In three sentences:
Current ASM approaches continue to have high failure rates due to lack of coordination, commitment from stakeholders, and implementation challenges. While conceptual frameworks are well developed, practical guidance is lacking. To be successful, future approaches need coordinated action through a shared framework, incentives for stakeholder commitment, and solutions to critical implementation barriers such as lack of state capacity.
presentation to british house of commons all parliamentary committee
RCS Global Director Harrison Mitchell presents on due diligence at British Parliament in London
On 20th October, RCS Global director Harrison Mitchell presented to a packed session of the All Party Parliamentary Committee on Extractives on conducting human rights due diligence in raw materials supply chains.
The presentation provides a background for why human rights due diligence is increasingly important for all companies in the supply chain, from miners, to traders, manufacturers and investors.
Human rights issues will continue to be of significant importance to the APPC, as well as the extractive sector generally, particularly in light of new legislation currently under discussion by the European Union on conflict minerals.
presentation to british house of commons all parliamentary committee
RCS Global Director Harrison Mitchell presents on due diligence at British Parliament in London
On 20th October, RCS Global director Harrison Mitchell presented to a packed session of the All Party Parliamentary Committee on Extractives on conducting human rights due diligence in raw materials supply chains.
The presentation provides a background for why human rights due diligence is increasingly important for all companies in the supply chain, from miners, to traders, manufacturers and investors.
Human rights issues will continue to be of significant importance to the APPC, as well as the extractive sector generally, particularly in light of new legislation currently under discussion by the European Union on conflict minerals.
Promoting legal mineral trade in Africa: new policy approachesRCS Global
International Policy Conference – Competitiveness and diversification: Strategic challenges in a petroleum-rich country (Ghana Ministry of Trade and Industry & UNIDO)
Accra, 14-15 March 2011
An introduction to ESG (Environmental, Social and Governance) Investing from Artifex Financial Group, a leader in ESG portfolio research and management.
Review of PWYP mission, membership and priorities
Presentation of “Publishing What We Learned” report – historical perspective on PWYP
Henry Parham, The Elders
Introduction to Community Development Agreements (CDAs)Ethical Sector
Presentation by Emma Irwin, Consultant, World Bank,
at a “Multi-Stakeholder Workshop on Community Engagement in the Extractive Industries” in Yangon on 27/28 January 2015, convened by the Myanmar Centre for Responsible Business (MCRB) to discuss international best practice in strategic community investment and engagement, including how to handle grievances.
Nina Eisenman hosts a webinar with the IIRC’s communications director, Jonathan Labrey, as part of an initiative to educate IROs in how they can ‘uncover new ways to create value throughout their organizations.’ The online discussion, entitled An Introduction to Integrated Reporting, will also allow IROs to ask their own questions about the framework in a Q&A with Eisenman and Labrey.
Balanced Rock Investment Advisors educational presentation on alternative investment strategies that reflect personal values.
Presented @ Brookline Library - 10.15.2015
The Rise and Risks of Lending to Non-Depository Financial InstitutionsColleen Beck-Domanico
This excerpt from the RMA Credit Risk Council's “2017 Industry Insights: Perspectives from the Front Line” talks about the risks of lending to non-depository financial institutions. Those credit risks can be substantial and can arise from various factors.
ESG Is No Longer Optional. What Every Private Equity Manager Should KnowNavatar
Recording: https://www.youtube.com/watch?v=K5NBmZs84gY&feature=youtu.be
Responsible investment (or ESG), once a do-good sideshow, is becoming mainstream. Private equity managers must consider a host of issues, from gender diversity to carbon emissions, or risk losing investor capital and deals. The trend is only growing.
The challenge today is formalizing ESG policies to meet heightened standards. In this webinar, Navatar in conjunction with Invest Europe, brought together leading ESG thinkers from the industry to discuss how GPs should present their ESG framework to investors, what to consider during pre-investment due diligence, and ultimately portfolio monitoring and exit.
We address:
- Why your ESG strategy can make or break a deal
- What LPs want to see in your policies/practices
- Bringing your ESG DDQ to the next level
-Automation, plastics and other emerging ESG risks
Speakers:
- Maaike van der Schoot, Responsible Investment Officer, AlpInvest Partners
- James Holley, Head of ESG, Bridgepoint
- Graeme Ardus, Head of ESG, Triton Partners
- Jaideep Das, Partner, ERM
International Project Financing: Environmental Social Governance (ESG)
How do the Revised Equator Principles (EP4) Apply?
LR Consultants
Dubai
UAE
March 2021
Stakeholder management seminar the petroleum industry bill as focusBolaji Okusaga
Effective Stakeholder Management is essential for sucess in policy and legislative environments. This Seminar looks at the dynamics of Stakeholder Relationship which can aid the passage of one of Nigeria's most sought-after piece of legislation - the Petroleum Industry Bill.
2020, the latest developments in Environment, Social and Governance investingnetwealthInvest
In this presentation, we discuss current ESG themes, including regulatory changes and key environmental, social and governance factors that investors need to understand in 2020.
This presentation by Adrian Blundell-Wignall was prepared for a session at COP21 on "Governance of Institutional Investments: Fiduciary standards for addressing green finance and the portfolio impact of climate change".
Find out more:
http://www.oecd.org/finance/COP21session-GovernanceofinstitutionalinvestmentsFiduciarystandardsforaddressinggreenfinanceandtheportfolioimpactofclimatechange.htm
http://www.oecd.org/daf/
Promoting legal mineral trade in Africa: new policy approachesRCS Global
International Policy Conference – Competitiveness and diversification: Strategic challenges in a petroleum-rich country (Ghana Ministry of Trade and Industry & UNIDO)
Accra, 14-15 March 2011
An introduction to ESG (Environmental, Social and Governance) Investing from Artifex Financial Group, a leader in ESG portfolio research and management.
Review of PWYP mission, membership and priorities
Presentation of “Publishing What We Learned” report – historical perspective on PWYP
Henry Parham, The Elders
Introduction to Community Development Agreements (CDAs)Ethical Sector
Presentation by Emma Irwin, Consultant, World Bank,
at a “Multi-Stakeholder Workshop on Community Engagement in the Extractive Industries” in Yangon on 27/28 January 2015, convened by the Myanmar Centre for Responsible Business (MCRB) to discuss international best practice in strategic community investment and engagement, including how to handle grievances.
Nina Eisenman hosts a webinar with the IIRC’s communications director, Jonathan Labrey, as part of an initiative to educate IROs in how they can ‘uncover new ways to create value throughout their organizations.’ The online discussion, entitled An Introduction to Integrated Reporting, will also allow IROs to ask their own questions about the framework in a Q&A with Eisenman and Labrey.
Balanced Rock Investment Advisors educational presentation on alternative investment strategies that reflect personal values.
Presented @ Brookline Library - 10.15.2015
The Rise and Risks of Lending to Non-Depository Financial InstitutionsColleen Beck-Domanico
This excerpt from the RMA Credit Risk Council's “2017 Industry Insights: Perspectives from the Front Line” talks about the risks of lending to non-depository financial institutions. Those credit risks can be substantial and can arise from various factors.
ESG Is No Longer Optional. What Every Private Equity Manager Should KnowNavatar
Recording: https://www.youtube.com/watch?v=K5NBmZs84gY&feature=youtu.be
Responsible investment (or ESG), once a do-good sideshow, is becoming mainstream. Private equity managers must consider a host of issues, from gender diversity to carbon emissions, or risk losing investor capital and deals. The trend is only growing.
The challenge today is formalizing ESG policies to meet heightened standards. In this webinar, Navatar in conjunction with Invest Europe, brought together leading ESG thinkers from the industry to discuss how GPs should present their ESG framework to investors, what to consider during pre-investment due diligence, and ultimately portfolio monitoring and exit.
We address:
- Why your ESG strategy can make or break a deal
- What LPs want to see in your policies/practices
- Bringing your ESG DDQ to the next level
-Automation, plastics and other emerging ESG risks
Speakers:
- Maaike van der Schoot, Responsible Investment Officer, AlpInvest Partners
- James Holley, Head of ESG, Bridgepoint
- Graeme Ardus, Head of ESG, Triton Partners
- Jaideep Das, Partner, ERM
International Project Financing: Environmental Social Governance (ESG)
How do the Revised Equator Principles (EP4) Apply?
LR Consultants
Dubai
UAE
March 2021
Stakeholder management seminar the petroleum industry bill as focusBolaji Okusaga
Effective Stakeholder Management is essential for sucess in policy and legislative environments. This Seminar looks at the dynamics of Stakeholder Relationship which can aid the passage of one of Nigeria's most sought-after piece of legislation - the Petroleum Industry Bill.
2020, the latest developments in Environment, Social and Governance investingnetwealthInvest
In this presentation, we discuss current ESG themes, including regulatory changes and key environmental, social and governance factors that investors need to understand in 2020.
This presentation by Adrian Blundell-Wignall was prepared for a session at COP21 on "Governance of Institutional Investments: Fiduciary standards for addressing green finance and the portfolio impact of climate change".
Find out more:
http://www.oecd.org/finance/COP21session-GovernanceofinstitutionalinvestmentsFiduciarystandardsforaddressinggreenfinanceandtheportfolioimpactofclimatechange.htm
http://www.oecd.org/daf/
On Tuesday, 23 September, MCRB hosted a half-day workshop on “Anti-Corruption Programmes” for Myanmar businesses in Yangon. The workshop, held in collaboration with Spectrum – a Yangon-based sustainable development knowledge network - was the first in a series of events to follow-up on the Transparency in Myanmar Enterprises (TiME) report and build business capacity in the area of anti-corruption and human rights.
LASSIB SOCIETY 2013 INDUSTRY ADVISORY REPORT ON "STRATEGY DEVELOPMENT"LASSIBSociety
Any organization/team can deliver excellent results when working with unlimited resources. However, being able to deliver the best results using limited resources is a key example of effective strategizing. It is a must read for those focusing to rebuild their strategies and attain a stable growth in their organizations.
Implementing Integrity: The Business Case for Forging an Ethical Company and ...Sean Cumberlege
This presentation advocates the need for extractive companies to commit to operating with integrity and recommends a more data driven and locally specific approach to identifying and mitigating social risk, including supply chain risk. The talk also frames social risk issues for an audience comprised mostly of attorneys.
What is Corporate Social Responsibility? Why CSR? How can you effectively deliver CSR...? etc. Enjoy this CSR Presentation we did in 2012 at le Bistro Latin in Douala.
Minimising reputation risks through sustainable change delivery assessment - ...Michael Young
This presentation provides an overview of the reputation risks facing organisations and how they can be minimised through a sustainable change delivery assessment.
Ideas, insights and inspiration on the topic of sustainability for anti-corruption Collective Action initiatives. The ideas arise from the 2020 Integrity Partners Workshop Series, hosted by the Basel Institute on Governance in August 2020 with the support of the Siemens Integrity Initiative.
Purpose Up - Doubling down in tough times by Barkley + JefferiesBarkley
Now is not the time to shrink back on sustainability and ESG criteria, it is time to double down with focus and clarity. These are the findings from our third annual report Purpose Up | Doubling Down in Tough Times, a joint research study with Jefferies.
Jennifer Schaus and Associates hosts a complimentary webinar series on The FAR in 2024. Join the webinars on Wednesdays and Fridays at noon, eastern.
Recordings are on YouTube and the company website.
https://www.youtube.com/@jenniferschaus/videos
Canadian Immigration Tracker March 2024 - Key SlidesAndrew Griffith
Highlights
Permanent Residents decrease along with percentage of TR2PR decline to 52 percent of all Permanent Residents.
March asylum claim data not issued as of May 27 (unusually late). Irregular arrivals remain very small.
Study permit applications experiencing sharp decrease as a result of announced caps over 50 percent compared to February.
Citizenship numbers remain stable.
Slide 3 has the overall numbers and change.
Understanding the Challenges of Street ChildrenSERUDS INDIA
By raising awareness, providing support, advocating for change, and offering assistance to children in need, individuals can play a crucial role in improving the lives of street children and helping them realize their full potential
Donate Us
https://serudsindia.org/how-individuals-can-support-street-children-in-india/
#donatefororphan, #donateforhomelesschildren, #childeducation, #ngochildeducation, #donateforeducation, #donationforchildeducation, #sponsorforpoorchild, #sponsororphanage #sponsororphanchild, #donation, #education, #charity, #educationforchild, #seruds, #kurnool, #joyhome
A process server is a authorized person for delivering legal documents, such as summons, complaints, subpoenas, and other court papers, to peoples involved in legal proceedings.
Russian anarchist and anti-war movement in the third year of full-scale warAntti Rautiainen
Anarchist group ANA Regensburg hosted my online-presentation on 16th of May 2024, in which I discussed tactics of anti-war activism in Russia, and reasons why the anti-war movement has not been able to make an impact to change the course of events yet. Cases of anarchists repressed for anti-war activities are presented, as well as strategies of support for political prisoners, and modest successes in supporting their struggles.
Thumbnail picture is by MediaZona, you may read their report on anti-war arson attacks in Russia here: https://en.zona.media/article/2022/10/13/burn-map
Links:
Autonomous Action
http://Avtonom.org
Anarchist Black Cross Moscow
http://Avtonom.org/abc
Solidarity Zone
https://t.me/solidarity_zone
Memorial
https://memopzk.org/, https://t.me/pzk_memorial
OVD-Info
https://en.ovdinfo.org/antiwar-ovd-info-guide
RosUznik
https://rosuznik.org/
Uznik Online
http://uznikonline.tilda.ws/
Russian Reader
https://therussianreader.com/
ABC Irkutsk
https://abc38.noblogs.org/
Send mail to prisoners from abroad:
http://Prisonmail.online
YouTube: https://youtu.be/c5nSOdU48O8
Spotify: https://podcasters.spotify.com/pod/show/libertarianlifecoach/episodes/Russian-anarchist-and-anti-war-movement-in-the-third-year-of-full-scale-war-e2k8ai4
Jennifer Schaus and Associates hosts a complimentary webinar series on The FAR in 2024. Join the webinars on Wednesdays and Fridays at noon, eastern.
Recordings are on YouTube and the company website.
https://www.youtube.com/@jenniferschaus/videos
ZGB - The Role of Generative AI in Government transformation.pdfSaeed Al Dhaheri
This keynote was presented during the the 7th edition of the UAE Hackathon 2024. It highlights the role of AI and Generative AI in addressing government transformation to achieve zero government bureaucracy
Many ways to support street children.pptxSERUDS INDIA
By raising awareness, providing support, advocating for change, and offering assistance to children in need, individuals can play a crucial role in improving the lives of street children and helping them realize their full potential
Donate Us
https://serudsindia.org/how-individuals-can-support-street-children-in-india/
#donatefororphan, #donateforhomelesschildren, #childeducation, #ngochildeducation, #donateforeducation, #donationforchildeducation, #sponsorforpoorchild, #sponsororphanage #sponsororphanchild, #donation, #education, #charity, #educationforchild, #seruds, #kurnool, #joyhome
What is the point of small housing associations.pptxPaul Smith
Given the small scale of housing associations and their relative high cost per home what is the point of them and how do we justify their continued existance
2. www.rcsglobal.com
INTRODUCTION: KEY QUESTIONS WE ASKED
2
1 How can ASM issues possibly be resolved?
2 Who is best placed to do so?
3 What are current practices?
4 What are the strengths and weaknesses of current practices?
5 What needs to change for ASM issues to be resolved?
Although practice on ASM issues
is being advanced, design,
stakeholder engagement and
implementation issues persist.
3. www.rcsglobal.com
CONTENT OF PRESENTATION
3
Consider ASM risk vs ASM development perspective (different
schools of practice with different champions)
Review principal ASM approaches (limited to the three
dominant approaches over the past decade)
Evaluate current practices in each approach (what is being done
and how well does it work)
Consider the key challenges in ASM approaches
4. www.rcsglobal.com
HOW TO TREAT ASM: DEVELOPMENT VS RISK PERSPECTIVE
4
Development
perspective
(longer-term)
Normally used by
NGOs, governments
and donors (still often
time-bound and project
based)
ASM
development
responses
Risk
perspective
(shorter-
term)
Normally used by
companies
ASM risk
mitigation
responses
5. www.rcsglobal.com
HOW TO TREAT ASM: COMPANY RESPONSES
5
LSM-ASM
RESPONSES
SUCCESS
LEVEL
METHOD
Venezuela:
Las Cristinas, Placer
Dome
Medium
Policy of tolerance, technical assistance to ASM workers for formalisation,
mercury and safety issues
Tanzania: North
Mara, Africa Barrick
Gold
Low
Technical and organisational assistance to ASGM producers working near
LSM site.
Tanzania:
Williamson Diamond
Mine, De Beers
N/A
Technical and organisational assistance to diamond mining of ASM
producers working near LSM site. (Conceptually developed, but never
implemented.)
Ghana:
Abosso, Goldfields
Low Live and Let Live approach. Segregation of concession.
Honduras:
Eurocantera,
Goldlake
High
ASM workers employed to liberate gold in deposits on LSM site. LSM
company processes ore. (Not an acute ASM hotspot.)
Philippines:
Benguet Corporation
Medium
LSM company identifies sites for ASGM, assists set-up and buys ore from
ASGM producers.
Bolivia:
San Simon,
Excalibur
Low Dialogue with ASM workers and signed agreement.
Nicaragua:
Multiple sites
Low LSM companies buys ore from ASM workers and processes.
6. www.rcsglobal.com
HOW TO TREAT ASM: DEVELOPMENT ISSUES CAUSE ASM RISKS
6
ASM DEVELOPMENT ISSUES (ILLUSTRATIVE LIST)
Informality
Low
investment
Weak enforcement
Negative
externalities in
communities
ASM RISKS FOR COMPANIES
No reasons to stay
off LSM concessions
Short-term, risk-
taking behaviour
Security risks
Risk to social and
political license
7. www.rcsglobal.com
HOW TO TREAT ASM: APPROACHES FOR SHORT- AND LONG-TERM
7
ASM
development
issues
Address root causes
(longer-term)
ASM
development
responses
ASM risks
Contain and
manage risks
(shorter-term)
ASM risk-
mitigation
responses
Companies require an integrated ASM strategy, but LSM-ASM practice
remains underdeveloped:
8. www.rcsglobal.com
THREE KEY DEVELOPMENT POLICY APPROACHES TO ASM
8
Formalisation
Ethical
certification &
due diligence
Technical
assistance /
Mercury
reduction
9. www.rcsglobal.com
KEY DOCUMENTS: FORMALISATION
9
BARRETO, 2011
Legislation guide for ASM
1
UNEP, 2013
Analysis of Formalisation
Approaches
2
SDC, 2011
Experiences with
Formalisation in 4 countries
UNEP, 2013
National Plan for ASM
3 4
10. www.rcsglobal.com
KEY DOCUMENTS: ETHICAL CERTIFICATION AND DUE DILIGENCE
10
ARM AND FLO, 2010
Fairtrade and Fairmined
Gold Standard
1
OECD, 2012
Due Diligence Guidance,
Supplement for Gold
2
BETTER GOLD, 2013
Next generation closed-pipe
ethical certification
ITSCI, 2009
Traceability scheme
3 4
11. www.rcsglobal.com
KEY DOCUMENTS: TECHNICAL ASSISTANCE AND MERCURY
11
NOETSTALLER, 1987
Small-Scale Mining Study
1
UNECA, 2002
Compendium of best
practices
2
GMP, 2006
Training Manual for Miners
UNEP, 2013
Global Mercury Treaty
3 4
12. www.rcsglobal.com
A number of challenges have
been both common and
persistent, that concern:
APPROACHES: PERSISTENT CHALLENGES
12
STAKEHOLDER ENGAGEMENT
IMPLEMENTATION
DESIGN
Persistent
high rate of
failure.
13. www.rcsglobal.com
DESIGN CHALLENGE: COOPERATION AND COORDINATION
13
On ASM,
stakeholders often
work in isolation
from one another,
which yields poor
results. Incentives
are often ill-
understood and
misaligned and
initiatives can in
the worst case
work against one
another.
LSM
action
LSM
initiative
Govt
action
Govt
initiative
Donor
action
Donor
initiative
ASM
initiative
ASM
action
14. www.rcsglobal.com
DESIGN CHALLENGE: COMMUNICATION AND VISION
14
Stakeholders find it difficult to work together because they do not share
visions of what should be done with ASM, or who should do it. This
means incentives are ill-understood.
Stakeholders should play different roles and align their approaches in
ASM initiatives, so a common idea of how things should work is critical.
We believe it is conceivable to translate this idea into an action
framework from which coordinated and aligned activities can derive.
15. www.rcsglobal.com
In some circumstances, stakeholders could coordinate their actions on ASM
and collaborate to improve their joint impact, but incentives to collaborate are
ill-understood and not acted upon.
DESIGN CHALLENGE: COOPERATION AND COORDINATION
15
COORDINATED ACTIVITIES THROUGH A FRAMEWORK
Government
action
LSM
action
Donor
action
ASM
organisations
action
NGO
action
16. www.rcsglobal.com
ENGAGEMENT CHALLENGE: INTEREST AND COMMITMENT
16
Governments receive few immediate gains from supporting ASM and
may e.g. due to elections, not be incentivised to act.
Donor interest varies between countries and over time. Commitment is
often-time bound, particularly in Africa and engagement is erratic.
Companies do not always recognise that ASM is an issue and
understand the true costs of ASM.
Artisanal miners are often marginalised and not collectively organised and
thus often lack a coherent voice (and thus viewpoint). Protest and invastons
could be regarded as a form of voice.
NGOs often have their own agenda and their involvement is sometimes
ad-hoc and many are new to ASM. Success rate in Africa is weak.
In the absence of the right incentives, ASM projects fail.
17. www.rcsglobal.com
Tests of well-designed licensing regimes:
IMPLEMENTATION CHALLENGE: LEGAL SYSTEMS
17
1 Are the definitions between categories consistent?
2 Are accompanying regulations and requirements
appropriately adjusted for each category?
3 Can licenses be upgraded or downgraded?
4 Are the perverse incentives to not upgrade or
downgrade such as taxes or regulations?
5 Can states administer it feasibly?
Artisanal and
small-scale mining
Small-scale mining
Artisanal mining
Micro-scale mining
Legal and
regulatory
frameworks can
create obstacles
for successful
engagement in
the ASM sector,
e.g. in the DRC.
18. www.rcsglobal.com
States
suffer from
technical, human
or organisational
capacity
constraints
They are most
acute at the
regional and local
levels
Sub-standard
regulation
Barriers to
formalisation
Diminished
monitoring
ability
Poor management of
ASM Zones, processes
or projects
IMPLEMENTATION CHALLENGE: STATE CAPACITY
18
This process is for
illustrative
purposes only.
19. www.rcsglobal.com
IMPLEMENTATION CHALLENGE: RESISTANCE TO REFORM
19
RESISTANCE TO REFORM
ASM
communities
ASM civic
representatives
ASM dealers ASM suppliers
Agencies whose
raison d’etre is
addressing
ASM issues
Government,
particularly in
the context of
elections
National and local stakeholders can create
obstacles to reforms not in their interest.
ASM institutional and stakeholder analysis
should be built into ASM project design.
20. www.rcsglobal.com
IMPLEMENTATION CHALLENGE: MINERS’ COSTS AND BENEFITS
20
Are artisanal miners’ priorities adequately
respected in technical assistance?
Do artisanal miners respect trainers and
technical assistance from NGOs?
What are the incentives that they face to
change their behaviour?
What chance do ASM projects have that do
not consider miners’ costs and benefits?
Miners must have
a sense of
ownership of
interventions to
increase
likelihood of
success. A
concept linked to
their perceived
costs and benefits
and participation.
21. www.rcsglobal.com
Current practice have been well developed conceptually.
Nevertheless, ASM initiatives continue to display a high rate of failure.
Most of all, this is due to:
Summary: Persistent Challenges
21
LACK OF COORDINATION AND COOPERATION
LACK OF VISION AND COMMUNICATION
LACK OF INTEREST AND COMMITMENT
CRITICAL IMPLEMENTATION CHALLENGES
LACK OF PARTNER CAPACITY
LACK OF PRACTICAL GUIDANCE
22. www.rcsglobal.com
Text
Key Points Discussed by Group
Governments receive few immediate gains from supporting ASM
Donor interest varies with policy fashions. It is inconsistent between
countries and over time.
Companies do not always recognise that ASM is an issue and understand
the true costs of ASM.
22
Paradoxically, current practices are developed in detail, but projects continue to fail. While
current practices are well developed conceptually, they are not well developed to assist project
design or implementation.
Practical challenges are the critical ones that reduce project successfulness. Approaches need
to be developed, and practical guidelines need to be developed.
Integrating risk and development perspectives is a key step towards addressing the causes of
ASM risks for companies.
Partnership and collaborative approaches should be used to galvanise actors to act.
ASM is both a development issue, and a risk issue for companies. Addressing ASM as a development
issue can resolve risk issues in the long term, but immediate risk issues should be addressed before
ASM is tackled as a development issue, especially at sites where ASM is well-developed already.