / waste even if not belonging to the project.
• With the exception of specialist equipment not available locally, procurement is 100% locally sourced.
Project negatives - Redcastle & Whroo
• While the risk-based approach within the jurisdiction (Victorian Governments Earth Resources Dept.) classifies current exploration activities as being "low-risk", current activities including drilling will disrupt the landscape even on a minimal and temporary basis.
• While not instigated by the project, contamination by suspected naturally occurring Antimony of soil and drinking water (above Australian Drinking Water guidance) has been identified in local residential area with the potential for this to be attributed to mining activities being undertaken by other organisations in the region.
• Sensitive receivers such as agriculture positioned downstream of the project area could be impacted by on site activities.
• No evidence was submitted to highlight the strength of health and safety programs or the strength of the safety culture was provided. The referenced documentation submitted was a government publication and is therefore not specific to the project; the slack links provided lead to database headings only.
• Some of the tenement is within the State Forest.
• No evidence was submitted of a Rehabilitation Plan or procedures for current activities, other than removal of drill cuttings and disposal to a licensed facility.
About Digbee Ltd.
Digbee, a United Kingdom based
company, is a new mining-focused expert network and ESG disclosure platform
with a goal to provide improved disclosure and better access to capital markets
for mining companies involved with strong ESG practices. Digbee has been
endorsed by leading financial firms who support the Digbee ESG initiative such
as Blackrock, BMO, and Dundee Corporation.
Figure 1. Groups Partnered with Digbee’s Platform
framework is aligned with global standards, including the Equator Principles,
which provide a framework for financial institutions to assess environmental
and social risks in projects. Digbee’s ESG framework currently maps to the
following Global Standards:
Figure 2. Digbee ESG Framework maps to global standards