Different contexts, types of ASM activities, and risks and impacts require different management approaches and controls. Figure 4K.3 and Table 4K.5 describe a range of approaches that may be relevant in different contexts and at different times. The approaches are schematic and broadly defined based on a spectrum. Sites should consider this range of options when determining a broad direction for their ASM management approach, tailored to their context. For example, avoiding ASM-related impacts might not always be possible (especially where ASM is present illegally on the site’s concession), and thus minimisation, mitigation, remediation and compensation/offsetting of impacts may play a larger role. The ASM management approaches are not mutually exclusive, and their components can be combined and adapted to the specific ASM context.

A full risk assessment should support decision making on the types or combination of ASM management approaches most suitable to address potential ASM-related risks and impacts and achieve long-term objectives. The SPMC should be involved in determining the broad direction of an approach to manage ASM, in consultation with other relevant functions including legal, security and Government relations. The BU or Group Social Performance should also be consulted, particularly if sites choose an approach that falls under categories 4 – 6.

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Figure 4K.3 – ASM management approaches

For ASM management approaches 1 to 3, economic or physical displacement of ASM stakeholders may be necessary. In such a case, sites should follow the process outlined in Section 4F on Land Access, Displacement and Resettlement, and consider the additional ASM-specific guidance in the Tools section. Under ASM management approaches 4 – 6, sites may allow ASM on the concession area under strict rules and supervision.

Targeted SED programmes may be an effective control for approaches 3 - 6. In such cases, sites should follow the guidance in Section 4A on Socio-Economic Development, and specifically assess the need for, and feasibility of, supporting the professionalisation and formalisation of ASM, providing technical and livelihoods support to ASM and/or supporting the development of alternative livelihoods.

Table 4K.5 suggests which approaches might be best suited for which contexts and provides a view of advantages and disadvantages. A site’s approach to ASM management can change over time.

Table 4K.5 ASM management approaches

ASM management approach	Description	Applicability and advantages	Disadvantages and considerations
1. Security only (this type is not typically recommended, but listed here to give a view of the full range of options)	Focus on protection of the site (including concession area) and deterrence of ASM activities on the site through site security measures Approach relies on security controls and arrest, detention and/or evictions of ASM stakeholders trespassing on the site by relevant security forces Typically calls on public security services as needed Any physical or economic displacement of ASM stakeholders is conducted in line with the requirements outlined in Section 4F on Land Access, Displacement and Resettlement No other measures are taken	May be necessary in some contexts, for example where ASM activity poses risks to employees or communities or is clearly illegal Can be useful where there are only sporadic incursions of individual miners Can be an appropriate preventative approach where the ASM population in the area is very small and where ASM is not common around the site.	Reactive approach only, often results in ‘firefighting’ Increases tensions, mistrust and conflictual relationships with ASM stakeholders and/or local community Can result in violence between ASM stakeholders and site workers or against site property Higher risk of human rights violations by public and private security forces on ASM stakeholders and innocent bystanders Taking only this approach is not considered good practice and can exacerbate the impacts and risks the approach intends to prevent or avoid.
2. Security and government deterrence of ASM	Protection of site (including concession area) and deterrence of ASM activities on the site through site security measures Approach relies on arrests, detention and/or negotiated departure of ASM stakeholders trespassing on the site Combined with regular formal and government engagement to discuss desired approach of public security forces (in line with the VPSHRs), Government efforts to formalise the ASM sector, and finding alternative solutions for allowing ASM outside the site’s concession area Any physical or economic displacement of ASM stakeholders is conducted in line with the requirements outlined in Section 4F on Land Access, Displacement and Resettlement	Can be useful where there may be risks of larger ASM influxes or more permanent ASM activities and larger groups of ASM stakeholders on the site’s concession, but the interaction between site and ASM actors is relatively straightforward to manage	Little control over the government’s approach regarding managing ASM could lead to human rights abuses and other negative impacts and risks Relatively reactive approach and broader dynamics and root causes around ASM not resolved Can result in violence between ASM stakeholders and site workers or against site property Risk of human rights violations on ASM stakeholders and innocent bystanders by public and private security forces
3. Co-existence off the site’s concession area: supporting alternative ASM areas	Protection of site (including concession area) and deterrence of ASM activities on the site through site security measures Regular formal and constructive engagement with government, ASM stakeholders and other relevant actors, potentially in a multi-stakeholder process Site provides support to the government and/or ASM stakeholders in finding a suitable alternative area for ASM activities to take place outside the site’s concession area. Support could consist of facilitating formalisation, assessing alternative areas’ geology and providing advice on ASM mine planning, as well as ASM enterprise development and other technical support if required. Any physical or economic displacement of ASM stakeholders is conducted in line with the requirements outlined in Section 4F on Land Access, Displacement and Resettlement	Can be useful if there are permanent ASM activities on the site’s concession area, requiring economic displacement Can be useful if ASM is an established and important livelihood for the communities in the area Can reduce tensions, establish trust and a less conflictual relationship Gives the site the opportunity to support community livelihoods	Thorough understanding of ASM context and dynamics is necessary Requires more time, expertise and resources May not be feasible in areas where no alternative area for ASM is available Alternative areas may be exhausted over time Interventions can be risky with a relatively small number of successful case studies
4. Co-existence on site concession area: allowing certain ASM activities in certain zones of the site’s concession area	Protection of site and deterrence of ASM activities through security measures, but adjusted to allow certain ASM activities on specific zones in the site’s concession area, requiring tailored security measures, such as miner registration and access control to that ASM zone, training and potentially technical assistance Can include site support for the ASM operator in terms of enterprise development, safety, health, and environmental standards and practices, and application of certain mining techniques. Tolerating certain clearly defined ASM activities under clear rules in specific zones on the site’s concession area (e.g. waste/tailings handpicking, washing of ore brought from outside the concession) Requirements for human rights, safety, health, and environmental practices for ASM activities. Site could support ASM activities in achieving these requirements Sometimes combined with government engagement to discuss formalising the ASM sector Sometimes combined with supporting the government and/or ASM stakeholders in finding a suitable alternative area for ASM activities to take place outside the site’s concession area Includes regular monitoring and conducting due diligence.	Can be useful if there is a large ASM population on the permit area Can be useful as a mitigation strategy to economic displacement of ASM from other concession areas Can be useful where ASM activities on concession consist mainly of handpicking or washing (not digging) Can be useful where ASM activities are focused on using the site’s waste rock dumps and/or tailings dams, or where ASM activities are focused on mining other minerals than those mined by the site Can be a means to upskill ASM populations if technical assistance and training is integrated with the approach Could serve as a route-to-market for economically marginalised ASM Can be a means to reduce tensions and improve relationships	Thorough understanding of ASM context and dynamics is necessary Higher reputational and legal risks where human rights, safety, health, and environmental issues related to ASM are not addressed Requires more time, expertise and resources and generally strong Government support Interventions can be risky with a relatively small number of successful case studies Suitable areas may be exhausted over time Requires clear, nuanced and timely communication on the efforts to secure civil society and media buy-in Not feasible in jurisdictions where the legal framework does not allow other operators on the site’s concession area Can increase rehabilitation and closure costs
5. Cohabitation	Protection of site (including concession area) and deterrence of ASM activities on site through site security measures Formally giving a part of the site’s concession area to an ASM operator, i.e. the site subcontracts/authorises ASM mining activities in a specific zone of its concession area, in accordance with the relevant legal framework. Includes a formal agreement with the ASM operator, including a clear definition of roles, responsibilities and liabilities between the site and the ASM operator Can include site support for the ASM operator in terms of enterprise development; health, safety, and environmental standards and practices, and application of certain mining techniques. Includes regular monitoring and conducting due diligence.	Can be useful where ASM activities focus on other minerals than those extracted by the site Can be useful where there are large permanent ASM activities on the site’s concession area, and where economic displacement of ASM stakeholders would cause conflict Opportunity to upskill ASM miners if technical assistance and training is provided by the company	Requires more time, expertise and resources and generally strong Government support Requires a well organised ASM counterpart (e.g. ASM association, ASM cooperative, ASM small business) Not feasible in jurisdictions where the legal framework does not allow giving parts of the site’s concession area to another operator Requires clear, nuanced and timely communication on the efforts to secure civil society and media buy-in Can increase rehabilitation and closure costs
6. Commercial collaboration	Protection of site (including concession area) and deterrence of ASM activities on site through site security measures Where feasible and legally possible, site formally gives (or authorises/subcontracts) a part of its concession area to an ASM operator by contracting the ASM operator as a supplier or sub-contractor A formal commercial agreement is established (for example one in which the site buys minerals produced by ASM operator) which includes a clear definition of roles, responsibilities and liabilities between the site and the ASM operator ASM operator workers are registered and access control around the ASM area is established Can include site support for the ASM operator in terms of enterprise development, safety, health, and environmental standards and practices, and application of certain mining techniques. Includes regular monitoring and conducting due diligence, as well as establishing a chain of custody/traceability system for ASM production.	Can be a win-win option for the site and the ASM stakeholders. Can be useful if there are large permanent ASM activities on the site’s concession area, and where economic displacement of ASM stakeholders would cause conflict. Can be useful in areas where ASM is an established and important livelihood. Can be useful where ASM targets the same minerals as the site. Site has control over ASM activities and how they are conducted Can support ASM formalisation.	Requires a well organised ASM operator (e.g. ASM association, ASM cooperative, ASM small business) Not feasible in jurisdictions where the legal framework does not allow the site to give parts of its concession area to another operator Requires the ASM operator to adhere to human rights, security, health and environmental standards Can include economic and/or productivity challenges, e.g. ASM operator not agreeing with prices paid, or stoppage of ASM activities when market prices fall