Environmental, social and governance considerations in public mineral reporting

Environmental, social and governance issues (ESG) have become a defining feature in the marketplace to differentiate preferred investments. With the sustainability commitment and reporting landscape anticipated to evolve exponentially, it is now imperative to rapidly develop the approach taken by mineral companies to adequately identify and address ESG risks and opportunities in the reporting of Mineral Resource and Mineral Reserve (MRMR). MRMR cannot be effectively reported as technically and financially assured and realistically executable, if ESG is not integrated into the strategy, business model, input assumptions and process that defines and drives robust MRMR public reporting. Regulatory reporting codes across the globe are presently in various stages of being updated and modified to ensure ESG factors are appropriately covered as a key part of diligent and transparent disclosure. Security exchanges are making it clear that companies must not omit ESG risks from reports to investors. This paper discusses associated challenges for MRMR reporting and suggests avenues for improvement. Key themes include: the importance of procedure rather than prescription and checklists; how ESG criteria impact Modifying Factors and determination of Reasonable Prospects for Economic Extraction (RPEE); the need for financial models to account for material ESG commitments; the uniqueness of each mineral asset; the need for education, upskilling and accreditation of both ESG experts about MRMR reporting and equally Competent Persons in ESG matters; and the need for clear and balanced reports that meet the needs of end users. (RPEE is adopted here for simplicity and consistency, recognising that some reporting codes still include ‘Eventual’ in the term (ie RPEEE). Whilst RPEE and RPEEE are subtly different the intent is to point to the process of assessing ESG factors in determining reasonable prospects.) The principles of transparency, materiality and competence remain paramount when considering the impact of ESG matters on MRMR reporting, and this necessitates an inclusive, cohesive, and integrated approach to assessing ESG issues to ensure the necessary expertise and diligence is applied.