RBA Conformity Schemes

Criterion: Business Integrity

Version 1.0.0 | Status: Active
UN conformity topic code:

Risk assessments and policies to prevent bribery, corruption, money laundering, anti-competitive behaviour, and misuse of data, including whistleblower mechanisms.

Full Description

MSG04 Business Integrity

Standard Section: 6.4 Category: Management Systems Scheme: Responsible Minerals Assurance Process (RMAP) Standard Version: 2.0 for Piloting (effective April 30, 2025)

Overview

Risk assessments and policies to prevent bribery, corruption, money laundering, anti-competitive behaviour, and misuse of data, including whistleblower mechanisms.

Requirements

The Facility shall:

  • 6.4.1 Carry out risk assessments of bribery, corruption, money laundering and anti-competitive behavior within the business.
  • 6.4.2 Establish commitments to prohibit any form of bribery, corruption, money laundering and anti-competitive behavior.
  • 6.4.3 Establish fraud and collusion identification and management systems.
  • 6.4.4 Establish procedures, and clear approval criteria, for giving, offering, or accepting gifts, offers of employment, contracts, and favors, and for making charitable donations and political contributions.
  • 6.4.5 Establish procedures that address misuse and security of confidential data, inclusive of measures for privacy protection. This includes both confidential and personal private data.
  • 6.4.6 Carry out a risk assessment to identify and assess risks of adverse impacts related to technological innovation, with consideration for how new technology or new applications of existing tools may impact compliance obligations, and ethical, social and environmental issues.
  • 6.4.7 Facilities utilizing AI technology shall have a policy in place that provides oversight of the AI systems in line with international guidance and applicable laws. Policy commitments shall include responsible innovation and engaging in dialogue and information sharing with local regulatory authorities and worker representatives.
  • 6.4.8 Establish an anonymous whistleblower mechanism to alert management to the risks including the risk or incidence of bribery, money laundering and anti-competitive behavior, and routinely and continuously encourage workers to report concerns around performing their duties in a manner that contravenes the organization policy or operating standards.
  • 6.4.9 For Facilities with integrated mining operations, the Facility (or organization as a whole) shall establish a public commitment to support the Extractive Industries Transparency Initiative (EITI) and publicly disclose all material payments to governments, including taxes, royalties, and all other forms of payment of benefits.

Source: RMI Facility Standard for Social, Environmental, OHS and Governance Risks, Version 2.0 for Piloting (April 2025), Section 6.4

Profiles using this criterion

Responsible Minerals Assurance Process

Conformity Alignment

Meets

Pass: Yes
Definition: "Facility has conducted bribery and corruption risk assessments, established documented prohibitions against bribery, corruption, money laundering and anti-competitive behavior, implemented an anonymous whistleblower mechanism, documented procedures for gifts, hospitality, and donations, and established data privacy and confidential data protection measures."

Partially Meets

Pass: No
Definition: "Business integrity commitments exist but are partially implemented: e.g., anti-bribery policy is in place but risk assessment has not been conducted, whistleblower mechanism exists but is not actively communicated to workers, gift procedures are informal or undocumented, or data privacy measures are incomplete."
Remediation: 180 days

Does Not Meet

Pass: No
Definition: "No anti-bribery or corruption risk assessment, no anonymous whistleblower mechanism, or no documented procedures governing gifts, hospitality, political donations, or data privacy."
Remediation: 90 days

Priority

Pass: No
Definition: "Priority findings are not raised against this criterion. Business integrity gaps are assessed under Does not Meet."
Remediation: 30 days

Not Applicable

Pass: Yes
Definition: "The EITI public disclosure requirement (6.4.9) is not applicable to facilities without integrated mining operations. All other requirements apply to all facilities."

Not Able To Assess

Pass: No
Definition: "The assessor was unable to access business integrity policies, risk assessment documentation, whistleblower records, or interview relevant management personnel."

Change Log

1.0.0 (2026-06-24)

Initial release.