Green mountain slopes above a turquoise lake

Environment

Our approach

Our standing environmental requirements for any activity, from the assessment before it starts to the ground after it stops.

Requirements

Requirement
What it means in practice
Environmental risk assessment
We assess environmental risk before an activity proceeds and reassess it as the activity develops. We record assessed risks in the risk register maintained under our Enterprise Risk Management Policy, and we build environmental risk assessment into project planning, procurement and operational decisions.
Waste and emissions management
We manage waste under the waste hierarchy of reduce, reuse, recycle, recover and dispose. We recover and reuse materials where practicable, segregate, track, handle and dispose of hazardous waste under the applicable requirements, and control emissions to air, water and soil.
Hazardous materials
We store, label and transport hazardous substances under controlled conditions, with inventory, segregation, containment and spill response arrangements appropriate to the substance and the setting.
Tailings
Where an activity involves a tailings storage facility, its design, operation and closure follow the Global Industry Standard on Tailings Management, supported by engineering design, independent review, monitoring and inspection, and emergency preparedness. We operate no tailings storage facility.
Land rehabilitation and closure
We address closure as part of project design rather than at the end of an activity. Closure planning covers landform stabilisation and revegetation, decommissioning of infrastructure, post-closure monitoring, and the social transition of the communities affected, and we develop it with those communities.
Energy and resource efficiency
Where we install or replace equipment, we specify energy-efficient technologies. Where we install or modify water systems, we specify water-saving and recycling options. Where an activity requires electricity, we assess renewable supply options as part of the procurement decision and record the assessment.
Sustainable procurement
We engage suppliers against the environmental standards set by our Responsible Sourcing and Supply Chain Policy and our Supplier Code of Conduct, and we apply due diligence to environmental risk in the supply chain.
Protected areas
We do not operate in legally designated protected areas or World Heritage Sites.

The mitigation hierarchy

Four steps we apply in order, wherever an activity affects habitats or species.

01

Avoid

We avoid the effect, by siting, timing or design, wherever avoidance is possible.

02

Minimise

Where we cannot avoid an effect, we reduce it as far as the activity permits.

03

Restore

Where an effect has occurred, we restore the affected habitat.

04

Offset

We use offset measures only where avoidance, minimisation and restoration cannot address the effect.

The order is not a preference. An offset is not an alternative to avoidance, and we treat it as the last step rather than as an option available at the first.

Closure, from the beginning

Closure planning starts at design. A landform that cannot be stabilised, a drainage arrangement that requires perpetual treatment, or an access road that leaves a community without a route are all cheaper to avoid at design than to remediate at the end. Our closure planning covers landform stabilisation and revegetation, decommissioning, post-closure monitoring of water and ground conditions, and the social transition of the communities affected. We develop it with those communities rather than present it to them.

Responsibilities

Environmental matters are subject to board oversight and are considered within strategy, risk and performance oversight. Responsibility for environmental strategy and for implementation of our Environmental Sustainability Policy rests with executive management. Monitoring of adherence, auditing, incident investigation and training are assigned within the Group and named in the governing policy. Environmental controls are applied in daily activity by those conducting it, together with the monitoring the activity requires, and our environmental standards are applied to suppliers through procurement.

Monitoring

We conduct environmental audits and site inspections on the cycle stated in the governing policy, and executive management reviews environmental strategy and performance on that cycle, revising objectives, metrics and action plans in the light of audit results, stakeholder feedback and regulatory change. We record and monitor environmental incidents, each with a root cause analysis and a corrective action. We escalate systemic or unresolved issues to executive management and, where appropriate, to regulators, providers of finance or affected communities. We structure our environmental management arrangements against ISO 14001 and hold no ISO 14001 certification.

Key facts

Mitigation hierarchy

The mitigation hierarchy is an order, not a menu.

Closure

Closure is a design input, not an end-of-life exercise.

Tailings

We operate no tailings storage facility; the standard applies if one is ever developed.

Protected areas

We do not operate in legally designated protected areas or World Heritage Sites.