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 the industrial departments and business units (excluding Oil and Capital Projects Group, which do not have TSFs), as well as dam owners, Engineers of Record (EOR) and Responsible Tailings Facility Engineers/Responsible Person (RTFE/RP) 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. 
• Dam owners are the site’s senior executive management person with assigned responsibility to appropriately resource the TSF.
• EORs are 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/RP have 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 Internal Audit and Assurance (GIAA)has been commissioning independent third-party dam safety audits of TSFs with an ‘Extreme’, ‘Very High’ or ‘High’ Consequence Classification 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.

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/RPs 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 we have the potential to impact human rights directly through our operations, and through relationships with business partners. We are committed to respecting the dignity and human rights of our workforce, business partners, and the societies in which we live and work in line with the United Nations (UN) Guiding Principles on Business and Human Rights. We aim to:

• make a positive contribution to the advancement of human rights of all people, including vulnerable groups
• 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. 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 the fundamental elements of our 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, prevent, mitigate, assess, and manage human rights risks linked to our operations, as part of our ongoing human rights due diligence process.

Glencore maintains a human rights risk rating tool that, based on our identified salient human rights risks and country and local-specific indicators, determines the level of exposure to human rights risks. This tool assigns a ‘High’, ‘Medium’ or ‘Low’ human rights risk rating to each Glencore industrial asset and sets minimum performance expectations for human rights management and due diligence. 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. 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 – aligned with the United Nations Guiding Principles effectiveness criteria – that enable all stakeholders to raise any actual or perceived 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 respect the rights, interests, perspectives, and aspirations of Indigenous Peoples, and recognise their right to maintain their culture, identity, traditions, and customs. In line with the ICMM Position Statement on Indigenous People and Mining, we are committed to operating in a manner that upholds these values. For new TSFs or significant changes to existing TSFs where significant adverse impacts are likely to occur, including relocation, or disturbance of lands, territories or areas of critical cultural heritage, we aim to obtain free, prior, and informed consent (FPIC) of Indigenous Peoples through good faith negotiation.

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 digital GIS. Geospatial data at each industrial asset Knowledge Base may be displayed, managed, and evaluated 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 current 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 or senior independent reviewer is required to undertake their independent review and confirms the Consequence Classification with the Accountable Executive. 

As the Consequence Classification can change throughout the TSF’s lifecycle. we review and update 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. 

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 further 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 in various geographies. 

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.

Where there is a credible flow failure, 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.

Aligning with principle 14 of the GISTM, we require our TSFs with an ‘Extreme’, Very High’, or ‘High’ Consequence Classification to develop long-term recovery plans (LTRP) so that we are prepared in the unlikely event of a failure.  The LTRP is informed by the knowledge base and provides existing information on the environmental, social, and local economic context within the area of influence and information on stakeholders that might help with post failure recovery strategies in the event of a failure.  

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 which consider physical and geochemical stability and that the TSF 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 observed anomaly, emergency response, monitoring, etc. Our Group Internal Audit and Assurance (GIAA) 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 industrial department and business unit management and reviewed as part of the dam safety audits by Group Internal Audit and Assurance (GIAA). 

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
GIAA commissions independent third-party dam safety audits to review alignment of our industrial assets’ Tailings Management Systems with the Glencore TSF Framework, applying a risk-based approach. 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.