Task 5 – Develop a Local Accountability StrategyParticipate

Overview

A critical path to achieve stakeholder engagement outcomes is through Local Accountability Mechanisms. Through Local Accountability mechanisms, site should aim to establish multiple levels of open and accountable dialogue leading to greater mutual trust.

To help achieve this, all sites are required to define a strategy that outlines their understanding of accountability and trust as relevant to their context and how they will participate in local accountability mechanisms. This Task helps site define their strategy towards participation in local accountability mechanisms.

Sites will likely draw from a range of available mechanisms to demonstrate local accountability, potentially including (as appropriate for the site’s context):

Community engagement and consultation processes, including focus group discussions, townhall style meetings, regular engagements with community stakeholder representatives;
Implementation of the site’s grievance management system;
Formalised community structures to discuss performance commitments, e.g. dialogue tables, specific committees;
Participation in existing municipality, local business and NGO forums;
Disclosure of impact assessment reports and documents explaining performance, e.g. the site’s Stakeholder Accountability Report;
Commissioning of third-party assessments and the publishing of their findings;
Radio broadcasts, community newsletters;
Site visits for community stakeholder representatives and regulators; and
Q&A sessions with technical experts from the site

Trust is not built overnight but is established through consistent actions and behaviours over time. Building trust requires ongoing engagement, active participation, and a genuine willingness to listen, learn, and improve the company's social and environmental performance, as well as a commitment to act in the best interests of affected communities. There are different elements that may contribute to the building of trust, that may have varying significance depending on context. These elements are:

Reliability: Trust is built on the perception that the site consistently acts in a reliable and dependable manner. This includes fulfilling commitments, meeting legal and regulatory requirements, and delivering on promised benefits and outcomes.
Honesty and Transparency: Trust is enhanced when the site demonstrates openness, honesty, and transparency in its communications, actions, and decision-making processes. Providing accurate and timely information, openly acknowledging challenges and risks, and sharing both positive and negative outcomes contribute to building trust.
Integrity and Ethics: Trust is fostered when the site operates with a strong sense of integrity, adhering to ethical standards and principles. This includes demonstrating a commitment to responsible business practices, respecting human rights, minimizing negative social-environmental impacts, and engaging in fair and equitable relationships with affected communities.
Empathy and Respect: Trust is strengthened when the site shows empathy and respect towards affected communities. This involves actively listening to community concerns, valuing local knowledge and perspectives, and considering community well-being as an integral part of decision-making processes.
Consistency and Predictability: Trust is developed when the mining companysite demonstrates consistency and predictability in its actions. By establishing clear guidelines, policies, and processes and consistently adhering to them, the companysite builds confidence that it will act in a predictable and accountable manner.
Long-Term Commitment: Trust is nurtured when the mining company site demonstrates a long-term commitment to the well-being of affected communities, even beyond the lifespan of the mining project. This includes supporting sustainable development initiatives, engaging in meaningful community development programs, and leaving a positive legacy once operations cease.
Responsive and Accountable: Trust is reinforced when the mining companysite takes responsibility for its actions, listens to community feedback, and takes appropriate measures to address concerns and grievances. Being responsive to community needs, engaging in dialogue, and providing effective mechanisms for resolution and remedy contribute to building trust.

Develop a Local Accountability Strategy

Sites should integrate a Local Accountability Strategy within the site’s SEP outlining a systematic approach for measuring and strengthening local accountability and trust with local communities, including vulnerable groups. The strategy should define the site’s approach to being answerable to locally affected stakeholders for its responsibilities and actions. The strategy should define how the site will participate in local accountability mechanisms to sustain open dialogue, to provide transparent information and to receive feedback on a broad range of issues, including environmental and social performance, operational and proposed project activities, and socio-economic development opportunities.

When defining the site’s approach towards local accountability, sites should consider the following principles:

Inclusive – the approach should seek to include representation from all relevant stakeholders across the site’s area of influence, including vulnerable groups, making sure to consider their needs and interests regarding accountability, and preferred methods of information, communication, and engagement. No single accountability mechanism will reach all stakeholder representatives or cover all topics, therefore a portfolio of mechanisms is anticipated.
Context-specific – the approach must evidence an in-depth understanding of the site’s context and stakeholders, and define mechanisms that are ‘fit for purpose’.
Cross-functional – a range of internal disciplines should be aware of and understand what local accountability seeks to achieve and contribute to the development of the site’s approach. All functions should be aware of their role in the implementation of the site’s approach and support its success through timely disclosure and explanation of (for example) relevant social and environmental performance data, site plans and proposed activities and progress against commitments made.
Capacity-building – the local accountability approach should consider if capacity-building is required amongst participants - according to the mechanisms defined - to improve meaningful collaboration and, if so, how this could be facilitated.
Governance – depending on the mechanisms defined in the site’s local accountability approach, the site should identify what type of governance is needed to support intended local accountability outcomes. As appropriate to site local context, sites may seek to try and strengthen governance of existing mechanisms.
Accountabilities and resources – clear accountabilities, sufficient company time and resources are allocated to allow for effective running of local accountability mechanisms. Resourcing may include the need for external resources such as third-party facilitators, independent technical experts, legal experts, interpreters or translators.

To define an approach to local accountability, sites should analyse relevant background information, to ensure that they have all pertinent elements to make the strategy inclusive and context specific. With this, the site should define the strategy through cross-functional collaboration, documenting what will be understood for trust and local accountability in their context and what local accountability mechanisms will be considered, with a long-term view towards achieving their objective. Lastly, sites must ensure the strategy is reflected in the annual stakeholder engagement plan and that the M&E framework for stakeholder engagement includes perception analysis so the site may measure trust and local accountability.

Step 1: Analyse

Baseline of existing mechanism: Consider what are the existing mechanisms used by affected communities and do they / could they support delivery of the Stakeholder Engagement long term objective? Consider for each existing mechanism who participates, who do they represent, what is their purpose, what issues do they address, who do they benefit most? Use this analysis to identify the need for the site to establish new local accountability mechanisms and/or to participate (with potential strengthening) of existing structures.

Stakeholder mapping and analysis of interests and concerns: Use the results of stakeholder mapping and analysis (See 3A.2 Guidance, Task 3) to identify potential participants in local accountability mechanisms based on different interest groups, affected communities, vulnerable groups, existing leadership, etc. Identify decision-makers and influencers in the community, and which members of the community are generally excluded from decision-making.

The results of stakeholder analysis should be used to identify any potential challenges to local accountability mechanisms due, for example, to existing power dynamics and relationships between different stakeholder groups. Potential needs for capacity-building or other measures among stakeholders to enable meaningful participation should be identified.

Informed by this analysis, define a consultation approach for how the site will engage with internal and external stakeholders to support co-design and co-management of local accountability mechanisms. It is important to understand what factors contribute to levels of trust with Anglo American and with the mining sector more broadly, and how creating open dialogue through local accountability mechanisms could lead to greater mutual trust. The approach to consultation should define how the site will identify and engage with vulnerable or less-represented groups to understand how they would like to participate in local accountability mechanisms, either directly or through representatives. Internal consultations are also important to build understanding of the value and purpose of local accountability mechanisms and ensure necessary resources are dedicated to it.

A series of engagements may be required to ensure that local stakeholders are aware of how the site intends to work through local accountability mechanisms and that they understand the objectives of the site’s local accountability strategy, who represents them, how they can engage and how participants can be held to account.

Undertake a risks, challenges and opportunities’ assessment
Identify and assess potential risks, challenges and opportunities and associated mitigation measures. An example assessment with common themes is included in Table 3A.9 below.

Table 3A.9 Local Accountability Risks, Challenges and Opportunities

	DESCRIPTION	ACTIONS
	Lack of buy-in from external stakeholders	Allow time to understand and respond to stakeholder concerns, objections, and questions Embed a culture of co-design and co-management in the site’s approach to delivering its local accountability strategy objectives
	Lack of buy-in from management or other functions	Ensure Social Way requirements are understood Dedicated internal co-ordinator Appoint functional ‘local accountability champions’ Reporting on progress and outcomes of local accountability discussions
	Local conflict or politics hinders process of engagement through local accountability mechanisms	Understand existing community divisions, tensions and politics. If groups cannot be brought together, consider the need for working through multiple local accountability mechanisms Transparent engagement processes to avoid perceptions of favouritism or bias Messaging around the neutrality of local accountability mechanisms and the co-design processes that have informed them
	Low capacity to participate in local accountability mechanisms	Consider use of third-party capacity building support for both internal and external stakeholders
	Lack of support from authorities owing to perception that local accountability mechanisms undermine their role for decision-making, oversight or monitoring	Consult local government on the remit of the local accountability mechanisms and involve them in co-design processes Inclusion of local government representatives in setting up and participating in running of local accountability mechanisms
	Local accountability mechanisms not seen as truly representative and perpetuates power imbalances/exclusion of some groups	Anonymous grievance and feedback mechanism Co-design of governance arrangements Mechanisms to monitor, evaluate and report on local accountability mechanisms and outcomes they are achieving
RISKS/CHALLENGES	Lack of trust between participants hinders effective functioning of local accountability mechanisms	Process for all participants to report regularly on progress against local accountability strategy objectives
	Confidentiality issues	Set expectations around scope of local accountability mechanisms, and provide clear justification for issues not open for discussion Establish internal processes to get sign-off from relevant levels of the business before making commitments or sharing company information
OPPORTUNITIES	Promotion of goodwill and partnership opportunities as stakeholders see we are trying to solve development challenges and create value for others. Expectations are also managed better as stakeholders increasingly understand the limits of what sites can provide and the responsibilities of others	Be ready to respond to invitations to partner Continue to look for opportunities for learning and improvement; e.g. re-look at terms of agreement for forums every few years Share learning an invite other private sector players to join or replicate what has been done
	Improved understanding of local stakeholders’ concerns, interests, capacities and knowledge feeding into improved decision-making and planning processes	- Systematic record keeping, monitoring and evaluation so that learnings can be captured, documented and fed back to site
	Creation of an enabling environment so that new capital or exploration projects can be pursued without local opposition	- Build learning from local accountability mechanisms into participatory stakeholder engagement processes for projects and exploration opportunities early on
	Greater understanding of cumulative impacts and collaboration to address them	- Invitation to other operators to participate in local accountability mechanisms either as guests or members and/or share learnings with them

Step 2: Define Local Accountability Strategy

The content for the site Local Accountability Strategy should include the following:

Summary of background information analysis: From the analysis, sites should summarize the most relevant elements that will inform the strategy. This should include key findings from the baseline of existing mechanisms; important results from the stakeholder mapping and analysis of interests and concerns, as well as any significant controls identified for the risks, challenges, and opportunities.

Long-term Objective: Sites will have defined a long-term stakeholder engagement objective that takes into account the aim of local accountability. Sites should reference this objective in their Strategy and how the approach will contribute to the achievement of this objective.

Trust and Accountability in local context: The Strategy should present what contributes towards local accountability and trust within the site’s area of influence, informed by stakeholder analysis and the site’s external context review. Each site should make efforts to understand what accountability and trust means to the stakeholders of the area of influence, as this will guide the definition of mechanisms and well as inform the design of the perception analysis.

Local Accountability mechanisms: the Strategy must identify the local accountability mechanisms the site will participate in and/or implement with local communities, including vulnerable groups, that are appropriate to local context and aligned with wider local, regional and national stakeholder engagement processes.

When the approach requires participating in existing internal or external accountability mechanisms, the site outlines the stakeholders involved, scope and (where relevant) terms of reference, and proactively plans their involvement to strengthen accountability. If the approach requires developing and implementing new accountability mechanisms, e.g. a Community Engagement Forum, Social Way 3.0 guidance is applied as appropriate to the local context, and is proactively designed in a way to strengthen accountability with local communities.

For all mechanisms, it is recommended that there is a clear profile, that explains its structure ad scope, as well as the most relevant topics for accountability it will address.

The strategy should also include high level actions and outputs that will be implemented under the following Local Accountability components in order to achieve the long-term objective:

Co-design of accountability mechanisms
Community capacity development
Provide transparent, timely and accessible information to affected communities about our current and proposed activities
Meaningful engagement to integrate stakeholder views into site decision making and provide feedback
Co-design of monitoring and evaluation approach for site’s responsibilities and reporting of results
Acknowledgment of grievances and legacy issues, their mutual resolution and reporting of feedback

Some examples of outputs are included in Step 3 below. Detailed activities should be included in the SEP annual implementation plan.

Timeline: given the local accountability mechanisms defined by the site, the Strategy should list the most important milestones expected, such as improvement actions, capacity building initiatives or establishing new mechanisms, in a timeline.

It is recommended that the Local Accountability Strategy is presented to the SPMC for review and feedback, and depending on the Site’s process, approval.

The final approved Strategy may be incorporated as a section or appendix in the site’s Stakeholder Engagement Plan (SEP).

Step 3: Integrate the Local Accountability Strategy into stakeholder engagement planning and M&E

Integrate into Stakeholder Engagement Plan (SEP): The Local Accountability Strategy is not meant to be a plan. It should reflect the site’s understanding of accountability and trust, as well as the mechanisms that need to be in place. All detailed planning, involving specific annual milestones and corresponding operational planning should be developed as an integral element of stakeholder engagement planning and be found in the SEP.

Integrate into M&E framework for engagement: Indicators to measure progress and the efficiency and effectiveness of site work towards the long-term objectives should be included within the site SEP monitoring and evaluation framework and aligned with the SMP M&E framework, as appropriate to the site, capturing progress towards annual activities and long-term objectives.

The components included in Table 3A.10 below should be incorporated into the SEP M&E Framework and aligned with the SMP M&E framework, as appropriate for site context. Sites should develop indicators that are appropriate to their individual needs and draw from the guidance contained in Section1. Governance.

Table 3A.10 Local Accountability Monitoring and Evaluation

Local Accountability Component	Intended Output, i.e. what do we need to produce in order for this change to happen	Intended Outcome i.e. what do we need to change to achieve intended impact, and example indicators	Intended Impact with example indicators
Co-design of accountability mechanisms	Cross-functional local accountability strategy outlining a systematic approach for strengthening and measuring accountability and trust with local communities, including vulnerable groups, that outlines: What contributes towards accountability and trust at a local level and how this can be measured. A detailed, clear and proactive approach towards strengthening accountability, informed by the external context, stakeholder analysis, a risks and opportunities assessment and consultation, which is appropriate to the local context and aligned with existing stakeholder engagement plans.	The site is participating in local accountability mechanisms with affected communities, including vulnerable groups, that are appropriate to local context Example outcome indicator: % of communities within Area of Influence with representatives actively participating in accountability mechanisms % of groups identified as vulnerable that have representatives actively participating in accountability mechanisms % of Community representatives that report that they find the local accountability mechanisms to be informative and valuable	Open and accountable dialogue, through local accountability mechanisms, has led to mutual trust with local communities Example impact indicator: % of Community representatives that report that they trust Anglo American to manage its site activities and associated impacts with consideration of how communities could be affected Note that this could be broken down into separate indicators focused on trust in managing impacts, trust in explaining activities, trust in communicating future plans, etc.
Community capacity development	Needs Assessment conducted by third party to identify community capacity gaps that need to be filled to enable effective participation in local accountability mechanisms Community capacity development plan in place to provide identified skills need to facilitate effective participation in local accountability mechanisms	Communities participate effectively in local accountability mechanisms with appropriate skills and knowledge Example Outcome Indicator: % of community representatives that report that report they have the knowledge and skills to fully participate in accountability mechanisms	Open and accountable dialogue has led to mutual trust with local communities Example Impact Indicator: % of Community representatives that report that they trust Anglo American to manage its site activities and associated impacts with consideration of how communities could be affected Note that this could be broken down into separate indicators focused on trust in managing impacts, trust in explaining activities, trust in communicating future plans, etc.
Provide transparent, timely and accessible information to affected communities about our current and proposed activities	Provide relevant, accessible information in a culturally appropriate manner to stakeholders on our current and proposed activities and how they could be affected, using the following as examples: Stakeholder Accountability Reports Stakeholder Factsheets Video media Community newsletters Stakeholder consultation information sheets Radio broadcasts	Communities are aware of and understand our current and proposed activities and how they could be affected Example Outcome Indicator: % of community representatives that report they feel aware of and understand site current and proposed activities and how they could be affected	Open and accountable dialogue has led to mutual trust with local communities Example Impact Indicator: % of Community representatives that report that they trust Anglo American to manage its site activities and associated impacts with consideration of how communities could be affected Note that this could be broken down into separate indicators focused on trust in managing impacts, trust in explaining activities, trust in communicating future plans, etc.
Meaningful engagement to integrate stakeholder views into site decision making and provide feedback	Stakeholder Engagement Plan defines activities to deliver two-way engagement through local accountability mechanisms on current and proposed site activities that could affect stakeholders’ lives Consultation analysis is undertaken to summarise stakeholder views relevant to site decision making Site meeting minutes, e.g. SPMC, demonstrate that stakeholder views are reported to site leadership, have been considered and where appropriate have informed site decision making Feedback sessions are held through local accountability mechanisms to explain how community views have informed site decision making	Operations demonstrate that site decisions which affect local community stakeholders are made informed by stakeholder views and feedback is provided Example Outcome Indicators: % of site key social performance processes³ that are planned and monitored with local communities through local accountability mechanisms⁴ % of community representatives that report their voice is listened to when the site makes decisions on issues that affect their lives	Open and accountable dialogue has led to mutual trust with local communities Example Impact Indicator: % of Community representatives that report that they trust Anglo American to manage its site activities and associated impacts with consideration of how communities could be affected Note that this could be broken down into separate indicators focused on managing impacts, trust in explaining activities, trust in communicating future plans, etc.
Co-design of monitoring and evaluation approach for site’s responsibilities and reporting of results	Co-designed monitoring and evaluation process for site responsibilities relevant to local communities –covering impact management, commitments and SED delivery Stakeholder engagement materials explain monitoring and evaluation results and corrective actions taken Stakeholder consultation logs demonstrate delivery of monitoring and evaluation focused engagement materials and recording of feedback	Communities understand and are confident in how site monitors and evaluates its responsibilities and how the site is committed to continuous improvement Example Outcome Indicators: % of community representatives that report they are confident in the process the site uses to monitor and evaluate its responsibilities % of community representatives that report they are confident that site’s monitoring and evaluation process is contributing to continuous improvement	Open and accountable dialogue has led to mutual trust with local communities Example Impact Indicator: % of Community representatives that report that they trust Anglo American to manage its site activities and associated impacts with consideration of how communities could be affected Note that this could be broken down into separate indicators focused on trust in managing impacts, trust in explaining activities, trust in communicating future plans, etc.
Acknowledgment of grievances and legacy issues, their mutual resolution and reporting of feedback	AASW aligned grievance management procedure Grievance management awareness raising materials Consultation logs demonstrating engagement on grievance remediation Action plans detailing approach to legacy issues including how – where feasible and appropriate – they will be addressed	Timely and collaborative remediation of grievances and – where feasible and appropriate – legacy issues Example Outcome Indicators: % of grievances closed out to satisfaction of complainant within the agreed timescales % of community representatives that report they are confident in the site’s grievance management processes % of known legacy issues that have been considered at SPMC for remediation (noting that the conclusion may still be that remediation is not feasible or appropriate)	Open and accountable dialogue has led to mutual trust with local communities Example Impact Indicator: % of Community representatives that report that they trust Anglo American to manage its site activities and associated impacts with consideration of how communities could be affected Note that this could be broken down into separate indicators focused on trust in managing impacts, trust in explaining activities, trust in communicating future plans, etc.

³Social Management Plan definition, stakeholder engagement approach, grievance management processes, commitments management processes, and impact identification and management

Sites are required to undertake Perception Analysis that can be carried out using both quantitative and qualitative methods. Many of the outcome indicators proposed above can be assessed using the Perception Analysis. Further details are provided under Task 9 and also in Tool 2.

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