SUMMARY DISSERTATION REPORT

Environmental Management System Implementation by Multinational

Mining Corporations Operating in Developing Countries

BY: EDGAR CHILANZI MULWANDA

Dissertation Submitted to Cardiff University for the partial fulfillment for the degree of
Master of Science in Sustainability, Planning and Environmental Policy
1.0. Research aim
The research aim was to establish how multinational mining corporations in developing
countries manage the operations to prevent environmental pollution and what motivates their
actions.

1.1. Main research questions

The main aim of this research can be divided into three (3) specific research questions which
include:

a) Do multinational mining corporations operating in developing countries have

environmental management systems in place and what systems if any?
This question was used as a baseline to establish the methods of environmental protection put
in place by the multinational mining corporations. The question also gives some insights as to
whether the systems in place are adequate to ensure effective prevention and control of
pollution.

b) What are the motivating factors and barriers to environmental management

system implementation by multinational corporations operating in developing
countries?
The question helped establish if the multinational mining corporations are under any pressure
to put in place effective environmental management systems. It also evaluated the main
factors pushing for effective environmental management systems in multinational mining
corporations. The question also established the barriers to effective environmental
management system implementation in multinational mining corporations.

c) What governance mechanisms are in place for environmental management

system implementation in developing countries?
This question looked at what institutions are in place to facilitate better environmental
management practices in multinational mining corporations. It also scrutinised the laws and
regulations governing environmental management in multinational mining corporations based
in developing countries.
2.0. Methodology
This research used the explanatory approach as it sought to establish how multinational
mining corporations in developing countries manage the operations to prevent pollution and
factors which motivate them.

This research took the qualitative approach as mainly words were used in the collection and
analysis of data. It aimed at generating theory on what may not be known about
environmental management in multinational corporations operating in developing countries
following the constructionist, interpretivism and inductive theory approach (Bryman, 2012).
Research questions for the study were developed to effectively deal with the subject of
environmental management by mining multinational corporations.

Formulation of well-grounded research questions is an important step in theory development

when conducting research (Alvesson and Sandberg, 2013). Vague research questions may
lead to employment of inappropriate research strategy which may lead to missing important
issues during data collection resulting into unclear findings (Bryman, 2012).

In order to explore and gain a rich understanding of the context of the research (Saunders et
al., 2012; Eisenhardt and Graebner, 2007) using multiple sources of information (Creswell,
1998), a case study strategy was used for this study. To gain an understanding on how
multinational mining corporations manage their environments in developing countries, it was
important that one country (a case) which reflected the conditions in developing countries is
studied falling well into the representative type of case study (Bryman, 2012). There are
concerns as to how findings from one case can be generalised to other developing countries.
However, as Bryman (2012) highlights, the study did not concentrate much at generalisation
but how well theory on environmental management in mining corporations operating in
developing countries has been generated by the researcher.
2.1. Methods of Data Collection
Semi-Structured Interviews
The main method of data collection for this research was semi-structured qualitative
interviews. The primary objective of using the semi-structured interviews was to gain in-
depth understanding into how mining multinational corporations operating in developing
countries manage the environment to prevent and control pollution and not to draw
generalisations from the research.

Other methods of data collection methods included observations, document review and focus
group discussions.

Table 1: List of Respondents

Stakeholder Background Interviews Planned Interviews Conducted

1. Mining Corporations 5 4
2. Government Institutions 4 4
3. Local Authorities 5 5
4. Civil Society Organisations 2 1
5. Universities 2 1
6. *One focus group discussion was planned and it was conducted with 6 participants.

3.0. Data Processing and Analysis

Data processing and analysis are important steps in any research. In order to bring order,
structure and meaning to the data collected, the thematic analysis approach was used
(Marshall and Rossman, 1989; Bryman, 2012). All the recorded interviews were transcribed,
checked and reviewed for any errors by the researcher. Self-transcription of the recorded data
allowed the researcher to familiarise himself with the data (Fraser, 2013). Further data
familiarisation was done by reading the transcripts and studying observational notes taken
during field work in order to gain an overview of the richness, depth and diversity of the data
(Huberman and Miles, 2002.
4.0. Findings
Mining corporations were responsible for water, land and air pollution in the mining areas
which was affecting the local communities. Mining corporations have shown commitment to
environmental management by developing environmental policies for their operations.
However, what they had committed to on paper is not implemented effectively even though
they have environmental management plans/systems in place. Mining environmental systems
were not effective as they were not following different stages and components for the systems
to operate well. Components for effective EMS implementation such as disclosure and
reporting were not done.

Different factors motivate multinational mining corporations to implement environmental

management systems. It is clear that government regulation, technological innovation,
corporate social responsibility, economic benefit, pressure from parent corporations and
market conditions were among the factors found to be influencing corporate environmental
management in Zambia. However, the EMSs were not effective in most corporations and this
was attributed to inadequate knowledge on EMS among the different stakeholders, lack of
government support to corporations, inadequate resources to invest in EMSs by mining
corporations and inadequate resources for other stakeholders such as enforcement institutions
and CSOs.

Governance mechanisms in place including government laws and regulations are adequate
but lack enforcement. There is also a fund called the Environmental Protection Fund into
which all mining corporations contribute depending on their environmental liabilities. There
are two main institutions in-charge of mining environmental management which are ZEMA
and MSD. However, the institutions are too centralised and are unable to effectively monitor
the mining corporations’ environmental activities. Local Authorities which are well
positioned to monitor environmental problems are not involved in monitoring mining
environmental management. The only time they come close to mining environmental
management is during the EIA process before the start of mining activities. CSOs and local
community members are also not actively involved in mining environmental management as
they too like LAs are only formally involved during the EIA process before the start of
mining activities
5.0. Conclusions and Recommendations

5.1. Introduction
The research was conducted to provide an understanding of how multinational mining
corporations in developing countries manage their operations to prevent pollution
Conclusions have been drawn from the findings and presented according to research
questions.

5.2. Research question 1: Do mining corporations operating in developing

countries have environmental management systems in place and what
systems if any?
This research revealed that mining corporations operating in developing countries had
environmental management systems in the form of plans. The mining corporations were
legally required to develop EMPs at the beginning of operations which are then taken as a
commitment towards environmental management implementation. Statutory EMPs are used
by the mining corporations although some mining corporations have developed voluntary
systems in line with international standards ISO 14001. The use of international standards
voluntary EMS by mining corporations in Zambia is in line with the findings by Morrow and
Rondinelli (2002) that corporations in developing countries are seeking to certify their EMSs
with international standards. However, it should be noted that despite having EMPs/EMSs,
mining corporations still pollute the environment showing that their EMPs/EMSs are not
effectively implemented echoing the findings by Ntengwe and Maseka (2006) and Kitula
(2006).

There are different factors which can be attributed to the ineffective EMP/EMS
implementation in multinational mining corporations operating in developing countries like
Zambia. The mining corporations were not following all the stages of EMS as stipulated by
the ISO 14001 which included planning, implementation, evaluation and review (Lally, 1998;
Curvovic and Sroufe, 2011). Mining corporations had in place corporate environmental
structures to help manage the environment but that the responsibilities and communication
channels have to be looked at and improved in order to attain effective EMS.
All the mining corporations showed commitment towards environmental management
through having environmental policies in place. However, this was just a paper exercise as
they did not adhere to their policies. Apart from the policy which was available in all the
mining corporations, important documents for an effective EMS such as aspects registers,
objectives and targets (Fresner, 1998) were not readily available also showing poor records
keeping. Training on environmental management was not provided for all personnel involved
in mining activities leading to them not appreciating the importance of EMS resulting in
ineffective implementation. Training is important for the effectiveness of the EMS (Hilson,
2000).

I conclude that reporting and disclosure on mining environmental management was not done
effectively and adequately as mining corporations were only doing it to ZEMA and not all
stakeholders. The reports written for disclosure are mostly qualitative (Hossain et al, 2006),
even where efforts have been made to report quantitatively to ZEMA, their reports are
questioned by other stakeholders as the monitoring to counter check the findings in the report
is not done.

5.3. Research Question 2: What are the motivation factors and barriers to
environmental management system implementation by Multinational
Corporations operating in developing countries?

I can conclude here that the most important factor that motivates multinational mining
corporations in developing countries like Zambia to implement EMS is the government
environmental regulations which are in place. The government environmental regulations
mandate that all the mining corporations develop EMP for their mining operations at the start
of the operations. Apart from the development of an EMP, it is also statutory for mining
corporations to contribute to an EPF which forces them to improve their environmental
management in order to reduce their environmental liabilities so as to contribute less deposit
towards the EPF.

Apart from government environmental regulations, modern technology has helped mining
corporations to improve their environmental management. Even if parent multinational
corporations are also motivating mining corporations to implement EMS, this is not effective
as the market for the final product is not affected by the EMS.

Adoption and effective implementation of EMSs was affected by different factors which
included lack of knowledge on EMSs as most people involved in the mining industry were
still not fully aware of the EMS. Government did not give support to corporations apart from
enacting the laws and applied limited pressure to ensure adoption and effective
implementation of EMS. Limited pressure was applied by government because it lacked
adequate capacity (Hilson, 2000). For EMPs which is a statutory requirement, there is a lack
of monitoring and enforcement of the regulations which govern environmental management
in Zambia. The lack of enforcement and monitoring is also attributed to inadequate support to
responsible institutions from central government due to political interest.

Lack of funds to finance the implementation of the EMS due to economic constraints was
highlighted by mining corporations. However, the reason for economic constraints showed
the lack of prioritising environmental management by mining corporations as they were able
to fund other social and economic activities.

5.4. Research question 3: What governance mechanisms are in place for

environmental management system implementation?

The governance mechanisms put in place for environmental management implementation

include laws and regulations under the Ministry of Lands, Natural Resources and
Environmental Protection and the Ministry of Mines, Energy and Water Development. The
Environmental Management Act No. 12 of 2011 and the Mines and Mineral Development
Act No. 7 of 2008 have all the necessary provisions to ensure effective environmental
management. However, there is a need for strengthening of enforcement of the laws
provided. The introduction of the EPF which is statutory is a good governance mechanism
which is capable of making the mining corporations improve their environmental
management as long as it is effectively implemented. The EMA has a provision for Honorary
Environmental Inspectors (HEIs) who are meant to help monitor environmental activities in
the country. However, the HEI have not been used as ZEMA is still putting in place other
mechanisms to ensure its effective implementation.
The main institutions involved in mining corporation’s environmental management are
ZEMA and MSD and they are the institutions which enforce critical laws used to govern
environmental issues in the mining industries. Local authorities which are central to mining
environmental management (Azapagic, 2004) are not adequately involved in environmental
management for the mining corporations as they are just engaged during the EIA process and
at times when there are emergencies.

Civil Society Organisations involved in environmental management are considered important

in environmental management for mining corporations although like the LAs they are not
adequately involved as they just participate at the beginning of the mining project during the
EIA process.

Local community members are another stakeholder in mining environmental management.

However, there involvement in Zambia is too weak to help in effective governance of the
environment in the mining corporations.

5.5. Recommendations
In order for effective environmental management by mining corporations operating in
developing countries like Zambia, the following are the recommendations to different
stakeholders.

5.5.1. Multinational Mining Corporations

 Mining corporations should ensure that the environmental management plans/systems put
in place are effectively implemented through top management commitment in a more
voluntary manner without waiting for enforcement officers.

 Information on mining environmental management activities is not easily accessed by all

the stakeholders, it is recommended that mining corporations should ensure an improved
information flow to all stakeholders using different disclosure channels which are suitable
and easily accessed.

 CSR mostly does not include environmental management activities as no stakeholders are
engaged during identifying of activities to be considered. There is a need for the mining
corporations to include stakeholders such the LAs and community members when coming
up with activities for CRS.
5.5.2. Government
 Institutions in charge of enforcing environmental laws which are meant to help mining
corporations manage their environments better are too centralised. Officers rarely visit
the mining sites highlighting the need to decentralise and allocate officers in all the
mining districts to help monitor and improve environmental management systems in the
mining corporations.

 Government should consider revising its environmental regulations so as to include LA

officers’ participation in continuous enforcement and monitoring of environmental
aspects in Mining Corporation’s EMPs in order to help improve environmental
management by mining corporations.

 Civil Society Organisations involved in environmental management are weak due to

mainly to lack of financial capacity in and therefore I recommend that the government
introduces a policy to fund CSOs on projects related to mining environmental
management

5.5.3. Civil Society Organisations

 CSOs should take a proactive approach to ensure that they are actively involved in
environmental management in the mining industry by engaging with the local community
and mining corporations.

5.5.4. Local Community

 Local communities are not well represented on issues of environmental management due
to lack of specific structures therefore I recommend that community environmental
management committees should be formed in all mining areas so as to get involved in
environmental management. These committees should be part of the local area
development committees.

5.5.5. Local Universities

 Knowledge on EMS for the mining industry is still a problem in Zambia. I recommend
that to bridge the gap, local universities should come up with formal partnerships with
mining corporations to conduct research on EMS and also help train their staff.

 Universities should also introduce EMS programmes to be offered at diploma or degree

level so that the number of environmental practitioners in Zambia can increase.