Mining enterprise compliance management practice points seven: project construction compliance

Third, several suggestions on mining enterprises to carry out compliance management of mining project construction

In order to effectively prevent and control compliance risks in the construction of mining projects, mining enterprises should focus on the content of sorting out compliance obligations, identifying compliance risks, coping with compliance risks, formulating special guidelines for compliance management, and improving the compliance operation mechanism, etc., and carry out professional and accurate compliance management of mining project construction, so as to help mine projects enter the production stage from the construction stage as soon as possible.

(1) Comprehensively sorting out compliance obligations around the regulatory requirements of mine project construction

The first is to systematically sort out the laws, regulations, rules and normative documents in the field of mining project construction, on the basis of doing a good job of combing the laws and policies at the central level, it should also strengthen the combing of local regulations, rules and normative documents in the location of mining rights, and make full reference to the service guidelines issued by government departments.

The second is to sort out and classify the compliance obligations involved in the construction of mine projects in combination with factors such as the timing of construction of mine projects, types of compliance obligations, administrative approval procedures, and form a systematic, complete and practical list of compliance obligations.

The third is to pay timely attention to the progress of the reform of the construction management of mine projects, pay attention to the revision of relevant laws and regulations, policy changes and regulatory developments, and regularly update the list of compliance obligations.

(2) Focusing on the whole process of mine project construction, systematically identifying compliance risks

First, mining enterprises should adopt various methods such as interview research, data reference and case analysis to comprehensively and systematically identify compliance risks according to the specific compliance requirements involved in various administrative approval links in the process of project approval, construction approval and completion acceptance, so as to ensure that risk identification covers the whole process of mine project construction.

Second, the legal basis, form of expression, risk examples and consequences of violations of each compliance risk in the construction process of a mine project are listed in detail, and classified and sorted according to the construction process of a mine project to form a systematic, comprehensive and intuitive compliance risk database.

Third, according to the progress of mine project construction, combined with changes in external laws, regulations and policies, timely revise and update the compliance risk database.

(3) Taking into account risk prevention and project promotion, and responding to compliance risks at different levels

First, in view of the compliance risks in the process of mining project construction, mining enterprises should carry out risk analysis and evaluation on the possibility of occurrence of compliance risks, the degree of risk impact and the degree of corporate control, and form a risk assessment report.

Second, according to the red line of disruptive risks, compliance defects that need to be focused on, general compliance defects and other different situations, compliance risks are divided into high, medium and low levels, and the priority of compliance risk prevention is distinguished. On this basis, a targeted response plan should be formulated, effective measures should be taken to eliminate risks or control risks within an acceptable range, and compliance management can take into account the needs of mine project promotion and compliance supervision.

(4) Formulate special compliance guidelines according to the actual needs of project compliance management

Mining enterprises should focus on the key issues and important links in the project construction management, and formulate special guidelines for compliance management as the action guide for the compliance management of mine project construction. Specific guidelines should focus on the following areas:

First, it is necessary to systematically and comprehensively sort out the mining project construction management process according to the project construction timing and the relationship between the approval items, and clarify the handling requirements and procedures of the administrative approval items in each specific link, so that the relevant departments and personnel of mining enterprises can fully grasp the key points of compliance management in the construction of mining projects.

The second is to clarify the compliance points that should be paid attention to and the compliance responsibilities that need to be performed among various departments and management entities at different levels of mining enterprises; At the same time, strengthen the internal coordination and cooperation of the enterprise to improve the efficiency of compliance work.