SUSTAINABILITY

Residue storage facility and dam management

We acknowledge the severe adverse impact poor Residue Storage Facility (RSF) (previously referred to as Tailings Storage Facilities (TSF)) management can have on human lives, the natural environment and our business.



Operational status of dams and residue storage facilities

We acknowledge the severe adverse impact poor Residue Storage Facility (RSF) (previously referred to as Tailings Storage Facilities (TSF)) management can have on human lives, the natural environment and our business. To this end, Letšeng has reviewed all applicable international standards, codes and guidelines related to responsible RSF management and aligned our Residue Management System (RMS) to the Conformance Protocols on the Requirements of the Global Industry Standard on Tailings Management (GISTM) published by the International Council on Mining and Metals (ICMM). The RMS is a comprehensive framework that integrates people, resources, processes and practices related to RSF management to help the business achieve its performance objectives, manage risk and ensure safe, responsible management of its RSFs. The RMS is aligned and integrated with other relevant site-level systems, such as the site-wide environmental and social management system and systems related to water management.

Letšeng has two RSFs and one freshwater dam on site:

  1. The Patising RSF, which is currently in use for the deposition of coarse and fine tailings from the treatment plants.
  2. The Old RSF, has reached capacity and is no longer used for any tailings deposition. Plans for concurrent rehabilitation are currently being considered.
  3. The Mothusi Dam, which is the mine’s freshwater supply source.

Letšeng’s RSFs and freshwater dam were constructed using the centre line and downstream tipping method, being a safer method of construction than the “upstream” construction methods used in most recent dam failures reported in the mining industry. The RSFs and freshwater dam are managed in accordance with the adopted industry best practices and governance structures. No areas of concern have been noted at the established governance forums and the operational parameters are in line with the set targets. The condition of the RSFs and all risk mitigation measures are continuously monitored and well managed. The appointed engineer of record (EoR) and Independent Tailings Review Board (ITRB) have conducted their periodic and annual inspections of the respective facilities and have not noted any issues or concerns related to the stability and management of these facilities. There were no incidents of compromised dam or RSF integrity in 2023 or prior thereto.

We recognise that ensuring the integrity of our RSFs and freshwater storage facilities is non-negotiable and integral in exercising our responsibility to safeguard our workforce, communities and environment to ensure business continuity. We remain focused and proactive in managing our RSFs according to adopted international best practice. Retaining structures and embankments undergo stringent safety monitoring in the form of inspections and audits, which are conducted both internally and externally at regular intervals throughout the year. Stringent inspections and monitoring on a daily, weekly and monthly basis include surveying various factors such as the densities of fines deposits, water levels, beach lengths and freeboard. Annual structural stability analysis is also conducted at our RSFs and an early-warning system, together with community training and awareness programmes, are used to ensure the emergency readiness of communities that could be affected in the unlikely event of a failure. The nearest village is located 20km downstream from the mine. The findings and recommendations stemming from these investigations and audits are reported quarterly to the Boards and Sustainability subcommittees at both operational and Group level.

An external consultant was appointed to investigate the founding conditions of the RSFs, construct stratigraphic models for each of those, and conduct a stability analysis followed by a review and update of the previous dam breach analysis that was conducted in 2020. From the study results it was concluded that the stability of the RSFs at current height complies with the minimum safety requirements. Based on the in-depth stability assessment conducted on the RSFs at final height, the overall stability exceeds requirements and liquefaction risk is considered low (and largely inconsequential if it were to occur). The most credible mode of failure associated with a far-reaching zone of influence is thus linked only to the escape of impounded water.

Governance framework

Our approach

It is our responsibility to guard our workforce, communities and the environment in which we operate against any potential risks posed by our operations. RSFs, while an integral part of mining, present a significant potential hazard if not responsibly managed and continuously monitored. Focused risk management is therefore crucial at every stage of the lifecycle of our RSFs.

In response to recent tragedies, the ICMM’s GISTM was established to achieve the ultimate goal of zero harm to people and the environment. The GISTM requires operators to take responsibility and prioritise the safety of RSFs through all phases of their lifecycles, including closure and post-closure. It also requires the disclosure of relevant information to support public accountability. Gem Diamonds has committed to and adopted the GISTM standards.

We recognise that ensuring the integrity of our RSFs and freshwater storage facilities is non-negotiable and integral in exercising our responsibility to safeguard our workforce, communities and environment to ensure business continuity. We take a focused and proactive approach to managing our RSFs according to appropriate international best practice. Retaining structures and embankments undergo stringent safety monitoring in the form of inspections and audits, which are conducted both internally and externally at regular intervals throughout the year. Stringent inspections and monitoring on a daily, weekly and monthly basis include surveying various factors such as the densities of fines deposits, water levels, beach lengths and freeboard. Annual structural stability analysis is also conducted at our RSFs and an early-warning system, together with community training and awareness programmes, are used to ensure the emergency readiness of communities that could be affected in the unlikely event of a failure. The nearest village is located 20km downstream from the mine.

The findings and recommendations stemming from these investigations and audits are reported quarterly to the Boards and Sustainability subcommittees at both operational and Group level.

The Global Industry Standard on Tailings Management

The GISTM is directed at operators and applies to RSFs, both existing and to-be-built. It makes it clear that extreme consequences to people and the environment from catastrophic RSF failures are unacceptable. To this end, operators must have zero tolerance for human fatalities and strive for zero harm to people and the environment, which is directly aligned to our safety culture. The GISTM provides the specified measures to prevent failure of RSFs and to implement best practices in planning, design, construction, operation, maintenance, monitoring, closure and post-closure activities.

Our dam and RSF management, monitoring and assurance strategy

Storage facility     Electronic channels     Written communication     Direct interaction     Media

Patiseng RSF

   

Daily inspections and weekly surveys of water level, beach length and freeboard as well as overall RSF condition

   

Quarterly structural stability inspections by the appointed EoR

Annual structural stability assessment by independent external expert

   
  • Facility risk assessment
  • Inundation studies with flow modelling
  • Geotechnical characterisation
   
  • Emergency assessments and planning for wall failures
  • Communication towers in downstream villages
  • Mobile phone contact with communication custodians
  • Alarm activation from within villages or Letšeng emergency control centre
  • Business continuity planning

Old RSF

   

Daily inspections and weekly surveys of water level, beach length and freeboard as well as overall RSF condition

   

Quarterly structural stability inspections by EoR

Annual structural stability assessment by independent external expert

   
  • Facility risk assessment
  • Inundation studies with flow modelling
  • Geotechnical characterisation
   
  • Emergency assessments and planning for wall failures
  • Communication towers in downstream villages
  • Mobile phone contact with communication custodians
  • Alarm activation from within villages or Letšeng emergency control centre
  • Business continuity planning

Mothusi Dam

   

Weekly inspections

   

Annual dam safety inspections by EoR

Quarterly dam safety inspections by Letšeng, reviewed by EoR

   
  • Facility risk assessment
  • Flow modelling study
  • Resistivity surveys
   
  • Emergency assessments and planning for wall failures
  • Communication towers in downstream villages
  • Mobile phone contact with communication custodians
  • Alarm activation from within villages or Letšeng emergency control centre
  • Business continuity planning

RSF Risk and Governance Management Framework

Group Risk and Reporting Structures

   

Board

   

The Board of Directors is informed of the status of the RSFs, providing confirmation of the following:

  • All RSFs have been designed with a full understanding of the consequence of failure, site conditions and reasonably expected operating conditions.
  • All RSFs are and will be constructed and operated in accordance with defined thresholds and performance indicators, with particular reference to containment integrity and overtopping risk management, and managed in accordance with the Gem Diamonds RSF Management Standard.
  • Construction, operation, maintenance and surveillance of each RSF is proceeding in conformance to design intent.
  • Compliance and performance are verified as part of the Gem Diamonds assurance programme, both internally and externally. Non-conformances that may increase risk to the point where the design intent may not be achieved are identified, reported and addressed.
  • An emergency response plan, based on a comprehensive understanding of the consequences of failure, has been developed, implemented, maintained and tested.
  • In alignment with the requirements of the recently published GISTM, the above items are independently verified by suitably qualified professionals (an external reviewer/review board) at intervals dictated by the consequence classification of each facility.

Internal Risk and Assurance

   

Risk and Assurance

   

Risk management and assessment commensurate with the consequences of failure of each facility is carried out routinely, the results of which are reviewed and overseen by independent third-party experts.

Independent Tailings Review Board

   

Independent Technical Review Board (ITRB)

   
  • An appointed ITRB consisting of Senior Independent Technical Reviewers (SITRs) is mandated for systematic and ongoing independent reviews.
  • The ITRB provides independent technical review of the design, construction, operation, closure and management of tailings facilities. The independent reviewers are third parties who are not and have not been directly involved with the design or operation of the particular tailings facility. The expertise of the ITRB members reflects the range of issues relevant to the facility and its context and the complexity of these issues. The ITRB reports directly to the COO.

Tailings Governance Committee

   

Tailings Governance Committee

   

The Tailings Governance Committee is chaired by the COO, who reports directly to the CEO on matters related to the GISTM, communicates with the Board of Directors, and is accountable for the safety of tailings facilities and for minimising the social and environmental consequences of a potential tailings facility failure.

Engineer of Record

   

Engineer of Record (EoR)

   

The EoR is a qualified engineering firm or individual responsible for confirming that the tailings facility is designed, constructed and decommissioned with appropriate concern for integrity of the facility, and that it aligns with and meets applicable regulations, statutes, guidelines, codes and standards. Every facility has an EoR working continuously with the Responsible Tailings Facility Engineer (RTFE) and operational management to ensure construction and operational adherence to design, and that the structure is performing in line with the design intent.

Operation (RFTE and Contractor)

   

Competent person (RTFE)

   

The RTFE is an engineer appointed by Letšeng who is responsible for the tailings facilities. The RTFE must be available at all times during construction, operations and closure. The RTFE has clearly defined, delegated responsibility.



Community engagement on RSF and dam safety

Letšeng provides the community and district-level stakeholders with balanced and objective information about the state and safety of its RSFs and freshwater storage dam. This is done during quarterly public gatherings attended by community representatives from nine neighbouring villages.

Consultations are held with these stakeholders on RSFs and dam-related safety activities and project decisions that directly or indirectly affect them. Letšeng and six of the nine neighbouring villages jointly established the downstream emergency preparedness programme. The aim of this programme is to alert the community in the event of a RSF or dam incident or any other emergency that would require the communities to evacuate from the downstream villages.

We frequently conduct in-depth training of community members on how to respond during an emergency. Emergency preparedness drills with community members are held every quarter. Assembly points have been identified and clearly marked in the villages. A two-way radio system is also in place and is regularly tested. Sirens have been installed in the six villages which are centrally controlled at the mine and manned 24 hours a day by the mine’s Emergency Team.

Stakeholder engagement platforms:

  • Quarterly public gatherings with local communities.
  • Daily, weekly and monthly engagement with community leaders.
  • Biannual district-level stakeholder forums.
  • Quarterly district leadership forums.
  • Monthly district leadership meetings.
  • Joint emergency preparedness drills.

Find out more

Annual Report and Accounts 2023

We implemented several initiatives to reduce the impact of significant cost increases, to drive efficiencies and effectively manage operating costs in a highly volatile and uncertain economic environment.

Download PDF here

Sustainability Report 2023

We are held in high regard across Lesotho for the community work we do. We will continue to foster this respect and constantly refine our contributions by listening closely to the people who need our assistance, enabling us to find practical solutions for the greatest possible benefit.

Download PDF here

Our approach to Climate Change 2022

We have committed to a decarbonisation target of a 30% reduction in scope 1 and 2 emissions by 2030, against a 2021 base.

Download PDF here