As a member of the International Council on Mining and Metals (ICMM) and the United Nations Global Compact (UNGC), we are committed to respecting human rights as set forth in the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights and under international humanitarian law. From employees and contractors to senior management, our workforce is expected to comply with our Human Rights SEMS standard and Human Rights Policy.
Our Human Rights Policy, first released in 2011 and subsequently updated in 2015, reflects the changing social context in which we operate. We acknowledge that strong sustainability performance is intrinsically linked with respect for human rights. Our revised policy defines our daily practices and commitments on human rights. New additions to this policy include clauses on community consultation; grievance mechanisms; commitment to the Conflict-Free Gold Standard; commitment to respect the rights, interests, perspectives, and traditions of Indigenous Peoples; resettlement planning; and potential measures in the event of non-compliance. To read the policy, click here.
Human Rights Due Diligence Mechanisms
At Goldcorp, we assess potential human rights issues, take measures to avoid infringing on them, and seek constructive dialogue and partnerships with stakeholders impacted by our activities. Some examples of our due diligence processes and mechanisms include:
All Goldcorp Board members, officers, contractors or any third party conducting work or acting on our behalf are expected to behave in a manner that respects human rights and avoids infringing upon them. We take appropriate measures to ensure that everyone working at Goldcorp, or on our behalf, respects our Code of Conduct, Human Rights Policy and Occupational Health and Safety Policy and also abides by our safety protocols, rules and standards.
For employees, non-compliance with these policies may be grounds for disciplinary action up to and including termination of employment. For contractors and third parties, non-compliance may be grounds for contract termination.
We respect the right to a safe and healthy work environment and strive to ensure our workforce complies with our Occupational Health and Safety Policy and associated procedures and guidelines to ensure Goldcorp is Safe Enough for Our Families. Our commitment to the right to water and sanitation is also part of our overall commitment to sustainable mining. Our Environmental and Sustainability Policy stipulates that all of Goldcorp and our subsidiaries are committed to the protection of life, health and the environment for present and future generations. In addition, our SEMS includes standards pertaining to our Water Stewardship Strategy. The SEMS is intended to be fully integrated into all core business functions throughout the Company, and it emphasizes sustainability responsibility and accountability at all organizational levels.
As stipulated by our Human Rights Policy, we respect the rights and dignity of employees, contractors, partners, community members and other stakeholders impacted by our business. We are committed to creating a safe and diverse workplace and embedding a human rights culture. This includes respect for all stakeholders, including human rights defenders.
We are currently implementing a revised integrated risk framework, which takes into consideration the actual and potential social impacts and human rights impacts our operations may generate. We adopt a multi-disciplinary approach to human rights issues; therefore, our analysis looks at impacts across departments and subject-matter areas. Occasionally, and where needed, we seek support and advice from external human rights experts.
Human Rights Training and Awareness
To ensure an integrated approach to human rights training, we coordinate our efforts. Improvements to our overall human rights awareness is coordinated through the corporate CSR team with support from the other sustainability functions and the Ethics department to deliver consistent messaging throughout our operations. In 2016, we launched Respecting Rights, Level I, an online training course that raises awareness about our Human Rights Policy, how to recognize human rights risks and violations, and the mechanisms in place to report them.
Over 88% of our workforce with daily access to computers1 (more than 2,900 full time employees and contractors) successfully completed the course and are now better equipped to recognize human rights risks and utilize our measures and procedures to report them. The training course improved our workforce’s average test score by 12%, from an average pre-test score of 60% to a post-test score of 72%. In 2017, we will be rolling out formal training to employees and contractors who do not have regular access to computers.
Summary of Compliance by Region
Number of employees and contractors enrolled in Respecting Rights, Level I
Number of employees and contractors who have completed Respecting Rights, Level I
Percentage of employees and contractors who have completed course
Total hours dedicated to human rights training
In addition, we designed and piloted Respecting Rights: Championing Human Rights at Goldcorp, an in-depth participatory workshop for employees whose work offers distinct opportunities to understand our human rights commitments and apply our Human Rights Policy. The goal of this workshop is to improve understanding of human rights and increase knowledge of our Human Rights Policy among the management team and key employees overseeing departments that may have exposure to human rights risks in order to promote its successful implementation across all our operations.
After completing the workshop, participants were able to:
Explain what human rights mean in the context of our operations
Identify existing human rights risks and potential human rights risks related to our operations
Identify prevention, mitigation and remediation measures for high-risk human rights issues
Explain reporting mechanisms and course of actions to take when becoming aware of an existing or potential human rights risk or violation
The workshop was piloted with our Coffee project. We plan to roll out the workshop to our other operations in 2017.
In recent years, security practices have come under increasing scrutiny for human rights compliance. We are committed to effectively managing and administering our security programs in accordance with company policies, local and national legal requirements, and industry best practices. Our security teams conduct in-depth risk analyses to determine threats to our workforce within their areas of operation and influence. Our sites are required to develop security plans in accordance with all applicable laws and regulations, as well as with our Human Rights Policy and Security Policy. When local conditions require us to deploy armed staff, careful consideration is given to this deployment and additional safety measures and training are implemented as necessary.
We have designed training programs for security providers at sites based on international best practices. In 2016, 100% of our security personnel in our Latin America region underwent training on the use of force and on the Voluntary Principles on Security and Human Rights; 98% of our security personnel in Canada have received human rights training.
In 2016, we became a signatory to the Voluntary Principles on Security and Human Rights. Established in 2000, the Voluntary Principles are designed to guide companies in maintaining the safety and security of their operations within an operating framework that encourages respect for human rights. As a signatory, we are implementing the principles across all of our operations, and have aligned our corporate policies and procedures with internationally recognized human rights principles in the provision of security.
In accordance with the Voluntary Principles, in our high- and medium-risk operations, all security personnel are required to undergo extensive and recurring background checks and receive annual training on the Voluntary Principles, including the requirement to sign a declaration of compliance with our human rights requirements. The security contractors also incorporate human rights training in their employee orientation. All security staff receive at least one pre-shift briefing per month on the use of force. Company security supervisors provide ongoing training and refresher classes. Non-compliance with our human rights requirements is not tolerated. There are a variety of complaint mechanisms for incident reporting, and all allegations of suspected human rights abuses are thoroughly investigated.
In 2016, Los Filos, Peñasquito, El Sauzal, Cerro Negro and San Martin were assessed by a third-party provider who evaluated their compliance against the Voluntary Principles. The San Martin site was assessed as a one-time baseline assessment since the site is in the post-closure phase. The results were positive with respect to the levels of implementation of the Voluntary Principles and human rights in general. Marlin was not assessed due to the fact that both a Conflict-Free Gold Standard review and a Voluntary Principles assessment were conducted in 2015.
Starting in 2015, we designed a more aggressive and formal implementation plan to ensure continuous compliance with the Voluntary Principles. Los Filos, Peñasquito and Cerro Negro, for example, developed action plans to mitigate and avoid security-related and human rights risks and to ensure effective implementation of the Voluntary Principles and sustainability-related management systems.
Promoting Awareness of the Voluntary Principles with Our External Partners
Our Latin American sites provide detailed training on human rights, use of force and the Voluntary Principles to their security personnel and contract security guards. This training is provided through workshops, presentations, videos and role-plays, and documented through attendance sheets or signed certifications. In 2016, several sites also engaged relevant public security partners located within their area of influence in order to build awareness of the Voluntary Principles and their importance. For example, at the Los Filos mine, our security team engaged with the State Police (Instituto de la Policía Auxiliar Estatal), which is contracted to provide perimeter security for the mine, in order to review the Voluntary Principles and build awareness of our Code of Conduct and Security and Human Rights policies, as well as our procedures on the use of force. In Argentina, Cerro Negro conducted a presentation with local police and the Gendarmerie (who are not contracted by the mine) on our commitment to the Voluntary Principles and the importance of respecting human rights. In Peñasquito, we are a key participant in the local Security Council, which is composed of peer companies and public security forces, to enhance collaboration and share best practices around security management and the respect of human rights. In addition, we promote the Voluntary Principles through outreach and awareness with organizations such as Camimex and CanCham.
Conflict-Free Gold Standard
The World Gold Council (WGC), the industry’s key marketing body, has recognized that in some places and circumstances, gold may represent a potential source of funding for armed groups involved in civil conflicts. In October 2012, the WGC published the Conflict-Free Gold Standard, which establishes a common approach by which gold producers can assess and provide assurance that their gold has been extracted in a manner that does not cause, support or benefit unlawful armed conflict or contribute to serious human rights abuses or breaches of international humanitarian law. As a member company, we supported the WGC’s efforts in developing the Standard, and implemented it effective January 1, 2013. We produce an annual, independently assured Conflict-Free Gold Report summarizing our conformance to the Standard.
The Standard requires companies with mines operating in areas considered to be “conflict-affected or high risk” (according to the Heidelberg Conflict Barometer) to evaluate processes and controls and implement additional measures to ensure conformance with the Standard. Although only our Mexican mines are located in areas deemed “conflict-affected or high-risk”, we voluntarily applied the same categorization to our Marlin mine in Guatemala based on our internal security assessment.
Our 2016 findings confirmed that all gold and gold-bearing material produced at mining operations where we operate have the appropriate systems and controls in place to conform to the World Gold Council’s Conflict-Free Gold Standard. Conformance with the Standard was subject to independent assurance.
For a copy of our 2016 Conflict-Free Gold Report and more information on the background and structure of the Standard, please visit www.goldcorp.com.
Investment and Procurement Practices
In order to conduct business in an efficient and cost-effective manner, it is essential that we have a steady, stable flow of production inputs to our sites. However, numerous social and environmental risks have the potential to disrupt the flow of goods. In our industry, there is increasing awareness of these risks as well as of the opportunities to leverage dollars and relationships to influence supplier sustainability both upstream and downstream.
At Goldcorp, we are driven to innovate and address situations that may hinder safe production. Increasingly, we are automating our processes to facilitate responsiveness to potential opportunities and mitigate supply shortages.
Our Third-Party Due Diligence Standards define the minimum due diligence that employees must fulfill when entering into a relationship with a third party on behalf of Goldcorp. Compliance with the Third-Party Due Diligence Standards is required under our Global Supply Chain Policy, our SEMS and our Anti-Bribery and Anti-Corruption Policy. Under the Global Supply Chain Policy, human rights, environment, safety and sustainability performance are requirements that must be assessed when selecting a third party.
Of the 320 contracts that were entered into with third parties (as reported by our sites), 96% were screened or had clauses for human rights compliance.2 None of the contractors screened were found to be in violation of human rights laws, and as a result, no potential contractor was declined from and no existing contractor was removed from contracting with us for human rights compliance reasons.
Our approach to risk management and impact assessment also includes reviews of significant investments against numerous criteria, including human rights risks. In this report, we define “significant investments” as those that either moved the organization into a position of ownership of another entity or initiated a capital investment project that was financially material. There were 81 such investments and contracts reported at our sites in 2016. Of those agreements, 80 had human rights clauses, and two were screened for human rights compliance.
Land Rights and Resettlement
To conduct our mining activities, we are occasionally required to acquire land and/or resettle individuals or communities. Land acquisition and resettlement is a complex and life-changing issue for the communities affected. It is never our first resort when other options are available. The timing and location of resettlement is negotiated with the affected households and every reasonable effort is made to ensure that the integrity of the community is maintained. In 2016, no resettlement occurred at any of our operations.
Community Response Mechanisms
As stated in our Corporate Social Responsibility Policy and SEMS, we are committed to establishing Community Response Mechanisms, also known as grievance mechanisms, based on international best practices. We acknowledge the corporate responsibility to respect human rights, which means that we, and our subsidiaries, must act with due diligence to avoid infringing on the rights of others. In light of the UN Guiding Principles for Business and Human Rights, we have implemented grievance and incident reporting procedures. Grievances may come from both internal and external stakeholders, such as employees, contractors, local community members, civil society and government.
At Goldcorp, we have two formal company-wide channels for receiving complaints and grievances, as well as other informal channels, which are implemented on a site-by-site basis.3
Our Community Response Mechanisms and Ethics from the Ground Up channels are accessible, inclusive, and available to internal and external stakeholders. Both channels respond to the local context and needs. Employees and communities negatively impacted by the actions of our contractors or business partners can also access these mechanisms to report a grievance or an incident.
COMMUNITY RESPONSE MECHANISMS
Principles of effective rights-compatible grievance mechanisms:
Proportionality: The mechanism must be scaled to the level and severity of the risk.
Legitimacy: The process must be perceived to be legitimate by local stakeholders.
Cultural Appropriateness: The mechanism must take into account the way local people express their concerns and how they normally resolve their disputes.
Accessibility: The process must be simple, convenient, easy to use and accessible to all.
Transparency and Accountability: Information must be provided ahead of time as to the exact process, requirements and timeline. Agreements must be fulfilled and commitments must be respected.
Fairness and Participation: Complainants must be treated with respect, encouraged to fully participate in the process, and offered fair compensation whenever appropriate.
Safety: The mechanism must explicitly guarantee there will be no retribution of any kind against the complainant.
We are committed to not tolerating any form of retaliation against a party who makes, in good faith, a report of a Code of Conduct violation or a report to any of our channels of complaints and grievances. Respect for all of our stakeholders is one of our core values. It is also part of our Human Rights Policy, and applies to all employees, contractors and third parties doing work for, or on behalf of, Goldcorp. We ensure there is no retaliation by creating awareness of our Code of Conduct and Human Rights policies, and by taking the necessary actions when either of these policies is violated.
Formal Channels for Complaints and Grievances
Ethics from the Ground Up Channels
Community Response Mechanisms
Receive complaints, questions and concerns related to the implementation of our Code of Conduct
Provide an easily accessible site-level process for community stakeholders to provide feedback to us
Code of Conduct, Anti-Corruption and Anti-Bribery Policy
Toll-free telephone hotline, email and mailing address
Varies by site: examples include a dedicated website, community drop boxes, offices, telephone lines, email addresses and text message systems
Employees and contractors
Local communities and other external stakeholders
Complaints and grievances process
Initial complaint is received (in confidence, if through our ethics and compliance hotline) from an external third party, and the cases are investigated and resolved by the corporate Ethics Committee with local site support as necessary
Complaints are received and documented at each operation. Classification and investigations vary based on severity. Operations engage with stakeholders to resolve and close out grievances
Type of complaints reported
Issues related to theft, fraud, discrimination, harassment, employee relations, labour, health and safety, and human rights
Issues related to environmental performance, physical disturbances, land access, compensation, job opportunities and contractor management
In 2016, our Ethics from the Ground Up channels received 46 complaints and/or inquiries regarding alleged discrimination, harassment and other issues that could relate to human rights, compared to 39 complaints in the previous year. All reports were investigated and 41 were resolved or closed during 2016. For the remaining five, the resolution process was ongoing at the end of the reporting period.
Ethics from the Ground Up hotline (human rights–related complaints only)
Received in previous year, resolved/closed in current period
Harassment and bullying
Impacts on livelihoods, personal safety and security
Sexual harassment and unwanted sexual advances
Our Community Response mechanisms are intended to meet the needs of local communities and other external stakeholders. Each Community Response mechanism at our operating sites is tailored to the local context, but they are all designed to comply with the Goldcorp Grievance Mechanism Framework.
In 2016, our sites received and responded to a total of 633 complaints, of which 228 were closed at the time of writing of this report, and the remaining 405 were in various stages of investigation and resolution. As part of our grievance reporting, we conduct a categorization process of grievances against related SEMS standards. In some cases, more than one standard is applied to a given complaint, as they may have impacts or aspects related to more than one category. This year we also revised and enhanced our process for assessing the severity of grievances. At Goldcorp, we endeavour to treat complaints in a respectful and holistic manner, aiming to understand and respond effectively to all the root causes.
Grievances received from Community Response mechanism by category
Examples of grievances received
G4-EN34Grievances related to the environment
Impact on water availability or quality
Waste and debris
G4-SO11Grievances related to society
Impacts to infrastructure
Damage of property, crops and livestock
Lack of communication about activities
Community safety around site installations
Delays on meeting commitments such as community investments
G4-LA16Grievances related to labour practices
Access to employment
G4-HR12Grievances related to human rights
Harassment and discrimination
Grievances related to Indigenous rights
Land and infrastructure access
Social, cultural and spiritual well-being
We received 54 other work-related concerns from employees that were resolved at the site either by line management or by the Human Resources team and were not reported to one of our two formal channels.
In 2016, there were no significant4 disputes related to land use or customary rights of local or Indigenous Peoples.
Community Feedback Mechanisms in Practice: Addressing Local Concerns in Chapleau
The Borden project is located near Chapleau in Ontario. Home to many different communities, the Township of Chapleau is known for its beautiful outdoor recreational facilities. Fishing, canoeing, hiking, bird watching and hunting are common activities in the area.
Many cottagers have permanent or seasonal properties on Borden Lake, within close proximity to the Borden project. The Borden team recognized that the project would bring changes to the area and that building positive relationships with the local community would be critical to ensuring long-term success.
One of the key elements necessary to build trust with community members was to provide all stakeholders, including Chapleau cottagers, the opportunity to voice their concerns through a site-level grievance mechanism.
In 2015, the Borden team created and implemented the Community Feedback Protocol,a procedure based on open communication and systematic response to stakeholders’ concerns. It included frequent visits and dialogue with local stakeholders to better understand the project’s local impacts and respond to community concerns.
Among the key concerns identified by locals were the visual and noise impacts related to exploration drilling. Through dialogue with local stakeholders, the Borden team identified several solutions to address these concerns and mitigate some of the impacts. Sound walls, sound monitoring equipment, and noise mitigation procedures, as well as directional lighting and broadband back-up alarms, are some of the examples of the noise and visual mitigation measures that remain in place.
This process has created positive results: many of the cottagers have welcomed the changes and have provided positive feedback. Trust between local stakeholders and the Borden project team has improved, with the project team successfully completing its 2015 drilling programs.
The Community Feedback Protocol has been a critical tool for hearing and addressing local stakeholders’ concerns. The Borden project continues to use the Protocol as an important engagement and grievance management tool. The project has also incorporated noise and visual impact mitigation measures as part of future site planning.