Thank you.
Thank you for inviting us to join you, and I apologize; I've had the trip on which everything that could go wrong has gone wrong. I'm running.
I work with the Association for Mineral Exploration B.C. I work out of our Vancouver office. What I really wanted to do today is bring a perspective to you from the exploration community, primarily in British Columbia, but also nationally and internationally.
The Association for Mineral Exploration was established in 1912. We represent over 300 corporate and 3,000 individual members. These are primarily prospectors and junior exploration companies. We also have the exploration divisions of some of the senior companies in our membership.
Our areas of focus are primarily health and safety, aboriginal and community engagement, and policy development. We also have a large conference, Mineral Exploration Roundup, where we do technical work.
The context for our members is that in some ways it is quite daunting for folks who are working in a small office or perhaps on their own to try to understand operationally what the guidance is telling them to do. In terms of the international work that has been happening, we've had to make a lot of investment in understanding and providing guidance to our members on how they can implement operational practices that will meet the tests of health and safety standards, environmental management, social development impacts, and, now, human rights.
I want to share some of my own involvement in this. I have worked with first nations for almost 25 years, both in the community as a social worker and in development initiatives as an industry employee. I think the challenge and the opportunity can both be underestimated in terms of what the presence of industry can mean to a community, and it's primarily the examples of first nations that have raised a lot of questions for our members about what the expectations are of them internationally.
As for some of the things we've been working on in British Columbia, we have been working with first nations in an area where there is very little of the province that's covered by treaty, so we're working in very uncertain kinds of situations, in a lot of conflict situations, and where there is a lot of uncertainty about decision-making and reaching consensus within the communities.
We work with the Prospectors and Developers Association very closely as well, and we've been deeply involved in the development of e3 Plus, on which I know Tony Andrews has shared some details with you already.
We also are participating as PDAC moves to its field testing of e3 Plus, and we've engaged two first nations in B.C. to participate in the field testing with companies operating in their area. I think that the connection to what we do domestically should not be lost. There is an awful lot that we've learned here, and there are a lot of similar kinds of situations that we've developed some expertise in managing.
Internationally, I think it's been recognized by all that the real performance challenge is being able to bridge the governance gap that has been created by globalization. But the current international human rights objectives were framed in relation to the obligations of states, not businesses.
At a practical level, there is also a lack for us of an understanding of the breadth and coherence of response. What I mean by that is that understanding who is responsible for what in any given situation on the ground is very difficult for people to do.
The way we experience success is by collaborating with government, with communities, and with non-profit organizations. I can cite several examples in British Columbia where we've done that very successfully in remote communities.
We can't do it alone. Nobody can do it alone. I feel very strongly that the way people learn how to manage these situations is not through sanctions, but by learning. It's by learning from each other, by having the responsibilities and the criteria set out for them very clearly in operational terms, and by being able to go to somebody who can provide them with some guidance.
I just want to speak briefly about what we're doing here in Canada. We have been following the work of the UN special representative very closely. In my experience in working in communities on a personal level, I am very pleased to see the scope and the comprehensiveness with which the UN special representative is approaching this work. It fits with my own experience of success and with the kind of guidance that I've provided to my members and that has been successful for them.
I also believe that here at home in Canada we've been providing a lot of support to the CSR counsellor and doing what we can to contribute to the CSR strategy, the centre for excellence, and a number of other initiatives. We have a very large group of people participating deeply in all of these consultations and discussions.
I want to speak briefly to the provisions of Bill C-300 in particular. I believe that the punitive measures that would be aimed at Canadian companies would divert significant resources away from the collaborative process that is under way now. We've made a huge investment in that. We're seeing results.
I don't want to see my members taking their time and resources away from the work we're doing now, which is helping, to something that would put them in a compliance mode. The compliance mode for them would be to do the minimum required, to not integrate that into their own corporate culture, and to not discuss with other people what their practices are. It becomes an issue of liability for them, rather than one of learning from each other.
It's very hard for me as an association staff member to get my members to speak openly about the challenges they face. They don't like making mistakes. They don't like it when they have done something wrong. They can come to me now, and we can bring opportunities to them for sharing and learning among each other; if they're looking at sanctions as the first line of response, all of that will disappear and I will have no ability to engage my members in these initiatives.
I also want to say specifically about Bill C-300 that I don't believe the IFC and voluntary principles give us enough detail to justify sanctions. They're too general. They don't tell people what they need to do operationally. I believe that sanctions should be applied after efforts to improve performance have been exhausted, not before.
The loss of the opportunity to improve is a loss for communities, host governments, and the competencies of industries. The ability to work things out with the communities is a really valuable thing for those communities as well.
I also don't believe that the bill accounts for the level of resources that would be required to implement its provisions. I have a great deal of experience with what it takes to implement these things effectively.
Thank you.