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Controls should be developed for all (potential) impacts and risks. SHIRA follows the mitigation hierarchy of avoid, minimise, mitigate, remediate, and compensate/offset. SHIRA also follows the hierarchy of controls of elimination, substitution, engineering, separation, administration, and PPE. The prioritisation of controls should reflect these hierarchies.

The controls for potential social and human rights impacts and risks are typically cross-Functional. While S&SD may be a Risk Owner, Control Owners may consist of Social Performance, Security, etc and vice versa.

As per the ORM process, all risks or potential impacts assessed as High or Major in their Social Consequence level are a Priority Unwanted Event (PUE), irrespective of their likelihood. A bowtie analysis should be developed for each PUE. Parent bowties have been developed by Group Social Performance for common PUEs and are available for sites as needed. Sites are required to implement, at a minimum and where relevant, the Critical Controls identified in the parent bowties, and identify additional controls as relevant to the site’s context.

The process of developing controls and bowties should be led by the Risk Owner and should include all Control Owners. Clear controls should be developed, and the roles and responsibilities of different departments in control ownership, implementation and monitoring and evaluation (see CHECK below) should be clarified.

Potential adverse impacts on vulnerable groups require specific and/or additional controls. Sites may also need to initiate additional, targeted and long-term measures to address both the causes and consequences of vulnerability.

In cases where some of those impacted are vulnerable to the impact and others are not, sites should provide two different consequence levels and develop addition controls for those who are vulnerable to the impact.

In order to mitigate cumulative impacts, engagement and/or partnerships with relevant external stakeholders, such as other companies or sites active in the area and/or local authorities, may be required.

3C.2 Guidance | Do
3.Engagement and analysis  |  3C Social and human rights impact and risk analysis (SHIRA)  |  3C.2 Guidance  |  Do