M&E Insights, June 2021

Continual improvement among Certified Entities is a key short-term outcome that ASI expects to see, as a result of implementing our strategies as defined in our Theory of Change. Entities are required to prepare and implement appropriate Corrective Action Plans for all Non-Conformances that are identified during an Audit, and address the root cause to prevent recurrence of the finding.

This month, we look at improvement in Conformance Ratings in ASI Performance Standard certificates as of 25 June 2021.  The data below reviews:

  • Incidences of Non-Conformances (Major and Minor) during the First Certification Audit, and
  • Whether these have been closed by the next Audit (i.e., Surveillance Audit, Re-Certification Audit or Scope Change Audit).

Non-Conformances of all Performance Standard Certificates (open and closed) are shown in the graph below.

The graph shows that 86% of NCs are closed (or downgraded) at the subsequent audit, demonstrating corrective actions and improvements on key sustainability topics are being put in place at ASI Certified operations.

The closed Major and Minor Non-Conformances in each Principle are indicated in the graph below.

ASI supports Members in improving their performance and supporting continuous improvement. As part of the current ASI’s Standards Revision process, the ASI Performance Standard Guidance is being further enhanced to support interpretation and implementation.

ASI will also develop new and update existing educationAl training modules in 2021 and 2022 to address key non-conformance areas.  These will include new modules on Human Rights and exercising risk-based due diligence in the aluminium value chain in accordance with the OECD Due Diligence Guidance, Waste Management, Discharges to Water, Quantifying and reporting Emissions to Air, Biodiversity Assessment and Mine Rehabilitation and Closure.

Closed Non-Conformances and Corrective Action taken

The majority of closed Major and Minor Non-Conformances in the ASI Performance Standard were found in Principle 6 – Emissions, Effluents and Waste, Principle 9 – Human Rights, Principle 2 – Policy and Management, and Principle 10 – Labour Rights.

Principle 6 – Emissions, Effluents and Waste

Under Principle 6, Emissions, Effluents and Waste, 11 Non-Conformances (2 Major, 9 Minor) were identified and have been closed as indicated in figure 1 below.

Figure 1 – Principle 6: Emissions, Effluents and Waste Closed Non-Conformances
Reasons for Non-Conformances Corrective Action taken
– Lack of public disclosure of specific information as required by the ASI Performance Standard – Making information accessible and publicly available in annual environmental reports or similar, or setting up procedures to publicly disclose.
– Impact Assessments of spills and remediation actions taken

Principle 9 – Human Rights

Under Principle 9, Human Rights, 9 Minor Non-Conformances were identified and have been closed as indicated in figure 2 below.

Figure 2 – Principle 9: Human Rights Closed Non-Conformances
Reasons for Non-Conformance Corrective Action taken
– Lack of, incomplete, or need for improvement of due diligence processes – Establishing proper due diligence processes, including previously missing elements that were identified
– Stakeholders were mapped but there was no regular engagement with the local council or communities – Regular engagement with the local communities and councils in the surroundings of the site is taking place

Principle 2 – Policy and Management

Under Principle 2, Policy and Management, 7 Minor Non-Conformances were identified and have been closed as indicated in figure 3 below.

Figure 3 – Principle 2: Policy and Management Closed Non-Conformances
Reasons for Non-Conformance Corrective Action taken
– Not having a Responsible Sourcing policy – Establishing a Responsible Sourcing policy that includes environmental, social, and governance issues
– Impacts Assessments omitted social, cultural and human rights aspects, or outdated supplier risk assessments – Developing and implementing systems and processes to conduct Impact Assessments according to ASI’s Performance Standard criterion.

Principle 10 – Labour Rights

Under Principle 10, Labour Rights, 7 Minor Non-Conformances were identified and have been closed as indicated in figure 4 below.

Figure 4 – Principle 10: Labour Rights Non-Conformances
Reasons for Non-Conformance Corrective Action taken
– Not all workers are enrolled in mandatory social insurance schemes – All workers engage in mandatory social security schemes
– One welder worked an amount of hours in excess of the legal maximum and had a period of rest below the legal minimum. Other employee files reviewed were in conformance. – No new situations were observed based on checks and controls performed during the Surveillance Audit.

Stay tuned for our next M&E Insights article coming in the June newsletter!