Effective assurance is a valuable feedback mechanism for those directly involved in tailings management. Depending on the mechanism used, assurance potentially provides perspectives on current performance, deficiencies, opportunities for improvement, future plans, and other tailings management aspects.
Also, effective governance of our TSFs also requires accountabilities to be clearly defined and appropriately qualified personnel appointed to key governance roles.
There are four key first-line activities that we mandate across our operated assets:
Frontline employees are the first line and manage the day-to-day operations and safety at the site while connected via regular communication to the relevant RTFE and AE.
Two of our operations have Independent Tailings Review Boards to strengthen the control environment for TSF failure risks. Gold Fields assesses the dam classification, risk, and operational circumstances in determining whether to appoint a Tailings Review Board. Not all TSFs will have a Tailings Review Board; they are in place for all our operated assets with ‘very high’ or ‘extreme’ consequence classified TSFs (following the GISTM classifications).
For TSFs where a Tailings Review Board is not required, independent, senior technical reviewers will act in this capacity.
Gold Fields utilises the following mechanisms to provide assurance:
Audits evaluate and report on the degree of conformance with stipulated criteria based on the systematic collection and documentation of relevant evidence. Audits involve some degree of judgment but are not designed tdetermine the root cause of deficiencies or evaluate management system effectiveness.
We retain an Engineer of Record (EoR) for most of our active sites. As of January 2023, our EoRs are employed by the following companies: WSP/Golder (4 TSFs), Stantec (1 TSF), SRK Consulting (1 TSF), Knight Piesold (4 TSFs), SLR Consulting (8 TSFs), Tetra Tech (5 TSFs) and CMW Geosciences (8 TSFs).
The EoRs are responsible for reviewing and approving all engineering and design data, associated operating and monitoring procedures, as-built drawings, and facility inspections tconfirm physical integrity, safety, and the performance of the facility and ancillary structures.
The EoRs define the parameters and specifications for construction and operations, such as embankment and dam slope angle, allowable rate of rise, construction and operational material quality and methods, and the dam's phreatic surface level and minimum freeboard requirements.
A comprehensive third-party review covering operational, legal aspects, and sustainable development must be carried out every three years. This review alschecks the operation's ongoing compliance against the Group TSF Management Standard and applicable design guidelines.
Facilities that have an "Extreme" consequence rating must have this third-party operational review carried out on an annual basis.
Legal and regulatory compliance audits are typically carried out annually tcheck compliance against permits and operating licenses. The frequency of these audits might differ for operations in Ghana and Peru.
Local regulations may alsrequire operations tregularly undertake third-party reviews with a report on the findings required tbe submitted tvarious governmental agencies. For example, Ghana requires quarterly third-party operational reviews tbe conducted and reported.
Third-party reviews are most effective if they begin at the project conception and continue through the design, construction, operation, and closure stages. As such, the intent of a third-party review is tidentify and address potential deficiencies before they occur and is fundamentally a preventative risk control measure. The preventative focus of third-party reviews fosters continual improvement and mitigates complacency.