"Re: Civil society calls for second public consultation on the proposed governance model of the Consolidated Mining Standard Initiative (CMSI)", 11 July 2025

"Rohitesh Dhawan, President and CEO, ICMM.
Pierre Gratton, President and CEO, MAC.
Michèle Brülhart, Executive Director, Copper Mark.
David Tait, CEO, World Gold Council.
Members of the Consolidated Mining Standard Initiative Industry Advisory Group and
Stakeholder Advisory Group

Re: Civil society calls for second public consultation on the proposed governance model of the Consolidated Mining Standard Initiative (CMSI)

Dear Mr. Dhawan, Mr. Gratton, Ms. Brülhart, Mr. Tait, and IAG and SAG members:

We, the below signed organizations and individuals are alarmed that the Consolidated Mining
Standard Initiative has seemingly removed the governance model from a second public
consultation.

We call on you to hold a second public consultation on the governance model by either
reinstating the governance model in the second public consultation of the full package or
holding a separate second public consultation on the governance model. It is important
the feedback process be open for ALL four components of the initiative, including and
especially the governance model.

Removing the governance model from the second consultation is a rollback of previous
publicly-communicated commitments that the 40-day long second public consultation would
include all four components of the Initiative: the draft Standard, governance model, assurance
process, and the reporting and claims policy.

It removes transparency and equitable access to influencing the development of the standard’s
decision-making body, arguably the most important element of the CMSI.

The governance model will dictate the implementation of the standard including how audits are
carried out, the quality of information audits provide, and whether companies or the CMSI will
meaningfully address any grievances brought forward by impacted workers and/or community
members.

The decision to forgo a full second consultation could decrease participation in the CMSI
process, which by the Executives' own admission has inherent power asymmetries and the
consultation report shows has low participation from frontline communities and rights-holders,
the very groups who will be most impacted by the standard.

The second public consultation must not only seek comment and feedback on all four parts of
the Consolidated Standard, but the Four Executives and their subsequent advisory groups

https://media.business-humanrights.org/media/documents/Standards_response_letter.pdf
https://miningstandardinitiative.org/wp-content/uploads/2025/03/CMSI-Consultation-Report.pdf
https://miningstandardinitiative.org/wp-content/uploads/2025/03/CMSI-Consultation-Report.pdf

should use the information captured in their summary report to expand the reach of the
consultation to frontline communities, particularly Indigenous Peoples, of mineral-producing
nations. At the very least, those who will be most affected by the standard should have equal
and equitable access to commenting on the draft standard since their direct participation has
been so limited.

Signed,
African Resources Watch (AFREWATCH)
Batani Foundation
Center for support of indigenous peoples of the North (CSIPN)
Dutch Association of Investors for Responsible Development (VDBO)
Earthworks
ECOS
Fundación Tantí
Global Witness
Indigenous Peoples Rights International (IPRI)
IndustriALL Global Union
London Mining Network
Malach Consulting
Mighty Earth
Natural Resources Governance Institute (NRGI)
NGO Ecosistemas Chile
Northern Confluence Initiative
Oxfam
Public Citizen
Publish What You Pay (PWYP)
Rainforest Foundation Norway
SOMO
Securing Indigenous Rights in the Green Economy (SIRGE) Coalition
Tallgrass Institute
Transparency International Australia - Accountable Mining Programme
Transparentem
Voices (former Society for Threatened Peoples, Switzerland)
Quipa Collective
ZERO – Association for the Earth Sustainability
Zimbabwe Environmental Law Association (ZELA)
Febrilliant Maulana Husein
Marilou Verano-Philippines
Ryan Guerry"