The Responsible Mining Index is not a responsible mining index

The Responsible Mining Index came out a few weeks ago and it’s a very interesting read and resource. It’s already helped me in my research and I am very glad for it’s existence. If you’ve not yet checked it out, do. It’s well thought through, gathers lots of information which is attractively presented and in so doing makes widely accessible useful and interesting information. So far, well done.

It is not, however, an actual index of how responsible mining companies are. The key sentence in their methodology report is this:

“RMI will not undertake systematic mine-site visits to verify the accuracy of information provided on the minesite indicators”

Translation: We didn’t actually check to see if these companies are ‘responsible’ on the ground.

I feel the problem here is self evident – if you wanted to know if I was good neighbour, would you just ask me if I played loud music late at night, or would you also ask my neighbours?

While the RMI is not 100% another example of the mining industry marking its own homework, the majority of the information does seem to come from mining companies. This is then supplemented with other information in the public domain, followed by an unspecified ‘expert review’. I’m not the only one to note flaws in the information reported. The usually sympathetic mining.com chose to run with a headline criticising the paucity of the self-reporting by the mining industry.

This is not an isolated problem. The vast majority of research and work on CSR by companies in developing countries fails a simple test: did you check if it was true? There is so much research out there which basically analyses the easily accessible data about CSR (the reports and what companies themselves produce) but does not actually seek the perspectives of those living with operations and CSR programmes in the developing world or seek to measure outcomes rather than outputs (i.e. not ‘how many people did you train?’ but ‘how much did people’s benefit as a result of the training?’). There are good reasons for this. Gathering this data is expensive, challenging and cumbersome. It is, however, critical if we are to make any kind of valid estimation of whether a company is ‘responsible’ or not. Without it, any picture we have has glaring absences. The perspectives of those who live with mining operations cannot be ignored in any objective assessment of responsible behaviour. To do so, and claim that an objective assessment of responsibility has been made, is irresponsible.

If looking at the impacts and CSR programmes of large mining companies on the ground has taught me one thing, it’s that the reports produced by mining companies selectively represent a much more complex reality. Mining operations are complicated, sprawling and dynamic affairs. CSR and community relations programmes are often also equally complicated, sprawling and dynamic. They exist in environments riddled with contradictions, conflicting interests, sharp political cleavages and, often, acute poverty. Acting ‘responsibly’ in such settings is tremendously challenging and I’ve yet to find a company that doesn’t have some areas where they fall short of the mark of being a ‘responsible’ organisation (I’m looking at you, resettlement programmes). By the same token, all the companies I have seen have areas where they have gone above and beyond what could be reasonably expected of a ‘responsible’ organisation – often without this being recognised or getting the commendation it deserves.

We need an index which captures more of this complexity. And we need an index that includes the voices of those who do not work for mining companies but live with them. If the RMI could bring together all the data they already have with a methodology that included people who live with mining company operations, it would be a lot closer to being a responsible mining index.

I’m giving a talk at Ryerson next week

On my current trip to Canada I’ll be giving a talk at Ryerson University’s Institute for the Study of Corporate Social Responsibility on ‘What’s the political impact of CSR? Evidence from the mining sector in Zambia, Ghana and Peru’ 12–2pm Tuesday May 22nd. More details and a link to the livestream for those interested but unable to attend can be found here. I’m pretty sure they archive the screencasts too so you can watch them later if you wish. I’ll be mainly presenting this paper, but also some of my more recent thinking on the topic of CSR and politics.

Letter to a prospective phd student

Dear Student,

I write in anticipation of your imminent email asking me to be your phd supervisor. Firstly, I am flattered that you have chosen to approach me out of the blue, I look forward to hearing more about your proposed research. However, I receive many approaches each year as my institution – sensibly – asks that each applicant have agreed a supervisor prior to formally applying. Many of these approaches make similar mistakes that I would like you to avoid. So, before you do fatefully press send, I’d like to caution you first against making some common mistakes mistakes:

1. Don’t think of applying for a phd as the same as applying for any other academic course

A phd is a very different beast to a masters or a bachelors. The structured taught element of a phd is minimal. A phd is essentially your project. You get guidance, but in the main, this is just guidance and you decide how you want to progress. This means you should have a very clear idea about what it is you want to do, why, and who you want to work with before you approach potential supervisors.

2. Choose where to apply based on the people you want to work with

Fundamentally, a phd is about you working with individuals – in a departmental setting, rather than you working at a specific university. Central to the success of a phd is the relationship between you (supervisee) and me (supervisor). I and other potential supervisors are making a 3+ year commitment to work with you to develop your ideas, skills, thinking and research. It is a close relationship over a long period of time. For a supervisor, this is a big commitment – with clear potential rewards. There may be a good research group in the field you’re interested in, but really it comes down to you and your supervisors. A basic rule is that you should be applying to work with people who are cited in your research proposal. If you’re not doing that, you need a good reason why not.

3. Study the stated research interests of the chosen supervisor

Without clear alignment between your and their research interests, supervisors are unlikely to agree to supervise your phd. Supervisors are paid no more or less depending on how many phd students they have. Most supervisors supervise because they care about the research project the phd student is doing. Therefore the proposed research should closely fit the research interests of the potential supervisor. Sometimes these can be quite broad, some supervisors might be happy to support any work on a country they specialise in, but there has to be clear overlap. If not, then the supervisor may not be able to support your work well and your phd will suffer as a result.

4. Pay attention to the funding application timelines of your chosen department

I would not recommend you do a phd without funding. This makes securing funding central to the application process. Here is the process for my department. In order to be considered for most funding my department administers you need to apply in early February. Sure, occasionally there is some flexibility but we are beholden to the administrators that need to process your application along with hundreds of others. Applying in March and later really will not cut it, if you want funding. If you don’t want funding then you can apply much later in the academic year. Supervisors rarely have access to funding they can allocate to a phd student they find interesting, instead you must enter a competitive process and secure funding. Which means applying in good time with a strong proposal. You can find more details about funding available through my university and search for other funders here.

5. Approach your supervisor in good time

Quality in academic work is based on critical feedback and iterative improvement. Expect that your potential supervisor will provide critical feedback on your proposal and you will therefore need to do more work on it. If you’re applying for funding, this is doubly important. Your proposal needs to be very sharp and may need substantial work to make it competitive. This will take time, particularly if you can only work on it evenings and weekends. I would recommend you approach supervisors before October of the academic year before you wish to start – nearly 12 months in advance of your proposed start date.

6. Focus on your ideas and research questions

Many students spend much of their time talking about personal motivation for the phd. While this is the most important thing for you, your job is convince others to support your project rather than you as an individual. Academics are, first and foremost, interested in ideas. Your motivation is secondary to the ideas. It is the ideas that will attract most potential supervisors so focus on this and explaining how these relate to work the potential supervisor has done and is interested in.

7. Include a research proposal

A proposal shows you are serious and allows the potential supervisor to get a more complete picture of your proposed project and abilities. Again, a phd is your project, it is up to you to define it’s focus and limits. At a bare minimum, you need to include an abstract, along with a ‘if you’re interested I can send you full proposal’ line.

8. Make sure your proposal follows basic academic norms

My institution provides some generic guidance on this here. The patter blog is good for general guidance on academic writing. You need to show that you understand what is required to when proposing research. Ironically, in a phd proposal you are not committing to doing a specific research project. Most phd projects change in the course of their first year and a more complete proposal is required to graduate the first year. Instead, you are showing that you know how to do a research project. Supervisors are looking to see that you understand academic norms and will be a strong student. Committing to supervising a phd student presents risk for supervisors too. A weak student can consume an enormous amount of time for support over the 3+ years they take to complete their project. So, potential supervisors are looking to see that you have what it takes – the proposal is the main way we judge this. (On this – a bit of a flashing warning light for me on this is if the student does not actually improve the proposal using feedback provided – This will basically be the basis of our relationship for 3+ years. Get into the habit of responding to feedback now. )

9. Keep your proposal short

Concision is key. The generic guidance from my department above says 1–1500 words. I’d say around 2000 words is closer to the mark. You have lots to cover in a proposal so you’ll need to boil the literature down to it’s essentials, covering only what is relevant to your project (while showing you are aware that the rest is there). For a 2000 word proposal I’d recommend a structure that is something the like this:

  • Abstract (150w)
  • Literature review (1200w – which usually means 3 paragraphs on the main elements of your conceptual framework and 1 on the proposed case)
  • Research questions (100w)
  • Methods (500w)
  • Work plan (100w table – I don’t see the point of these myself but it’s a requirement in my department)
  • References (not included in word count)

10. Make your proposal sharp

In order to secure funding your proposal needs to be sharp. The competition is strong and you need to stand out. If I am interested in in your proposal I will help you improve it, but we can speed things along by avoiding some of the more common mistakes such as:

  • Abstract – not including one, not summarising your research in the first sentence, not summarising your main concepts, questions and methods, not making a case for why your research is important (why it should be funded) in the abstract.
  • Literature review – not narrowing down quickly on the most relevant ideas and literature and spending lots of time on broad basic points, not highlighting gaps in the literature, not defining key concepts, not following a clear structure (easiest is broad to narrow), not using topic sentences, separating the ‘literature review’ and your ‘conceptual framework’ (you don’t have the time/space for this), detailing the case more than you detail the conceptual framework used to analyse it.
  • Research questions – not including them (these are the pivot on which the whole proposal turns), not making sure they are focussed and specific (basically, the narrower, the better), not using analytical language developed in the literature review, not clearly linking to the problems and concepts laid out in the literature review.
  • Methods – not citing the academic literature on your chosen methods, not linking the methods to the research questions, spending lots of time on questions of ontology and epistemology, not providing detail on what data will be collected – how it will be collected and how it will be analysed, thinking that you have to include a quantitative element to be ‘rigourous’,
  • General – not writing in full sentences, not using proper english, not having someone proof read your proposal, not keeping the proposal short, not making sure there are clear links between the literature – questions – methods, not citing clearly and fully.

Please do not be discouraged. I offer this peremptory advice in the hope that you do approach me (or someone else having decided they are a better fit and less condescending) with a strong proposal and we (or you) have a great time working together. I see the above steps as the best way to make the best start towards succeeding in your phd. I look forward to hearing from you.

Yours,
Tomas

“If you have a bad image and are bad, then you don’t have an image problem”

This news on the role of a dam executive in the murder of environmental activist Berta Caceres caught my eye this week. Great to see progress being made in the case, though the fact that 60% of the environmental activist who were killed last in 2015 were killed in Latin America should really give pause for thought. There is a long way to go yet. As the quote from BBC journalist Evan Davis on bankers eloquently points out, sometimes when industries have a bad reputation it’s justified

My colleagues are just starting out on a big research project on the next generation of dams. Lets hope they can help improve their human rights record, along with their sustainability.

Brexit, mining and CSR

All this recent news about Brexit has reminded me of this article in The Times (behind a paywall – apologies). It tells the story of one of the areas which voted for Brexit. As we now know, these were often rural areas which are relatively poor for whom foreign labour threatens wages, jobs and services. This article was one of many in the weeks following the vote where the London-centric media tried to figure out what the hell had just happened to them by dispatching unsuspecting correspondents to far flung corners of the nation (to which they never then returned, but it’s the thought that counts, right?). What stood out to me though was that this story was based in the formerly prosperous (and oddly famous) town of Grimethorpe, South Yorkshire. Prosperous that is, until the mines closed.

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The Grimethorpe Colliery Band

The story of mine closure leading to decline and poverty, as friend of the blog Dylan McFarlane tweeted recently, is a global one. Dylan was pointing to a recent article on The Conversation telling the story of mining towns in Guinea. These towns had seen limited prosperity and a great deal of inequality as the benefits of Bauxite extraction had not been widely shared.

So far, so familiar. Mine closure, it turns out, is one of the thorniest issues facing mining companies looking to improve their social and environmental impact. One answer I saw in Ghana is the creation of foundations which pay a percentage of company profits into a fund a proportion of which only pays out when the mine closes. Even these, I suspect, will only slightly soften a very sharp drop in economic prosperity.

In Europe, sudden drops in economic prosperity have historically been associated with a shift towards populist, nationalist leaders and rhetoric that we are currently witnessing. As surprising as Brexit was for London-based elites, its seeds were sown in the industrial and mining policy of the 1980s. This all raises the question of what difference might have well managed closures made? If today’s best practices had been adopted 30 years ago would things be different? Would Grimethorpe be prospering and actually in need of foreign labour? (My inner pessimist makes me think this is unlikely, CSR seems only to be able to do so much)

For those of us interested in mining and CSR, the Brexit vote should renew attention on the long term political consequences of mine closure. The effects of mine closure and decline are an important but under-researched area. The mining industry has just seen a marked global downturn as the decades-long commodities boom came crashing to a halt. Hundreds of thousands have been laid off and many mines closed. As a result, telling the story of Grimethorpes around the world is more pressing than ever.

Image from The Guardian.

The modern way to regulate the mining industry

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This recent story about Miningwatch Canada attempting to sue the Mount Polley Mining Corporation and the British Columbia Government, has caught my attention. Their claim is that “it has now been over two and a half years since the Mount Polley disaster happened and yet, despite clear evidence of violations of Canadian laws, no charges have been brought forward by any level of government.” Indeed, last year the company has been allowed to resume operations at the site. Effectively, Miningwatch are using a private prosecution to goad the state into action – and the state is responding by trying to get the case stopped.

There are a few things about this that are interesting. The first is that for many actors in the field, the best way to increase pressure on mining companies to improve their practices is through the courts. There is a steady drip drip of stories of mining companies headquartered in the developed world being sued for the behaviour of legally separate (but often wholly owned) subsidiaries in developing countries. This is obviously not the case for Mt Polley – a Canadian mine being sued in Canadian courts – but this shift to the courts is telling. Acacia and Vedanta are being sued in UK courts (and as I pointed out on twitter, UK lawyers meeting their clients in Zambia in the Vedanta case was last week were subject to some pretty serious hassling) and Hudbay is being sued in Ontario courts. Monterrico Metals settled out of court before a verdict was reached in 2011. My own research shows that these cases are being “very attentively watched” by the industry.

One particularly interesting (for me, at least) finding from my research was that these cases often draw on the voluntary standards mining companies have adopted. Unlike the Miningwatch Canada/Mt Polley case above, these are often civil suits based on the tort of negligence. In essence, those suing the mining companies are accusing the companies of being negligent in their behavioiur. In order to establish what is negligent, the cases need to establish a ‘standard of care’ – a standard against which the mining companies can be said to have been negligent. In the past, this was often done using internal company policies. Now, however, with many companies signing up to international voluntary standards it’s these standards that are being used to establish standards of care. If mining companies have signed up to standards, and the courts establish that following these standards would have avoided the human rights abuses companies are being sued for, then the companies will have been negligent. The financial penalties of this can be enormous – just look at BP. BHP Billiton is hoping to sign a $1.55bn agreement with the Brazillian federal prosecutors to avoid $47.5 billion civil suit following the Sanmarco tailings disaster, having already settled with federal and state governments. All of a sudden, the vague sounding pledges of voluntary CSR and environmental standards have teeth.

In my own research, these cases, amongst a range of other pressures, are creating a new regulatory landscape for mining companies. Courts, bringing together hard and soft regulation, increasingly appear to be a modern way to regulate the mining industry.

Photo of Mt Polley disaster from Al Jazeera