Coal Operations: Sustainability Accounting Standard

EXTRACTIVES & MINERALS PROCESSING SECTOR
COAL OPERATIONS
Sustainability Accounting Standard
Sustainable Industry Classification System® (SICS®) EM-CO
Prepared by the
SASB Standards Board
December 2021
INDUSTRY STANDARD | VERSION 2021-12
© 2022 The IFRS Foundation. All Rights Reserved. sasb.org

COAL OPERATIONS
Sustainability Accounting Standard
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and leverage SASB’s industry-based approach to standards development. The ISSB encourages preparers
and investors to continue to provide full support for and to use the SASB Standards until IFRS Sustainability
Disclosure Standards replace SASB Standards.
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SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 2

Table of Contents
Introduction....................................................................................................................................................................4
Purpose of SASB Standards.........................................................................................................................................4
Overview of SASB Standards.......................................................................................................................................4
Use of the Standards...................................................................................................................................................5
Industry Description.....................................................................................................................................................5
Sustainability Disclosure Topics & Accounting Metrics...............................................................................................6

Greenhouse Gas Emissions..........................................................................................................................................9
Water Management..................................................................................................................................................13
Waste Management..................................................................................................................................................15
Biodiversity Impacts...................................................................................................................................................19
Rights of Indigenous Peoples.....................................................................................................................................23
Community Relations................................................................................................................................................26
Labor Relations..........................................................................................................................................................30
Workforce Health & Safety........................................................................................................................................32
Reserves Valuation & Capital Expenditures.................................................................................................................34
Tailings Storage Facilities Management......................................................................................................................38

INTRODUCTION
Purpose of SASB Standards

The use of the term “sustainability” in the SASB Standards refers to corporate activities that maintain or enhance the
ability of the company to create value over the long term. Sustainability accounting reflects the governance and
management of a company’s environmental and social impacts arising from production of goods and services, as well as
its governance and management of the environmental and social capitals necessary to create long-term value. The SASB
Standards also refer to sustainability as “ESG” (environmental, social, and governance), though traditional corporate
governance issues such as board composition are not included within the scope of the SASB Standards.
SASB Standards are designed to identify a minimum set of sustainability issues most likely to impact the operating
performance or financial condition of the typical company in an industry, regardless of location. SASB Standards are
designed to enable communications on corporate performance on industry-level sustainability issues in a cost-effective
and decision-useful manner using existing disclosure and reporting mechanisms.
Businesses can use the SASB Standards to better identify, manage, and communicate to investors sustainability
information that is financially material. Use of the Standards can benefit businesses by improving transparency, risk
management, and performance. SASB Standards can help investors by encouraging reporting that is comparable,
consistent, and financially material, thereby enabling investors to make better investment and voting decisions.
Overview of SASB Standards

The SASB Standards board has developed a set of 77 industry-specific sustainability accounting standards (“SASB
Standards” or “industry standards”), categorized pursuant to the SASB Sustainable Industry Classification System®
(SICS®). Each SASB Standard describes the industry that is the subject of the Standard, including any assumptions about
the predominant business model and industry segments that are included. SASB Standards include:
1. Disclosure topics – A minimum set of industry-specific disclosure topics reasonably likely to constitute material
information, and a brief description of how management or mismanagement of each topic may affect value creation.
2. Accounting metrics – A set of quantitative and/or qualitative accounting metrics intended to measure performance
on each topic.
3. Technical protocols – Each accounting metric is accompanied by a technical protocol that provides guidance on
definitions, scope, implementation, compilation, and presentation, all of which are intended to constitute suitable criteria
for third-party assurance.
4. Activity metrics – A set of metrics that quantify the scale of a company’s business and are intended for use in
conjunction with accounting metrics to normalize data and facilitate comparison.

Furthermore, the SASB Standards Application Guidance establishes guidance applicable to the use of all industry
standards and is considered part of the standards. Unless otherwise specified in the technical protocols contained in the
industry standards, the guidance in the SASB Standards Application Guidance applies to the definitions, scope,
implementation, compilation, and presentation of the metrics in the industry standards.
The SASB Conceptual Framework sets out the basic concepts, principles, definitions, and objectives that guide the
Standards Board in its approach to setting standards for sustainability accounting. The SASB Rules of Procedure is focused
on the governance processes and practices for standards setting.
Use of the Standards

SASB Standards are intended for use in communications to investors regarding sustainability issues that are likely to
impact corporate ability to create value over the long term. Use of SASB Standards is voluntary. A company determines
which Standard(s) is relevant to the company, which disclosure topics are financially material to its business, and which
associated metrics to report, taking relevant legal requirements into account1. In general, a company would use the SASB
Standard specific to its primary industry as identified in SICS® . However, companies with substantial business in multiple
SICS® industries can consider reporting on these additional SASB Standards.
It is up to a company to determine the means by which it reports SASB information to investors. One benefit of using
SASB Standards may be achieving regulatory compliance in some markets. Other investor communications using SASB
information could be sustainability reports, integrated reports, websites, or annual reports to shareholders. There is no
guarantee that SASB Standards address all financially material sustainability risks or opportunities unique to a company’s
business model.
Industry Description
The Coal Operations industry includes companies that mine coal and those that manufacture coal products. Mining
activity covers both underground and surface mining, and thermal and metallurgical coal.
1
Legal Note: SASB standards are not intended to, and indeed cannot, replace any legal or regulatory requirements that may be
applicable to a reporting entity’s operations.

SUSTAINABILITY DISCLOSURE TOPICS & ACCOUNTING METRICS
Table 1. Sustainability Disclosure Topics & Accounting Metrics
UNIT OF
TOPIC ACCOUNTING METRIC CATEGORY CODE
MEASURE
Metric tons (t)

Gross global Scope 1 emissions, percentage
Quantitative CO₂-e, EM-CO-110a.1
covered under emissions-limiting regulations
Percentage (%)
Greenhouse
Gas Emissions Discussion of long-term and short-term
strategy or plan to manage Scope 1 emissions, Discussion and
n/a EM-CO-110a.2
emissions reduction targets, and an analysis of Analysis
performance against those targets
(1) Total fresh water withdrawn, (2)

Thousand cubic
percentage recycled, (3) percentage in regions
Quantitative meters (m³), EM-CO-140a.1
with High or Extremely High Baseline Water
Percentage (%)
Water Stress
Management
Number of incidents of non-compliance
associated with water quality permits, Quantitative Number EM-CO-140a.2
standards, and regulations
Total weight of non-mineral waste generated Quantitative Metric tons (t) EM-CO-150a.2
Total weight of tailings produced Quantitative Metric tons (t) EM-CO-150a.3
Total weight of waste rock generated Quantitative Metric tons (t) EM-CO-150a.4
Total weight of hazardous waste generated Quantitative Metric tons (t) EM-CO-150a.5
Waste
Management Total weight of hazardous waste recycled Quantitative Metric tons (t) EM-CO-150a.6
Number of significant incidents associated

Quantitative Number EM-CO-150a.7
with hazardous waste management
Description of waste management policies and Discussion and

n/a EM-CO-150a.8
procedures for active and inactive operations Analysis
Description of environmental management Discussion and

n/a EM-CO-160a.1
policies and practices for active sites Analysis
Percentage of mine sites where acid rock

drainage is: (1) predicted to occur, (2) actively
Quantitative Percentage (%) EM-CO-160a.2
Biodiversity mitigated, and (3) under treatment or
Impacts remediation
Percentage of (1) proved and (2) probable

reserves in or near sites with protected
conservation status or endangered species
habitat
Percentage of (1) proved and (2) probable

reserves in or near indigenous land
Rights of
Indigenous
Discussion of engagement processes and due
Peoples Discussion and
diligence practices with respect to the n/a EM-CO-210a.2
Analysis
management of indigenous rights

UNIT OF
TOPIC ACCOUNTING METRIC CATEGORY CODE
MEASURE
Discussion of process to manage risks and

Discussion and
opportunities associated with community n/a EM-CO-210b.1
Community Analysis
rights and interests
Relations
Number and duration of non-technical delays Quantitative Number, Days EM-CO-210b.2
Percentage of active workforce covered under

collective bargaining agreements, broken Quantitative Percentage (%) EM-CO-310a.1
Labor Relations down by U.S. and foreign employees
Number and duration of strikes and lockouts2 Quantitative Number, Days EM-CO-310a.2
(1) MSHA All-Incidence rate, (2) fatality rate,

Quantitative Rate EM-CO-320a.1
and (3) near miss frequency rate (NMFR)
Workforce
Health & Safety Discussion of management of accident and
Discussion and
safety risks and long-term health and safety n/a EM-CO-320a.2
Analysis
risks
Sensitivity of coal reserve levels to future price

Million metric
projection scenarios that account for a price Quantitative EM-CO-420a.1
tons (Mt)
on carbon emissions
Reserves
Estimated carbon dioxide emissions embedded Metric tons (t)
Valuation & Quantitative EM-CO-420a.2
in proven coal reserves CO₂-e
Capital
Expenditures Discussion of how price and demand for coal
and/or climate regulation influence the capital Discussion and
n/a EM-CO-420a.3
expenditure strategy for exploration, Analysis
acquisition, and development of assets
Tailings storage facility inventory table: (1)

facility name, (2) location, (3) ownership
status, (4) operational status, (5) construction
method, (6) maximum permitted storage
capacity, (7) current amount of tailings stored, Quantitative Various EM-CO-540a.1
(8) consequence classification, (9) date of most
recent independent technical review, (10)
Tailings Storage material findings, (11) mitigation measures,
Facilities (12) site-specific EPRP
Management
Summary of tailings management systems and
governance structure used to monitor and Discussion and
n/a EM-CO-540a.2
maintain the stability of tailings storage Analysis
facilities
Approach to development of Emergency

Discussion and
Preparedness and Response Plans (EPRPs) for n/a EM-CO-540a.3
Analysis
tailings storage facilities
2 Note to EM-CO-310a.2 – Disclosure shall include the number, duration, and reason for the stoppage.

Table 2. Activity Metrics
UNIT OF
ACTIVITY METRIC CATEGORY CODE
MEASURE
Million metric
Production of thermal coal Quantitative EM-CO-000.A
tons (Mt)
Million metric
Production of metallurgical coal3 Quantitative EM-CO-000.B
tons (Mt)
3 Note to EM-CO-000.B – The scope includes pulverized coal injection.

Greenhouse Gas Emissions
Topic Summary
Coal operations are energy intensive and generate significant direct greenhouse gas (GHG) emissions, including carbon
dioxide from fuel use and methane released from coal beds during mining and post-mining activities. Regulatory efforts
to reduce GHG emissions in response to the risks posed by climate change may result in higher operating and capital
expenditures based on the magnitude of their direct emissions. Operational efficiencies can be achieved through the cost-
effective reduction of GHG emissions. Such efficiencies can mitigate the potential financial impact of increased fuel costs
from regulations that seek to limit—or put a price on—GHG emissions.
Accounting Metrics
EM-CO-110a.1. Gross global Scope 1 emissions, percentage covered under

emissions-limiting regulations
1 The entity shall disclose its gross global Scope 1 greenhouse gas (GHG) emissions to the atmosphere of the seven
GHGs covered under the Kyoto Protocol—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O),
hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3).
1.1 Emissions of all GHGs shall be consolidated and disclosed in metric tons of carbon dioxide equivalent (CO2-e),
and calculated in accordance with published 100-year time horizon global warming potential (GWP) values. To
date, the preferred source for GWP values is the Intergovernmental Panel on Climate Change (IPCC) Fifth
Assessment Report (2014).
1.2 Gross emissions are GHGs emitted into the atmosphere before accounting for offsets, credits, or other similar
mechanisms that have reduced or compensated for emissions.
2 Scope 1 emissions are defined and shall be calculated according to the methodology contained in The Greenhouse
Gas Protocol: A Corporate Accounting and Reporting Standard (GHG protocol), Revised Edition, March 2004,
published by the World Resources Institute and the World Business Council on Sustainable Development
(WRI/WBCSD).
2.1 These emissions include direct emissions of GHGs from stationary or mobile sources; these sources include but
are not limited to: equipment at mine sites, mine mouth electric generating facilities, coal seam methane
emissions, production and processing facilities, storage facilities, office buildings, and transportation (marine,
road, and rail).
2.2 Acceptable calculation methodologies include those that conform to the GHG Protocol as the base reference,
but provide additional guidance, such as industry- or region-specific guidance. Examples include, but are not
limited to:

2.2.1 GHG Reporting Guidance for the Aerospace Industry provided by International Aerospace
Environmental Group (IAEG)
2.2.2 Greenhouse Gas Inventory Guidance: Direct Emissions from Stationary Combustion Sources provided
by the U.S. Environmental Protection Agency (EPA)
2.2.3 India GHG Inventory Program
2.2.4 ISO 14064-1
2.2.5 Petroleum Industry Guidelines for reporting GHG emissions, 2nd edition, 2011, published by IPIECA
2.2.6 Protocol for the quantification of greenhouse gas emissions from waste management activities
published by Entreprises pour l’Environnement (EpE)
2.3 GHG emissions data shall be consolidated and disclosed according to the approach with which the entity
consolidates its financial reporting data, which is generally aligned with the “financial control” approach
defined by the GHG Protocol, and the approach provided by the Climate Disclosure Standards Board (CDSB)
that is described in REQ-07, “Organisational boundary,” of the CDSB Framework for reporting environmental
information, natural capital and associated business impacts (April 2018).
3 The entity shall disclose the percentage of its gross global Scope 1 GHG emissions that are covered under an
emissions-limiting regulation or program that is intended to directly limit or reduce emissions, such as cap-and-trade
schemes, carbon tax/fee systems, and other emissions control (e.g., command-and-control approach) and permit-
based mechanisms.
3.1 Examples of emissions-limiting regulations include, but are not limited to:
3.1.1 California Cap-and-Trade (California Global Warming Solutions Act)
3.1.2 European Union Emissions Trading Scheme (EU ETS)
3.1.3 Quebec Cap-and-Trade (Draft Bill 42 of 2009)
3.2 The percentage shall be calculated as the total amount of gross global Scope 1 GHG emissions (CO2-e) that
are covered under emissions-limiting regulations divided by the total amount of gross global Scope 1 GHG
emissions (CO2-e).
3.2.1 For emissions that are subject to multiple emissions-limiting regulations, the entity shall not account for
those emissions more than once.
3.3 The scope of emissions-limiting regulations excludes emissions covered under voluntary emissions-limiting
regulations (e.g., voluntary trading systems), as well as reporting-based regulations [e.g., the U.S.
Environmental Protection Agency (EPA) GHG Reporting Program].

4 The entity may discuss any change in its emissions from the previous reporting period, including whether the change
was due to emissions reductions, divestment, acquisition, mergers, changes in output, and/or changes in calculation
methodology.
5 In the case that current reporting of GHG emissions to the CDP or other entity (e.g., a national regulatory disclosure
program) differs in terms of the scope and consolidation approach used, the entity may disclose those emissions.
However, primary disclosure shall be according to the guidelines described above.
6 The entity may discuss the calculation methodology for its emissions disclosure, such as if data are from continuous
emissions monitoring systems (CEMS), engineering calculations, or mass balance calculations.
EM-CO-110a.2. Discussion of long-term and short-term strategy or plan to

manage Scope 1 emissions, emissions reduction targets, and an analysis of
performance against those targets
1 The entity shall discuss its long-term and short-term strategy or plan to manage its Scope 1 greenhouse gas (GHG)
emissions.
1.1 Scope 1 emissions are defined according to The Greenhouse Gas Protocol: A Corporate Accounting and
Reporting Standard (GHG Protocol), Revised Edition, March 2004, published by the World Resources Institute
and the World Business Council on Sustainable Development (WRI/WBCSD).
1.2 The scope of GHG emissions includes the seven GHGs covered under the Kyoto Protocol—carbon dioxide
(CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur
hexafluoride (SF6), and nitrogen trifluoride (NF3).
2 The entity shall discuss its emission reduction target(s) and analyze its performance against the target(s), including
the following, where relevant:
2.1 The scope of the emission reduction target (e.g., the percentage of total emissions to which the target is
applicable);
2.2 Whether the target is absolute- or intensity-based, and the metric denominator, if it is an intensity-based
target;
2.3 The percentage reduction against the base year, with the base year representing the first year against which
emissions are evaluated toward the achievement of the target;
2.4 The timelines for the reduction activity, including the start year, the target year, and the base year;
2.5 The mechanism(s) for achieving the target; and

2.6 Any circumstances in which the target or base year emissions have been, or may be, recalculated
retrospectively or the target or base year has been reset.
3 The entity shall discuss the activities and investments required to achieve the plans and/or targets, and any risks or
limiting factors that might affect achievement of the plans and/or targets.
4 The entity shall discuss the scope of its strategies, plans, and/or reduction targets, such as whether they pertain
differently to different business units, geographies, or emissions sources.
5 The entity shall discuss whether its strategies, plans, and/or reduction targets are related to, or associated with,
emissions-limiting and/or emissions reporting-based programs or regulations (e.g., the EU Emissions Trading Scheme,
Quebec Cap-and-Trade System, California Cap-and-Trade Program), including regional, national, international, or
sectoral programs.
6 Disclosure of strategies, plans, and/or reduction targets shall be limited to activities that were ongoing (active) or
reached completion during the reporting period.

Water Management
Topic Summary
Coal operations have an impact on both the quality and quantity of local water resources. Coal operations are water
intensive. The use of water in coal washing to remove sulfur, in cooling drilling equipment, and in transporting coal in
slurry pipelines can impact resources. The severity of these risks can vary depending on the region’s water availability and
the regulatory environment. Reducing water use and contamination could also create operational efficiencies for
companies and lower their operating costs. Wastewater treatment and discharge is often regulated by national or local
agencies. Violating limits on selenium, sulfate, and dissolved solids could affect coal operations companies through
significant penalties, compliance costs, delays in production, or higher costs related to mine closure.
Accounting Metrics
EM-CO-140a.1. (1) Total fresh water withdrawn, (2) percentage recycled, (3)
percentage in regions with High or Extremely High Baseline Water Stress
1 The entity shall disclose the amount of water, in thousands of cubic meters, that was withdrawn from freshwater
sources:
1.1 Fresh water may be defined according to the local statutes and regulations where the entity operates. Where
there is no regulatory definition, fresh water shall be considered to be water that has less than 1000 parts per
million of dissolved solids per the U.S. Geological Survey.
1.2 Water obtained from a water utility in compliance with U.S. National Primary Drinking Water Regulations can
be assumed to meet the definition of fresh water.
2 The entity shall disclose the percentage of water recycled as the volume, in thousands of cubic meters, recycled
divided by the volume of water withdrawn.
2.1 Any volume of water reused multiple times shall be counted as recycled each time it is recycled and reused.
3 The entity shall analyze all of its operations for water risks and identify activities that withdraw and consume water in
locations with High (40–80%) or Extremely High (>80%) Baseline Water Stress as classified by the World Resources
Institute’s (WRI) Water Risk Atlas tool, Aqueduct.
4 The entity shall disclose its water withdrawn in locations with High or Extremely High Baseline Water Stress as a
percentage of the total water withdrawn.
5 The entity shall disclose its water consumed in locations with High or Extremely High Baseline Water Stress as a
percentage of the total water consumed.

EM-CO-140a.2. Number of incidents of non-compliance associated with water
quality permits, standards, and regulations
1 The entity shall disclose the total number of instances of non-compliance, including violations of a technology-based
standard and exceedances of quantity and/or quality-based standards.
2 The scope of disclosure includes incidents governed by national, state, and local statutory permits and regulations,
including, but not limited to, the discharge of a hazardous substance, violation of pretreatment requirements, or
total maximum daily load (TMDL) exceedances.
2.1 Typical parameters of concern include selenium, total dissolved solids (TDS), sulfate, total suspended solids
(TSS), and pH.
3 The scope of disclosure shall only include incidents of non-compliance that resulted in a formal enforcement
action(s).
3.1 Formal enforcement actions are defined as governmental recognized actions that address a violation or
threatened violation of water quantity and/or quality laws, regulations, policies, or orders, and can result in
administrative penalty orders, administrative orders, and judicial actions, among others. For example, the U.S.
Environmental Protection Agency (EPA) provides guidance on the scope of formal enforcement actions in,
Informal and Formal Actions, Summary Guidance and Portrayal on EPA Websites.
4 Violations shall be disclosed, regardless of their measurement methodology or frequency. These include violations
for:
4.1 Continuous discharges, limitations, standards, and prohibitions that are generally expressed as maximum daily,
weekly average, and monthly averages
4.2 Non-continuous discharges and limitations that are generally expressed in terms of frequency, total mass,
maximum rate of discharge, and mass or concentration of specified pollutants

Waste Management
Topic Summary
The Coal Operations industry generates large volumes of non-mineral and mineral waste, including solid rock and clay
waste, process refuse, and liquid coal waste, which may contain toxic elements such as mercury, arsenic, or cadmium.
Waste produced during coal mining and processing operations, depending on its type, can be treated, disposed of, or
stored on- or off-site in impoundments or old mine pits. Improper disposal or storage of hazardous materials or mining
waste can present a significant long-term threat to human health and ecosystems through potential contamination of
groundwater or surface water that is used for drinking or agriculture purposes. This poses operational and regulatory
challenges for coal operations companies. Companies that reduce waste streams while implementing policies to manage
risks related to waste and that have rigorous hazardous waste disposal practices may see lower regulatory and litigation
risks, remediation liabilities, and costs.
Accounting Metrics
EM-CO-150a.2. Total weight of non-mineral waste generated

1 The entity shall disclose the total amount, in metric tons, of non-mineral waste it generated.
1.1 Non-mineral waste is defined as anything for which the entity has no further use and which is discarded,
intended to be discarded, or released into the environment.
1.2 The scope of disclosure includes non-mineral waste generated from all activities.
1.2.1 The scope of non-mineral waste includes scrap metal, reject coal, used oil, tires, batteries, and other
solid wastes.
1.3 The scope of non-mineral waste excludes overburden, waste rock, tailings, and gaseous wastes.
EM-CO-150a.3. Total weight of tailings produced

1 The entity shall disclose the total weight, in metric tons, of tailings it produced.
1.1 The definition of tailings shall be consistent with that provided in the Global Industry Standard on Tailings
Management (GISTM).
EM-CO-150a.4. Total weight of waste rock generated

1 The entity shall disclose the total amount, in metric tons, of waste rock it generated.

1.1 Waste rock is defined as mineral materials and low-grade ore with no economic interest at the time of mining.
EM-CO-150a.5. Total weight of hazardous waste generated

1 The entity shall disclose the total weight, in metric tons, of waste it generated that was hazardous.
1.1 Hazardous wastes are defined per the legal or regulatory framework(s) applicable within the jurisdiction(s)
where the waste is generated.
1.1.1 The entity may use definitions from the United Nations Environment Programme (UNEP) Basel
Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal,
1989.
EM-CO-150a.6. Total weight of hazardous waste recycled

1 The entity shall disclose the total weight, in metric tons, of hazardous waste it generated that was recycled.
1989.
1.2 Recycled materials are defined as waste materials that have been reprocessed or treated by means of
production or manufacturing process and made into a final product or a component for incorporation into a
product.
1.2.1 This definition is based on the UNEP Basel Convention on the Control of Transboundary Movements of
Hazardous Wastes and Their Disposal, 1989.
1.3 Materials incinerated, including for energy recovery, shall not be considered within the scope of recycled
waste.
1.3.1 Energy recovery is defined as the use of combustible waste as a means to generate energy through
direct incineration, with or without other waste, but with recovery of the heat.
EM-CO-150a.7. Number of significant incidents associated with hazardous waste

management
1 The entity shall disclose the total number of significant incidents associated with the handling, storage,
transportation, or disposal of hazardous waste.

1.1 The scope of disclosure includes incidents of mishandling and improper disposal of hazardous waste that are
significant or have impacts on the environment, employees, and/or surrounding communities.
1.1.1 Impacts on the on environment, employees, or surrounding communities include, but are not limited
to, surface water and ground water contamination and land contamination that required response and
remediation, caused adverse impacts on biodiversity, or caused personal injury or death to employees
or community members.
1.2 A significant incident is defined as an incident that exceeds the volume and concentration limits of local
regulatory requirements or industry-accepted codes, or is otherwise included in the entity’s financial
statements (e.g., due to resulting liabilities) or recorded by the entity as an incident required to be reported by
local jurisdictions; or is an event that is significant in the judgment of the operator, even though it did not
meet the criteria above.
1.2.1 The entity may disclose its criteria for establishing the threshold in volume and concentration for which
it considers an incident significant.
1989.
EM-CO-150a.8. Description of waste management policies and procedures for

active and inactive operations
1 The entity shall describe the policies and procedures that are set forth by its waste management strategy.
1.1 The scope of disclosure shall include policies and procedures for the entity’s active and inactive operations.
1.2 The scope of waste includes mineral and non-mineral waste.
1.2.1 Mineral waste is defined as wastes generated during the extraction and beneficiation of ores and
minerals.
1.2.2 Non-mineral waste is defined as all other waste (excluding mineral waste) for which the entity has no
further use and which is discarded, intended to be discarded, or released into the environment.
2 The entity shall describe how its policies and procedures compare with those required by local jurisdictions that apply
to the entity.

2.1 The entity shall discuss whether and how its policies and procedures exceed the requirements of local
jurisdictions.
2.2 The entity shall discuss how its policies and procedures vary by region.
3 The entity shall describe its approach to waste management during entire project life cycle.
3.1 The scope of disclosure shall include, but is not limited to, a discussion of the entity’s:
3.1.1 Approach to assessment of potential environmental impacts associated with waste streams;
3.1.2 Policies and procedures related to waste avoidance;
3.1.3 Approach to identification, assessment, and application of recycling, reuse, and repurposing as waste
management strategies;
3.1.4 Policies and procedures related to waste disposal or incineration;
3.1.5 Policies and procedures related to remediation of environmental or social impacts of incidents
associated with the mishandling of hazardous waste; and
3.1.6 Approach to decommissioning waste facilities.
4 The entity shall include a description of how waste management efforts are coordinated among business partners
(e.g., contractors and subcontractors).
5 The entity shall describe how it ensures compliance and conformance with its waste management policies and
procedures.

Biodiversity Impacts
Topic Summary
Coal operations can have a range of impacts on biodiversity. Surface mining and mountaintop removal can alter the
landscape, removing vegetation and wildlife habitats. Acid mine drainage is particularly significant: it is highly acidic
water, rich in heavy metals, formed when surface and shallow subsurface water comes into contact with coal mining
overburden, and can have harmful effects on humans, animals, and plants. Biodiversity impacts of coal operations can
affect the valuation of reserves and create operational risks. The environmental characteristics of the land where reserves
are located could increase extraction costs as a result of increasing awareness and protection of ecosystems. Companies
could also face regulatory or reputational barriers to accessing reserves in ecologically sensitive areas, such as the
designation of areas where reserves are located as protected areas. Coal operations companies face regulatory risks
related to reclamation after a mine is decommissioned, per applicable regulatory requirements to restore mined property
according to a prior, approved reclamation plan. Material costs may arise from removing or covering refuse piles, fulfilling
water treatment obligations, and dismantling infrastructure at the end of life. Furthermore, ongoing coal operations are
subject to laws protecting endangered species. Companies that have an effective environmental management plan for
different stages of the project lifecycle may minimize their compliance costs and legal liabilities, face less resistance in
developing new mines, avert delays in project completion, and avoid difficulties in obtaining permits and accessing
reserves.
Accounting Metrics
EM-CO-160a.1. Description of environmental management policies and practices

for active sites
1 The entity shall describe its environmental management plan(s) implemented at active sites, including, where
relevant:
1.1 Lifecycle stages to which the plan(s) apply, such as: pre-bid (when the entity is considering acquisition of a
site), exploration and appraisal, site development, production, and during closure, decommissioning, and
restoration
1.2 The topics addressed by the plan(s), such as: ecological and biodiversity impacts, waste generation, noise
impacts, emissions to air, discharges to water, natural resource consumption, and hazardous chemical usage
1.3 The underlying references for its plan(s), including whether they are codes, guidelines, standards, or
regulations; whether they were developed by the entity, an industry organization, a third-party organization
(e.g., a non-governmental organization), a governmental agency, or some combination of these groups

2 Where relevant, the entity shall describe specific policies and practices that apply to areas with protected
conservation status and/or areas of critical habitat, which are defined by the International Finance Corporation (IFC)
Performance Standard 6 as:
2.1 Areas with high biodiversity value, including (i) habitat of significant importance to Critically Endangered and/
or Endangered species; (ii) habitat of significant importance to endemic and/or restricted-range species; (iii)
habitat supporting globally significant concentrations of migratory species and/or congregatory species; (iv)
highly threatened and/or unique ecosystems; and/or (v) areas associated with key evolutionary processes.
3 If the management policies and practices do not apply to all of the entity’s sites or operations, it shall indicate the
percentage of sites to which they were applied.
4 The entity shall disclose the degree to which its policies and practices are aligned with the International Finance
Corporation’s (IFC) Performance Standards on Environmental and Social Sustainability, January 1, 2012, including
specifically:
4.1 Performance Standard 1 — Assessment and Management of Environmental and Social Risks and Impacts
4.2 Performance Standard 3 — Resource Efficiency and Pollution Prevention
4.3 Performance Standard 4 — Community Health, Safety, and Security
4.4 Performance Standard 6 — Biodiversity Conservation and Sustainable Management of Living Natural
Resources
5 Additional relevant references may include:
5.1 “Environmental management in oil and gas exploration and production — An overview of issue and
management approaches,” Joint E&P Forum/UNEP Technical Publication 1997.
5.2 “Towards Sustainable Decommissioning and Closure of Oil Fields and Mines: A Toolkit to Assist Government
Agencies,” DRAFT Version 2.0, November 2009, World Bank Multistakeholder Initiative.
EM-CO-160a.2. Percentage of mine sites where acid rock drainage is: (1) predicted
to occur, (2) actively mitigated, and (3) under treatment or remediation
1 The entity shall disclose the percentage of its mine sites, by annual production output from mines in metric tons,
where acid-generating seepage into surrounding surface water and/or groundwater is: (1) predicted to occur, (2)
actively mitigated, and (3) under treatment or remediation.
2 Acid rock drainage (ARD) is predicted to occur if, based on computer simulations, chemical evaluations, and/ or acid-
base accounting, it is biochemically likely that ARD could form at the mine site.

3 ARD is considered to be actively mitigated if the entity is preventing the formation of ARD through methods that
include, but are not limited to: storing or covering sulfite-bearing minerals to prevent oxidation, flood prevention and
mine sealing, mixing of acid-buffering materials with acid-producing materials, or chemical treatment of sulfide
wastes (e.g., organic chemicals designed to kill sulfide-oxidizing bacteria).
4 ARD is considered under treatment or remediation if the acidic water discharged from the mine area is captured and
undergoes a wastewater treatment process (active or passive).
5 ARD may also be referred to as acid-generating seepage or acid mine drainage.
EM-CO-160a.3. Percentage of (1) proved and (2) probable reserves in or near sites
with protected conservation status or endangered species habitat
1 The entity shall disclose the percentage of proved reserves, in metric tons, in sites with protected conservation status
or in areas of endangered species habitat.
1.1 The percentage of proved reserves shall be calculated as the amount of proved reserves located in areas either
with protected conservation status or in areas of endangered species habitat divided by the total amount of
proved reserves
2 The entity shall disclose the percentage of probable reserves, in metric tons, in sites with protected conservation
status or in areas of endangered species habitat.
2.1 The percentage of probable reserves shall be calculated as the amount of probable reserves located in areas
either with protected conservation status or in areas of endangered species habitat divided by the total
amount of probable reserves.
3 Reserves are considered to be in areas of protected conservation status if they are located within:
3.1 International Union for Conservation of Nature (IUCN) Protected Areas (categories I-VI)
3.2 Ramsar Wetlands of International Importance
3.3 UNESCO World Heritage Sites
3.4 Biosphere Reserves recognized within the framework of UNESCO’s Man and the Biosphere (MAB) Programme
3.5 Natura 2000 sites
3.6 Sites that meet the IUCN’s definition of a protected area: “A protected area is a clearly defined geographical
space, recognized, dedicated and managed, through legal or other effective means, to achieve the long term
conservation of nature with associated ecosystem services and cultural values”4
4 Dudley, N. (ed.) (2008) Guidelines for Applying Protected Areas Management Categories. IUCN: Gland, Switzerland. p.8-9.

3.6.1 These sites may be listed in the World Database of Protected Areas (WDPA) and mapped on
ProtectedPlanet
4 Reserves are considered to be in endangered species habitat if they are in or near areas where IUCN Red List of
Threatened Species classified as Critically Endangered (CR) or Endangered (EN) are extant.
4.1 A species is considered extant in an area if it is a resident present during breeding or non-breeding season, or
if it makes use of the area for passage.
4.1.1 For the purposes of disclosure, “passage” is defined as all areas of land or water that a migratory
species inhabits, stays in temporarily, or crosses or overflies at any time on its normal migration route.
5 For the purposes of this disclosure, “near” is defined as within 5 kilometers (km) of the boundary of an area of
protected conservation status or an endangered species habitat to the location of the entity’s proven and probable
reserves.
6 Reserves are defined by the U.S. Securities and Exchange Commission (SEC) Industry Guide 7, Description of Property
by Issuers Engaged or to Be Engaged in Significant Mining Operations:
6.1 Reserves, as that part of a mineral deposit which could be economically and legally extracted or produced at
the time of the reserve determination
6.2 Proved reserves, as reserves for which (a) quantity is computed from dimensions revealed in outcrops,
trenches, workings, or drill holes; grade and/or quality are computed from the results of detailed sampling,
and (b) the sites for inspection, sampling, and measurement are spaced so closely and the geographic
character is so well defined that size, shape, depth, and mineral content of reserves are well established.
6.3 Probable reserves are reserves for which quantity and grade and/or quality are computed from information
similar to that used for proven (measured) reserves, but the sites for inspection, sampling, and measurement
are farther apart or are otherwise less adequately spaced. The degree of assurance, although lower than that
for proven (measured) reserves, is high enough to assume continuity between points of observation.
7 The entity may separately identify reserves in areas with additional ecological, biodiversity, or conservation
designations such as those listed by the A-Z Guide of Areas of Biodiversity Importance prepared by the United
Nations Environment Programme’s World Conservation Monitoring Centre (UNEP-WCMC).
8 The entity may discuss reserves that are located in protected areas or endangered species habitats but present low
risk to biodiversity or ecosystem services. The entity may provide similar discussion for reserves located in areas with
no official designation of high biodiversity value but that present high biodiversity or ecosystem services risks.

Rights of Indigenous Peoples
Topic Summary
Companies in the Coal Operations industry can operate and hold assets in areas occupied by indigenous peoples.
Companies perceived as contributing to human rights violations or failing to account for indigenous peoples’ rights may
be affected due to protests, riots, or suspension of permits. They could face substantial costs related to compensation or
settlement payments, and write-downs in the value of their reserves in such areas. In the absence of country laws to
address such cases, several international instruments have emerged to provide guidelines for companies. These
instruments include obtaining the free, prior, and informed consent of indigenous peoples for decisions that affect them.
With greater awareness, several countries are also beginning to implement specific laws protecting indigenous peoples’
rights, creating increasing regulatory risk for companies. Furthermore, indigenous peoples are often vulnerable sections of
the population, with limited capacity to defend their unique rights and interests.
Accounting Metrics
EM-CO-210a.1. Percentage of (1) proved and (2) probable reserves in or near

indigenous land
1 The entity shall disclose the percentage of proved reserves that are located in or near areas that are considered to be
indigenous peoples’ land.
1.1 The percentage of proved reserves shall be calculated as the amount of proved reserves located in or near
indigenous land divided by the total amount of proved reserves.
2 The entity shall disclose the percentage of probable reserves that are located in or near areas that are considered to
be indigenous peoples’ land.
2.1 The percentage of probable reserves shall be calculated as the amount of probable reserves located in or near
indigenous land divided by the total amount of probable reserves.
3 Indigenous lands are considered those occupied by people who self-identify as indigenous per Article 33 of the
United Nations Declaration on the Rights of Indigenous Peoples and the International Labour Organization
Convention No. 169, and likely have one or more of the following characteristics based on the working definition of
“Indigenous Peoples” adopted by the United Nations:
3.1 Historical continuity with pre-colonial and/or pre-settler societies
3.2 Strong link to territories and surrounding natural resources
3.3 Distinct social, economic, or political systems

3.4 Distinct language, culture, and beliefs
3.5 Form non-dominant groups of society
3.6 Resolve to maintain and reproduce ancestral environments and systems as distinctive peoples and communities
4 For the purposes of this disclosure, “near” is defined as within 5 kilometers of the recognized boundary of an area
considered to be indigenous land to the location of the entity’s proven and probable reserves.
5 Reserves shall be calculated in metric tons and are defined by the U.S. Securities and Exchange Commission (SEC)
Industry Guide 7, Description of Property by Issuers Engaged or to Be Engaged in Significant Mining Operations:
5.1 Reserves, as that part of a mineral deposit that could be economically and legally extracted or produced at the
time of the reserve determination
5.2 Proved reserves, as reserves for which (a) quantity is computed from dimensions revealed in outcrops,
trenches, workings, or drill holes; grade and/or quality are computed from the results of detailed sampling and
(b) the sites for inspection, sampling, and measurement are spaced so closely and the geographic character is
so well defined that size, shape, depth, and mineral content of reserves are well established
5.3 Probable reserves are reserves for which quantity and grade and/or quality are computed from information
EM-CO-210a.2. Discussion of engagement processes and due diligence practices

with respect to the management of indigenous rights
1 The entity shall describe its due diligence practices and procedures with respect to indigenous rights of communities
in which it operates or intends to operate, which include, but are not limited to:
1.1 Upholding ILO Convention No. 169
1.2 Use of free, prior, and informed consent (or consultation) processes
1.3 The establishment of project grievance mechanisms
1.4 The establishment of formal community agreements
2 The discussion shall include due diligence processes employed during all stages of project development (i.e., prior,
during, and post).

3 The discussion may include governance mechanisms the company puts in place to ensure that its policies and
practices are adhered to throughout all levels of the organization.
4 The discussion shall include how practices apply to business partners, such as contractors, sub-contractors, suppliers,
and joint venture partners.
4.1 Where practices do not apply to business partners, the entity may discuss factors that prevent the application
of such practices.

Community Relations
Topic Summary
Coal operations take place over a number of years and can have a wide range of community impacts. Community rights
and interests may be affected by the environmental and social impacts of operations, air emissions, waste generation,
wastewater discharges, and decommissioning activities. Coal operations companies often need support from local
communities to be able to obtain permits and leases and conduct their activities without disruptions. The expected value
of reserves could be affected if the community interferes or lobbies its government to interfere with the rights of a coal
company in relation to those reserves. In addition to community concerns about the direct impacts of projects, the
presence of coal mining activities may give rise to associated socioeconomic concerns related to education, health, and
livelihoods. Coal companies that are perceived as engaging in rent-seeking and exploiting community resources without
providing any socioeconomic benefits in return may be exposed to the risk of resource nationalism actions by host
governments and communities that restrict their activities or impose additional costs. Companies in the extractives
industries can adopt various community engagement strategies in their global operations to manage risks and
opportunities associated with community rights and interests, such as integrating community engagement into each
phase of the project cycle. Companies that adopt a “shared value” approach may be able to provide key socioeconomic
benefits to communities while maintaining profitable operations.
Accounting Metrics
EM-CO-210b.1. Discussion of process to manage risks and opportunities

associated with community rights and interests
1 The entity shall discuss its processes, procedures, and practices to manage risks and opportunities associated with the
rights and interests of communities in areas where it conducts business, where community rights and interests
include:
1.1 Economic rights and interests, including, but not limited to, employment, fair wages, payment transparency,
and respect of infrastructure and agricultural land
1.2 Environmental rights and interests, including, but not limited to, clean local air and water, as well as safe
discharge and disposal of waste
1.3 Social rights and interests, including, but not limited to, adequate health care, education, and housing
1.4 Cultural rights and interests, including, but not limited to, protection of places of cultural significance (e.g.,
sacred sites or burial sites)
2 The entity shall disclose the following, as relevant:

2.1 Lifecycle stages to which its practices apply, such as: pre-bid (when the entity is considering acquisition of a
site), exploration and appraisal, site development, coal production, and during closure, decommissioning, and
restoration
2.2 The community rights and interests (enumerated above) specifically addressed by the entity's practices
2.3 The underlying references for its procedures, including whether they are codes, guidelines, standards, or
regulations and whether they were developed by the entity, an industry organization, a third-party
organization (e.g., a non-governmental organization), a governmental agency, or some combination of these
groups
3 Risks and opportunities include, but are not limited to: non-technical delays, availability and development of local
content, availability and access to adequate infrastructure, community actions related to resource nationalism, and
challenges associated with resettlement and access to land.
4 The entity shall disclose the degree to which its policies and practices are aligned with the International Finance
Corporation’s (IFC) Performance Standards on Environmental and Social Sustainability, January 1, 2012, including
specifically:
4.1 Performance Standard 4 — Community Health, Safety, and Security
4.2 Performance Standard 5 — Land Acquisition and Involuntary Resettlement
4.3 Performance Standard 8 — Cultural Heritage
5 The discussion shall include how practices apply to business partners such as contractors, sub-contractors, suppliers,
and joint venture partners.
6 The entity may describe its efforts to eliminate or mitigate community risks and/or address community concerns,
including, but not limited to:
6.1 The use of a social impact assessment (SIA) that evaluates, manages, and mitigates risks
6.2 Efforts to engage with stakeholders, build consensus, and collaborate with communities
6.3 “Shared” or “blended” value projects that provide quantifiable benefits to the community and the entity
7 The entity may quantify its community risks by calculating the aggregate estimated value at risk to its capital
expenditure projects as the difference in value between a project free from country, regional, and/or community risks
(hereafter, country risk) and the value of a project adjusted for these risks.
7.1 This calculation may be conducted using an appropriate valuation model; variations of the Capital Asset
Pricing Model (CAPM) are commonly used to assess country risk.

7.1.1 Value at risk can be calculated by applying an additional discount rate premium when calculating the
net present value of a project using discounted cash flow (DCF) analysis.
7.1.2 Value at risk can be expressed as a reduction in the expected cash flows of a project due to country risk
when calculating the net present value of a project using DCF.
7.1.3 If a project is insured for country risks, the value at risk can be expressed as a reduction in the cash
flows of a project due to the cost of insurance when calculating the net present value of a project
using DCF analysis.
7.2 Country, regional, and/or community risks include, but are not limited to: corruption, business legal structure,
political stability, regulation, resource nationalism, ethnic conflict, stability of the local market, labor force
(skills) availability, resettlement and access to land, quality of access to infrastructure (e.g., ports, roads,
shipping channels), and/or general license to operate.
7.2.1 These risks are likely to manifest differently at the country (national), regional (state), community (local)
levels, and project levels.
7.2.2 This risk differs from sovereign risk, which is defined as the potential for a central bank or government-
backed entity to willingly or unwillingly default on debt obligations, or significantly alter key economic
variables such as currency exchange rates, import ratios, and money supply.
7.3 The entity may identify and describe country risks specific to its projects and unique operating context.
7.3.1 This may include the identification of country, regional, and community risks and/or the discussion of
specific projects.
7.3.2 This may include discussion of how the entity has mitigated these risks (e.g., through community
engagement partnerships, and blended value projects); the entity shall quantify this reduction in risk
according to the methods described above.
7.3.3 Discussion should be in addition to broad country risk classification (e.g., OECD Prevailing Country Risk
classification, Standard & Poor’s Country Risk ratings, and the World Economic Forum Global
Competitiveness Index).
7.4 The entity may describe the model or approach used to value capital expenditure projects such as adjusted
discount rate, expected cash flow, or other methods.
EM-CO-210b.2. Number and duration of non-technical delays

1 The entity shall disclose the total number and aggregate length, in days, of site shutdowns or project delays due to
non-technical factors.

2 The scope includes shutdowns and project delays including, but not limited to, those resulting from pending
regulatory permits or other political delays related to community concerns, community or stakeholder resistance or
protest, and armed conflict.
3 The scope of disclosure excludes delays due to strikes and lockouts that are disclosed according to EM-CO-310a.2.
4 The entity may discuss specific delays including associated costs, root cause and corrective actions for resolved delay,
and status of ongoing delays.

Labor Relations
Topic Summary
Coal mining companies face inherent tension between the need to lower the cost of labor to remain price- competitive
and the need to manage human resources to ensure long-term performance. Working conditions related to coal
operations are usually physically demanding and hazardous. Labor unions play a key role in representing workers’ interests
and managing collective bargaining for better wages and working conditions. This makes the management of labor
relations critical, as conflict with workers can result in labor strikes and other disruptions that can delay or stop
production, leading to significant lost revenue and reputational damage. Continued labor stresses can impact the long-
term profitability of the entity. At the same time, positive outcomes of effective labor engagement can include enhanced
work practices, labor utilization, as well as the reduction in safety incidents, accidents, or fatalities.
Accounting Metrics
EM-CO-310a.1. Percentage of active workforce covered under collective

bargaining agreements, broken down by U.S. and foreign employees
1 The entity shall disclose the percentage of U.S. employees and the percentage of foreign employees in the active
workforce that are covered under collective bargaining agreements during any part of the reporting period.
1.1 Active workforce is defined as the maximum number of unique employees employed at any time during the
reporting period.
1.2 Collective bargaining agreements are defined as a mechanism or tool of negotiation by which a union has a
collective interest in negotiations to the benefit of several employees.
1.3 U.S. employees are defined as employees that do not need a visa to work in the U.S.
1.4 Foreign employees are defined as employees that do need a visa to work in the U.S.
EM-CO-310a.2. Number and duration of strikes and lockouts

1 The entity shall disclose the number of work stoppages and total duration, in worker days idle, of work stoppages
involving 1,000 or more workers lasting one full shift or longer.
1.1 Worker days idle is calculated as the product of days idle and number of workers involved.
2 The scope of disclosure includes work stoppage due to disputes between labor and management, including strikes
and lockouts.

3 The scope of disclosure excludes work stoppages due to other non-technical reasons that are disclosed according to
EM-CO-210a.2.
Note to EM-CO-310a.2
1 The entity shall describe the reason for each work stoppage (as stated by labor), the impact on production, and any
corrective actions taken as a result.

Workforce Health & Safety
Topic Summary
Safety is critical to coal mining operations due to the often hazardous working conditions. Fatalities or injuries can result
from a number of hazards associated with the industry, including accidents, cave-ins, explosions, and flooding. Due to
these hazards, the industry is characterized by higher-than-average fatality and injury rates. Coal miners are also
susceptible to long-term health risks such as chronic lung disease, commonly known as “black lung” disease, as well as
mental health problems. Specific federal health and safety laws protect coal mining workers and make provisions for
compensation for black lung disease. These can impose additional costs on companies or lead to regulatory penalties.
Changes in legislation can result in additional liabilities. A company’s ability to protect employee health and safety, and to
create a culture of safety and well-being among employees at all levels, can help prevent accidents, mitigate costs and
operational downtime, and enhance workforce productivity.
Accounting Metrics
EM-CO-320a.1. (1) MSHA All-Incidence rate, (2) fatality rate, and (3) near miss
frequency rate (NMFR)
1 The entity shall disclose its U.S. Mine Safety and Health Administration (MSHA) All-Incidence rate and fatality rate.
1.1 For U.S.-based workforces, the entity shall disclose its All Incidence Rate (AIR) and fatality rate, as calculated
and reported through the Mine Safety and Health Administration’s (MSHA) Form 7000-1 (as required under
U.S. 30 CFR, Part 50), where incidents include:
1.1.1 Fatalities, or work-related injuries resulting in death to employees on active mine property
1.1.2 Nonfatal, Days Lost (NFDL) cases, or occupational injuries that result in loss of one or more days from
the entity’s scheduled work, or days of limited or restricted activity while at work
1.1.3 No Days Lost (NDL) cases, or occurrences requiring only medical treatment (beyond first aid); that is,
nonfatal-injury occurrences resulting only in loss of consciousness or medical treatment other than first
aid
1.2 For non-U.S.-based workforces, the entity shall calculate its AIR and fatality rate according to the MSHA
instructions and definitions.
2 The entity shall disclose its near miss frequency rate (NMFR) for work-related near misses.
2.1 A near miss is defined as an unplanned incident in which no property or environmental damage or personal
injury occurred, but where damage or personal injury easily could have occurred but for a slight circumstantial
shift.

2.2 The U.S. National Safety Council (NSC) provides guidance on implementing near miss reporting, including in,
“Near Miss Reporting Systems.”
2.3 The entity may disclose its process for classifying, identifying, and reporting near misses.
3 Rates shall be calculated as: (statistic count × 200,000) / hours worked
3.1 The U.S. Bureau of Labor Statistics (BLS) provides additional guidance for the calculation of rates in, “How to
Compute a Firm’s Incidence Rate for Safety Management” and “Incidence Rate Calculator and Comparison
Tool.”
4 The scope of disclosure includes all employees regardless of employee location and type of employment, such as full-
time, part-time, direct, contract, executive, labor, salary, hourly, and seasonal employees.
EM-CO-320a.2. Discussion of management of accident and safety risks and long-

term health and safety risks
1 The entity shall discuss its management of accident and safety risks.
1.1 The scope of discussion includes how the entity manages safety and emergency preparedness throughout its
value chain, such as through training, joint management by the workforce and leadership, rules and guidelines
(and their enforcement), and use of technology.
1.2 The scope of discussion includes how emergency preparedness is coordinated amongst business partners (e.g.,
contractors and sub-contractors).
1.3 The scope of discussion may focus broadly on safety and emergency management systems, but shall
specifically address the systems to avoid and manage emergencies, accidents, and incidents that could have
catastrophic human health, local community, and environmental impacts.
2 The entity shall discuss how it manages long-term health and safety risks associated with coal mining (e.g., coal
worker’s pneumoconiosis) such as through training, rules and guidelines (and their enforcement), use of personal
protective equipment, and use of technology.
3 The entity may discuss implementation of relevant management systems such as CORESafety (developed by the
National Mining Association), including progress towards tracking safety and health (S&H) metrics, management
system (MS) metrics, and obtaining third-party verification.

Reserves Valuation & Capital Expenditures
Topic Summary
Estimates suggest that coal companies may be unable to extract a significant proportion of their coal reserves if
greenhouse gas (GHG) emissions are to be controlled to limit global temperature increases to two degrees Celsius per the
Paris Agreement. Stewardship of capital resources while taking into account medium- to long-term trends, particularly
related to climate change mitigation actions, is critical in order to prevent asset impairment and maintain profitability and
creditworthiness. Globally, regulations and policies are and may continue to be put into place to limit GHG emissions from
coal-fired power plants—the customers of coal companies—thus lowering the demand for, and subsequently the prices
of, coal. Coal demand is also being affected by regulations governing other harmful air emissions that apply to coal-fired
power plants. An expansion of GHG-mitigation regulations may increase the magnitude of potential financial impacts in
the medium to long term. Along with improved competitiveness of alternative energy technologies, this poses a long-
term risk for the reserves and capital expenditures of coal operations companies.
Accounting Metrics
EM-CO-420a.1. Sensitivity of coal reserve levels to future price projection

scenarios that account for a price on carbon emissions
1 The entity shall perform a sensitivity analysis of its reserves to determine how several future scenarios may affect its
determination of whether the reserves are proven or probable.
2 The entity shall analyze the sensitivity of its current proven and probable reserves using the price trajectories
published by the International Energy Agency (IEA) in its World Energy Outlook (WEO) publication, including:
2.1 Current Policies Scenario, which assumes no changes in policies from the mid-point of the year of publication
of the WEO
2.2 New Policies Scenario, which assumes that broad policy commitments and plans that have been announced by
countries—including national pledges to reduce greenhouse gas emissions and plans to phase out fossil-
energy subsidies—occur, even if the measures to implement these commitments have yet to be identified or
announced. This broadly serves as the IEA baseline scenario.
2.3 Sustainable Development Scenario, which assumes an energy pathway occurs that is consistent with the goal
of limiting the global increase in temperature to 2°C by limiting concentration of greenhouse gases in the
atmosphere to around 450 parts per million of CO2-e
3 The entity shall consider the WEO scenarios as a normative reference, thus any updates to the WEO made year-on-
year shall be considered updates to this guidance.

4 Reserves are defined by U.S. Securities and Exchange Commission (SEC) Industry Guide 7, Description of Property by
Issuers Engaged or to Be Engaged in Significant Mining Operations:
4.1 Reserves, as that part of a mineral deposit that could be economically and legally extracted or produced at the
time of the reserve determination
4.2 Proven reserves, as reserves for which (a) quantity is computed from dimensions revealed in outcrops,
trenches, workings, or drill holes; grade and/or quality are computed from the results of detailed sampling and
(b) the sites for inspection, sampling, and measurement are spaced so closely and the geographic character is
so well defined that size, shape, depth, and mineral content of reserves are well established
4.3 Probable reserves, as reserves for which quantity and grade and/or quality are computed from information
5 The entity shall follow guidance published by the Securities and Exchange Commission (SEC) in its Oil and Gas
Reporting Modernization (Section §229.1202 (Item 1202) Disclosure of Reserves) for conducting a reserves sensitivity
analysis.
6 The entity may summarize its findings in the following table format:
Table 1. Sensitivity of Reserves to Prices By Principal Product Type and Price

Scenario
PRICE CASE PROVEN RESERVES PROBABLE RESERVES
Coal Product A Coal Product A

(Scenario)
(tons) (measure) (tons) (measure)
Current Policies Scenario (base)
New Policies Scenario
Sustainable Development
Scenario
7 The entity may disclose the sensitivity of its reserve levels in other price and demand scenarios in addition to those
described above, particularly if these scenarios differ depending on the type of coal reserves, regulatory environment
in the countries or regions where mining occurs, end-use of the entity's products, or other factors.
8 For additional sensitivity analyses, the entity should consider disclosing the following, per the Task Force on Climate-
Related Financial Disclosures (TCFD) Recommendations Report Figure 8 as well as the Implementing the
Recommendations of the TCFD Report, Section E:

8.1 The alternative scenarios used, including other 2ºC or lower scenarios
8.2 Critical input parameters, assumptions, and analytical choices for the climate-related scenarios used,
particularly as they relate to key areas such as policy assumptions, energy deployment pathways, technology
pathways, and related timing assumptions
8.3 Time frames used for scenarios, including short-, medium-, and long-term milestones (e.g., how organizations
consider timing of potential future implications under the scenarios used)
EM-CO-420a.2. Estimated carbon dioxide emissions embedded in proven coal

reserves
1 The entity shall calculate and disclose an estimate of the carbon dioxide emissions embedded in its proven coal
reserves.
1.1 Nota bene — this estimate applies a factor for potential CO2 only and does not include an estimate for all
potential greenhouse gas emissions, as these are dependent on downstream use (e.g., utility electricity
generation, industrial heating and electricity generation, cement production, or steel production).
2 Estimated potential carbon dioxide emissions from proven coal reserves shall be calculated according to the following
formula, derived from Meinshausen et al:
2.1 E = R × V × C, where:
2.1.1 E are the potential emissions in kilograms of carbon dioxide (kg CO2);
2.1.2 R are the proven reserves in gigagrams (Gg);
2.1.3 V is the net calorific value in terajoules per gigagram (TJ/Gg); and
2.1.4 C is the effective carbon dioxide emission factor in kilograms CO2 per terajoule (kg/TJ).
3 In the absence of data specific to the entity’s coal reserves, carbon content shall be calculated using default data for
each major type of coal resource published by the Intergovernmental Panel on Climate Change (IPCC) in its 2006
IPCC Guidelines for National Greenhouse Gas Inventories.
3.1 The entity shall use default carbon content values per unit of energy that is listed in IPCC Table 1.3 Default
Values of Carbon Content, Volume 2: Energy, Chapter 1.
3.2 The entity shall use calorific values per weight of coal resource contained in IPCC Table 1.2 Default Net
Calorific Values (NCVs) and Lower and Upper Limit of the 95% Confidence Intervals, Volume 2: Energy,
Chapter 1.

4 The entity shall use engineering estimates to determine the weight of its coal reserves in gigagrams.
5 For other assumptions required to estimate the carbon content of coal reserves, the entity shall rely on guidance from
the IPCC, Greenhouse Gas Protocol, U.S. Energy Information Agency (EIA), or the International Energy Agency (IEA).
EM-CO-420a.3. Discussion of how price and demand for coal and/or climate
regulation influence the capital expenditure strategy for exploration, acquisition,
and development of assets
1 The entity shall discuss how projections for price and demand for coal and the path of air quality and climate
regulation influence the entity’s capital expenditure (CAPEX) strategy.
1.1 This discussion should include the entity’s projections and assumptions about future coal prices and the
likelihood that certain price and demand scenarios occur.
2 The entity shall discuss the implications of price and demand scenario planning (i.e., EM-CO-420a.1) and how they
may affect decisions to explore, acquire, and develop new reserves.
3 The entity may discuss factors that materially influence its CAPEX decision making, including, but not limited to:
3.1 How the scope of air quality and climate change regulation—such as which countries, regions, and/or
industries are likely to be impacted—may influence where the entity focuses its exploration and development
3.2 Its view of the alignment between the time horizon during which price and demand for coal may be affected
by climate regulation and time horizons for returns on capital expenditures on reserves
3.3 How the structure of climate regulation—i.e., a carbon tax versus cap-and-trade—may differently affect price
and demand, and thus the entity's capital expenditure decision making
4 The entity may discuss how these trends affect decision-making in the context of different types of reserve
expenditures, including development of assets, acquisition of properties with proven reserves, acquisition of
properties with unproven resources, and exploration activities.

Tailings Storage Facilities Management
Topic Summary
Coal waste impoundments or fine coal refuse ponds, also called tailings storage facilities (TSFs), can leak and contaminate
water supplies when mismanaged, leading to potential adverse impacts to the environment or human health. These
impacts may carry financial implications such as regulatory penalties, compensation payments, and remediation or
compliance obligations. Companies’ ability to lower the number and size of fine coal refuse ponds and ensure the
structural integrity of impoundments can help minimize such impacts. Even though the type of materials stored in coal
refuse impoundments are characterized with lower flowability than those in the Metals & Mining industry, a catastrophic
failure of such facilities (e.g., a dam failure) can still release significant volumes of waste and materials that are potentially
harmful to the environment, leading to high-consequence impacts on ecosystems, human livelihood, local economies,
and communities. Such catastrophic incidents may result in significant financial losses for companies and may erode their
social license to operate. Robust processes and approaches to tailings facilities design, management, operation and
closure, as well as appropriate management of associated risks, can help prevent such incidents from occurring.
Companies that adopt robust practices to maintain the safety of TSFs may do so through assigning accountability for
tailings management at the highest levels of the company, conducting frequent internal and external independent
technical reviews of TSFs, and ensuring that mitigation measures are implemented in a timely manner in case of a safety
concern. Additionally, a strong safety culture and well-established emergency preparedness and response plans can
mitigate the impacts and financial implications of such events should they occur. Company obligations related to long-
term remediation and compensation for damages may result in additional financial impacts in case of a failure. A
company's ability to meet such obligations after an incident occurs is an additional component of emergency
preparedness.
Accounting Metrics
EM-CO-540a.1. Tailings storage facility inventory table: (1) facility name, (2)
location, (3) ownership status, (4) operational status, (5) construction method, (6)
maximum permitted storage capacity, (7) current amount of tailings stored, (8)
consequence classification, (9) date of most recent independent technical review,
(10) material findings, (11) mitigation measures, (12) site-specific EPRP
1 The entity shall disclose an inventory of its tailings storage facilities.
1.1 The definition of tailings facilities shall be consistent with that provided in the Global Industry Standard on
Tailings Management (GISTM) .
2 For each tailings facility, the entity shall disclose (a) the facility name, (b) its location, (c) ownership status, (d)
operational status, (e) construction method, (f) maximum permitted storage capacity, (g) current amount of tailings
stored, (h) consequence classification, (i) date of the most recent independent technical review, (j) material findings,
(k) mitigation measures, and (l) site-specific emergency preparedness and response plan (EPRP).

2.1 The entity shall provide the name or other identifier used by the entity for the facility.
2.2 Location shall include country.
2.3 Ownership status shall indicate whether the entity is the operator of the facility.
2.3.1 The definition of an operator shall be consistent with that provided in the GISTM.
2.4 The entity shall disclose the operational status of its facilities (e.g., active, inactive—under maintenance,
closed, etc.).
2.5 The entity shall disclose the construction method of the facility.
2.5.1 The entity shall disclose the construction method as "downstream", "upstream", or "centreline",
consistent with the definitions provided by the International Council on Mining and Metals (ICMM).
2.5.2 If the construction method does not match any of these definitions, the entity shall disclose "other"
and provide a brief description.
2.6 The entity shall disclose the maximum permitted storage capacity of the facility, in metric tons.
2.7 The entity shall disclose the amount of tailings stored in the facility as of the end of the reporting period, in
metric tons.
2.8 The entity shall disclose the consequence classification of the facility in accordance with Requirement 4.1 of
the GISTM.
2.9 The entity shall disclose the date of the most recent independent technical review of the facility conducted in
accordance with Requirement 10.6 of the GISTM.
2.9.1 A review is considered independent when conducted by third parties who are not and have not been
directly involved with the design or operation of the facility.
2.10 The entity shall disclose whether the most recent independent technical review resulted in material findings
related to safety of the facility.
2.10.1 The definition of material findings shall be consistent with that provided in the GISTM, where the
criteria for what is material is to be defined by the entity, subject to the provisions of local regulations,
and evaluated as part of any audit or external assessment that may be conducted on implementation.
2.10.2 The entity shall state either “Yes” or “No.”
2.10.3 For facilities where the entity has responded "Yes", the entity may provide a summary of the material
findings in addition to the inventory table.

2.10.4 For facilities where an independent technical review was not conducted, the entity shall state “N/A.”
2.11 If the entity has disclosed "Yes" regarding material findings, the entity shall disclose whether mitigation
measures have been implemented to reduce risk to a level as low as reasonably practicable (ALARP).
2.11.1 The definition of ALARP shall be consistent that provided in the GISTM.
2.11.3 For facilities where the entity has responded "Yes", the entity may provide a summary of the relevant
mitigation measures in addition to the inventory table.
2.12 The entity shall disclose whether a site-specific EPRP is in place in accordance with Requirements 13.1 and
13.2 of the GISTM.
2.12.1 The definition of EPRP shall be consistent with that provided in the GISTM.
3 The entity should disclose this inventory in the following table format:
(i) Date
(f)
(g) of most
Maximu (h) (k)
(c) (d) (e) Current recent
(a) (b) m Conseq (j) Mitigati (l) Site-
Owners Operati Constru amount indepen
Facility Locatio permitt uence Material on specific
hip onal ction of dent
name n ed classific findings measur EPRP
status status method tailings technic
storage ation es
stored al
capacity
review
EM-CO-540a.2. Summary of tailings management systems and governance

structure used to monitor and maintain the stability of tailings storage facilities
1 The entity shall provide a summary of the tailings management systems used to monitor and maintain the structural
integrity of tailings facilities and to minimize the risk of a catastrophic failure.
1.1 The scope of disclosure shall include a summary of the policies and procedures for the entity’s active and
inactive tailings facilities for all phases of their life cycle, including closure and post-closure.
1.2 The definitions of tailings facilities and tailings management systems shall be consistent with those provided
in the Global Industry Standard on Tailings Management (GISTM).
2 The disclosure shall include concepts outlined in Principles 7–11 of the GISTM and include, but not be limited to:

2.1 A summary of the performance monitoring program for tailings facilities and their appurtenant structures;
2.2 A summary of the engineering monitoring systems that verify design assumptions and monitor potential
failure modes;
2.3 The frequency of risk assessments consistent with Requirement 10.1 of the GISTM;
2.4 Frequency of Engineer of Record or senior independent technical reviewer construction and performance
reviews;
2.4.1 The definition of Engineer of Record shall be consistent with that provided in the GISTM.
2.5 A summary of the governance framework that outlines the accountability from management from the site
level through to executive leadership and the board of directors; and
2.6 Frequency of reviews to confirm that adequate financial capacity (including insurance, to the extent
commercially reasonable) is available for planned closure, early closure, reclamation, and post-closure of
tailings facilities and their appurtenant structures.
EM-CO-540a.3. Approach to development of Emergency Preparedness and

Response Plans (EPRPs) for tailings storage facilities
1 The entity shall disclose its approach to the development of Emergency Preparedness and Response Plans (EPRPs).
1.1 The definition of EPRP shall be consistent with that provided in the Global Industry Standard on Tailings
Management (GISTM).
1.2 The scope of disclosure shall include a summary of plans, procedures, and policies for the entity’s active and
inactive tailings storage facilities for all phases of the life cycle, including closure and post-closure.
1.2.1 The definition of tailings facility shall be consistent with that provided in the GISTM.
2 The entity shall disclose its approach to engagement concerning EPRPs at its facilities, including the preparedness of
local stakeholders.
2.1 Disclosure shall include, but not be limited to:
2.1.1 The entity’s approach to engaging with employees, contractors, public sector agencies, first
responders, and local authorities and institutions in accordance with Requirements 13.1 and 13.2 of
the GISTM; and
2.1.2 The entity’s frequency of emergency response plan tests and evacuation exercises to minimize
consequences of a potential failure.

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EXTRACTIVES & MINERALS PROCESSING SECTOR

Sustainable Industry Classification System® (SICS®) EM-CO

INDUSTRY STANDARD | VERSION 2021-12

© 2022 The IFRS Foundation. All Rights Reserved. sasb.org

Historical Information About the SASB Foundation

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 2

Sustainability Disclosure Topics & Accounting Metrics...............................................................................................6

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 3

Purpose of SASB Standards

Overview of SASB Standards

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 4

Use of the Standards

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 5

Table 1. Sustainability Disclosure Topics & Accounting Metrics

Metric tons (t)

(1) Total fresh water withdrawn, (2)

Total weight of tailings produced Quantitative Metric tons (t) EM-CO-150a.3

Number of significant incidents associated

Description of waste management policies and Discussion and

Description of environmental management Discussion and

Percentage of mine sites where acid rock

Percentage of (1) proved and (2) probable

Percentage of (1) proved and (2) probable

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 6

Discussion of process to manage risks and

Percentage of active workforce covered under

(1) MSHA All-Incidence rate, (2) fatality rate,

Sensitivity of coal reserve levels to future price

Tailings storage facility inventory table: (1)

Approach to development of Emergency

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 7

3 Note to EM-CO-000.B – The scope includes pulverized coal injection.

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 8

EM-CO-110a.1. Gross global Scope 1 emissions, percentage covered under

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 9

2.2.3 India GHG Inventory Program

2.2.4 ISO 14064-1

3.1.1 California Cap-and-Trade (California Global Warming Solutions Act)

3.1.2 European Union Emissions Trading Scheme (EU ETS)

3.1.3 Quebec Cap-and-Trade (Draft Bill 42 of 2009)

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 10

EM-CO-110a.2. Discussion of long-term and short-term strategy or plan to

2.5 The mechanism(s) for achieving the target; and

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 11

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 12

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 13

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 14

EM-CO-150a.2. Total weight of non-mineral waste generated

EM-CO-150a.3. Total weight of tailings produced

EM-CO-150a.4. Total weight of waste rock generated

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 15

EM-CO-150a.5. Total weight of hazardous waste generated

EM-CO-150a.6. Total weight of hazardous waste recycled

EM-CO-150a.7. Number of significant incidents associated with hazardous waste

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 16

EM-CO-150a.8. Description of waste management policies and procedures for

1.2 The scope of waste includes mineral and non-mineral waste.

SUSTAINABILITY ACCOUNTING STANDARD | COAL OPERATIONS | 17

3.1.2 Policies and procedures related to waste avoidance;