A strong governance structure supports our TSF management. Our TSF Framework is governed by the Glencore Board through its HSEC Committee. It requires the appointment of an Accountable Executive for each industrial commodity department (excluding oil, which does not have TSFs), as well as dam owners, Engineers of Record (EOR) and Responsible Tailings Facility Engineers (RTFE) at our industrial assets. 

• Our Accountable Executives are answerable to Glencore’s Chief Executive Officer and are required to report to the Board of Directors at a minimum annually on their respective TSF portfolio. 
• Each TSF has a dam owner, who is the site’s senior executive management person with assigned responsibility to appropriately resource the TSF.
• Each TSF has an EOR who is responsible for verifying that the TSF is designed, constructed, and operated in accordance with the applicable regulations, as well as our TSF Framework.
• A RTFE/responsible person is also appointed for each TSF and has clearly defined, delegated responsibility for the TSF management throughout its entire lifecycle.

For all TSFs with an ‘Extreme’ or ‘Very High’ Consequence Classification, an Independent Tailings Review Board (ITRB) is required. Further, Group Assurance has been commissioning independent third-party dam safety audits of TSFs from internationally recognised dam consultants, typically on a 12- to 18-month basis.

Glencore’s TSF Framework is aligned with the ICMM’s Tailings Governance Framework position statement, the GISTM, the CDA’s Dam Safety Guidelines and the ICOLD. Our TSF and Dam Management Standard embeds corresponding dam design and management guidance, as well as other internal and external guidelines to inform the requirements detailed in our TSF and Dam Management Standard.

We have established an online TMA to develop the knowledge of TSF management. Training modules within the TMA are organised into three levels (Level 1 to Level 3) of competency and are assigned to employees based on their roles and responsibilities: operators and technicians (Level 1), dam owners, managers, and Accountable Executives (Level 2) and RTFEs/responsible persons and engineering staff (Level 3).

The TMA was developed with the assistance of external subject matter experts. It is aligned with leading industry guidelines and standards, such as the CDA’s Dam Safety Guidelines and GISTM, and covers all aspects of tailings management, from geotechnical and hydrotechnical engineering, environmental and closure to emergency response planning, human rights, and social performance. The TMA includes competency tests and, to support our diverse portfolio, is also available in Russian, Spanish and French.

We recognise that we have the potential to impact human rights directly through our operations, and indirectly through our relationships with joint ventures, contractors, and suppliers. We are committed to respecting human rights and actively support our workforce, business partners and suppliers to understand and meet this commitment. Our ambition is to uphold and promote respect for human rights within the Group, and throughout our value chain, to enable peoples’ basic rights and freedoms. We aim to:

• avoid causing, or contributing to, adverse human rights impacts;
• prevent or mitigate adverse human rights impacts linked to our operations, products, or services, through our business relationships; and
• make a positive contribution to the advancement of human rights of all people.

In the event we cause or contribute to an adverse impact on human rights, we provide for, or cooperate in, processes to enable an appropriate remedy.

Our Human Rights Policy, which was developed in consultation with communities and external experts, articulates Glencore’s approach and how we fulfil our commitment to respect human rights. The policy aligns with the ICMM Mining Principles, and the United Nations Guiding Principles on Business and Human Rights (UNGPs) and Sustainable Development Goals (SDGs). Our Human Rights Standard defines the minimum requirements for Glencore industrial assets to identify, assess, and manage human rights risks linked to our operations.

Glencore maintains a human rights risk rating tool comprising input data from internal and external sources to assign a ‘High’, ‘Medium’ or ‘Low’ human rights risk rating to each Glencore industrial asset and set minimum performance expectations for human rights management and due diligence. Human rights due diligence refers to the on-going process through which we identify, prevent, mitigate, and monitor human rights risks associated with the presence of our industrial assets. Completion of Human Rights Risk Assessments (HRRA) or Human Rights Impact Assessments (HRIA) are essential steps in the human rights due diligence process. 

All industrial assets with a ’High’ human rights risk rating are required to complete an HRIA using a competent third-party expert which must be reviewed and, where required, updated at least every five years or sooner, based on risk. 

Industrial assets with a ‘Medium’ or ‘Low’ human rights risk rating are required to conduct HRRA. A third-party expert is required to participate and provide support for ‘Medium’ risk industrial assets. Third-party expert support is optional for ‘Low’ risk industrial assets. The HRRA must be reviewed and, where required, updated every two years or sooner, based on risk.

Glencore is committed to building and maintaining constructive, long-standing relationships with its stakeholders. Culturally appropriate engagement mechanisms, tailored to local contexts, are established by our industrial assets with communities and other stakeholders to facilitate open dialogue, exchange information and seek feedback, and address any complaints or grievances, including in relation to TSFs where appropriate, throughout the industrial asset’s lifecycle. 

Our local engagement activities support the building of community and stakeholder knowledge about how we manage our TSFs and, where appropriate, support their participation in decisions that may have a bearing on public safety. Our Social Performance Policy requires our industrial assets to develop and maintain local level complaints and grievance processes where all stakeholders can raise any complaints or grievances they may have and which our teams are required to investigate and seek to resolve in a timely and consultative manner. 

We seek to ensure that Indigenous Peoples are consulted and have given their Free Prior and Informed Consent (FPIC) in relation to new TSFs or changes to existing TSFs where significant adverse impacts are likely to occur, including relocation, disturbance of lands and territories with critical cultural heritage. We seek, through good faith negotiation, to reach agreements with Indigenous Peoples who maintain an interest in, or connection to, the land on which we operate TSFs, formalising engagement processes and sustainable benefits. 

Aligned with the GISTM and to support safe tailings management, we require our industrial assets to develop and document knowledge about the local social, environmental, and economic context for each of their TSFs. This information is referred to as a Knowledge Base that is stored and managed within a centralised, digital GIS. Each industrial asset Knowledge Base displays, manages, and evaluates geospatial data within a single environment and can be used to inform tailings dam Consequence Classification and to prepare for long-term recovery in the event of a TSF emergency. The Knowledge Base also considers uncertainties associated with climate change.

Industrial assets are required to review and update their Knowledge Base at least every five years, and whenever there is a Material change either to the TSF or to the local social, environmental, and economic context.

The consideration of Credible Failure Modes, and the design measures/operational controls that should be in place in response, are key elements of our TSF design. The GISTM defines ‘Credible Failure Modes/Scenarios’ as "Refers to technically feasible failure mechanisms given the materials present in the structure and its foundation, the properties of these materials, the configuration of the structure, drainage conditions and surface water control at the facility, throughout its lifecycle. Credible failure modes can and do typically vary during the lifecycle of the TSF as the conditions vary. A facility that is appropriately designed and operated considers all these credible failure modes and includes sufficient resilience against each. Different failure modes will result in different failure scenarios. Credible catastrophic failure modes do not exist for all tailings facilities.

The term ‘credible failure mode’ is not associated with a probability of this event occurring and having credible failure modes is not a reflection of facility safety."

The assessment and selection of the Consequence Classification is based on Credible Failure Modes. It does not represent the likelihood or risk of a dam failure, meaning the Consequence Classification of a TSF is not equivalent with risk of TSF failure.

We assess our TSFs in accordance with the requirements of the GISTM and assign them a Consequence Classification based on the potential effects of dam failure by assessing the downstream conditions documented in the Knowledge Base and selecting the Consequence Classification corresponding to the highest consequence. 

We re-assess the Consequence Classification of our TSFs when there is a Material change in the condition of the TSF, or downstream conditions documented by the Knowledge Base, informed by the dam break analysis (DBA). The ITRB regularly review these DBAs for our TSFs with an ‘Extreme’ or ‘Very High’ Consequence Classification for alignment with international best practice. 

The Consequence Classification for a facility is required to be assessed and recommended by the EOR, based on the DBA informed by Credible Failure Modes. The ITRB is required to undertake their independent review and confirms the Consequence Classification with the Accountable Executive. In cases where the EOR and ITRB come to diverging assessments with regards to the recommended Consequence Classification, a further review and discussions are required to be held to reach alignment.

As the Consequence Classification can change throughout the TSF’s lifecycle we review and disclose on these on an annual basis for all our TSFs.

The assessment and management of risk is essential to the effective operation of TSFs across their entire lifecycle. For each TSF, our industrial assets are required to undertake a multidisciplinary risk assessment that considers the applicable Credible Failure Modes and the hypothetical consequences of a failure. Our industrial assets are also required to ensure and verify the adequacy and effectiveness of the preventative and mitigating controls for all Material risks for each of their TSFs. The verification conducted by our industrial assets is assured by Group Assurance.

When considering the risks posed by TSFs, there needs to be a methodology for assessing whether the risks may be classified as intolerable or tolerable. Where risks are classified as intolerable, we require actions to be undertaken to reduce the risks and where risks are classified as tolerable these risks may be considered acceptable without further risk reduction being undertaken. This range between intolerable and broadly acceptable risks is referred to as the As Low As Reasonably Practicable (ALARP) risk level. As defined in the GISTM, ALARP requires that all reasonable measures be taken with respect to tolerable or acceptable risks to reduce them even further until the cost and other impacts of additional risk reduction are grossly disproportionate to the benefit. Risks in the ALARP zone may be tolerable if it can be demonstrated to have been reduced to a level that is ALARP.

Applying the ALARP demonstration process to the risks posed by Glencore’s TSFs is conducted through a combination of Glencore’s TSF vulnerability matrix, which shows the vulnerability regions and where ALARP applies, and a measure of meeting Glencore’s TSF and Dam Management Standard. The assessment of ALARP is also supported by multi-disciplinary risk assessments which are required to consider the Credible Failure Modes, Consequence Classification of the TSF and the adequacy of the preventative and mitigative controls.

Whilst risk quantification can be used within an ALARP demonstration, this has not been adopted by Glencore for TSF risk management because quantitative techniques have the effect of compounding uncertainties and producing erroneous levels of confidence by using input data (such as TSF failure rates) that are generalised across incidents at sites that may have little in common with Glencore’s sites and approach to TSF management.

Robust designs are required to be developed that minimise the risk of failure during all phases of the TSF lifecycle, including closure and post-closure for all TSFs. For new TSFs, options relating to the site, technologies and design are to be assessed to identify the opportunities to reduce the potential consequences of a dam failure and support transition to a closure condition that minimises the long-term risk. We also require existing TSFs to periodically review new technologies to reduce risk and improve environmental outcomes. 

Uncertainties and impacts due to climate change are also required to be considered in the design, operation, maintenance, and closure of TSFs. A closure plan is required to be developed for each TSF with supporting details to a level of detail that is commensurate with the life of the facility. 

The operational management model of our TSFs follows a Plan-Do-Check-Act (PDCA) cycle through all phases of the lifecycle of a TSF: project conception and planning, design, construction, operations, and ongoing construction, temporary or permanent closure and post-closure when facilities have been configured for their perpetual form/state.

Our TSF Framework requires our industrial assets to develop and maintain TSF-specific EPRPs to ensure preparedness and response in the event of a failure. The EPRP is to provide information on managing the emergency response to a potential TSF failure event that presents a risk to people and the environment. 

We require our industrial assets to undertake a drill of their EPRP at all phases of the TSF lifecycle at a frequency established in the plan, or more frequently if triggered by a Material change either to the TSF or to the social, environmental, and local economic context.

Information and training sessions on the EPRP are required to be held with our employees and contractors to inform the implementation of preventative measures and mitigating controls. 

Our industrial assets must communicate their EPRPs with relevant stakeholders. Where appropriate, industrial assets may also engage with local and regional emergency response services in scenario planning and practice exercises.

TSF closure plans are required to be developed in accordance with the applicable regulations, as well as our internal standards and guidelines and are approved through the regulatory process where required. 

When we decommission and close our TSFs, we require that our industrial assets put in place appropriate measures for physical and geochemical stability and that land is rehabilitated for appropriate post-mining use in a manner that enhances stability. Where a landform for a closed TSF is not possible, closure plans of our industrial assets must address physical stability and the control of geochemical stability in a manner that protects the environment.

Until they reach the state of safe closure, TSFs are required to be inspected and monitored by dedicated teams on a regular basis. Our decommissioned and closed industrial sites with TSFs that are not in a state of safe closure are required to have operational manuals that include instructions on actions in case of an anomaly, emergency response, monitoring, etc. Our Group Assurance programme includes closed industrial sites.

Glencore has developed and implemented assurance processes to review effective execution of its TSF Framework and responsible management of our TSFs.

Self-assessment 
Our industrial assets are required to monitor their TSFs on an ongoing basis and identify, assess, and manage risk against the requirements of our TSF Framework to identify possible gaps and develop implementation plans to address them. The results are shared with industrial asset and commodity department management and reviewed as part of the dam safety audits by Group Assurance. 

Independent technical review
Our TSF Framework requires independent technical review by an ITRB or external engineer of the design, construction, operation, closure, and management of TSFs. The independent reviewers are required to be third parties who are not, and have not been, directly involved with the design or operation of the TSF. 

Group Assurance and dam safety audits
Group Assurance commissions independent third-party dam safety audits to review alignment of our industrial assets’ Tailings Management Systems with the Glencore TSF Framework. The results of these dam safety audits are reported to Glencore’s senior management, including the Accountable Executives, and our Board HSEC Committee. Findings are followed up through verification audits, which include review of progress on actions to close out findings. 

Dam Safety Reviews (DSRs)
We require our industrial assets to commission DSRs in accordance with the schedule set out in the TSF’s Operations, Maintenance and Surveillance Manual based on the Consequence Classification of the structure. Our Standard mandates that DSRs must be conducted at least every five years for TSFs with an Active or Inactive Status and at least every eight years for facilities with Closed Status unless there has been a Material change in performance or site conditions.

The DSRs are required to be carried out by an independent qualified review engineer who assesses and evaluates the safety of a dam or system of dams against Credible Failure Modes and defines an action plan to address any findings.