By Karina Sangha, Chief Auditor, Mine Audits Unit
The British Columbia Mine Audits Unit plays a key role in the continuous improvement of mining regulation in the province. Led by the Chief Auditor, the Mine Audits Unit is a dedicated team in the Ministry of Energy, Mines and Low Carbon Innovation (the Ministry). The team evaluates the Ministry’s oversight of the mining sector and makes public recommendations to government.
Created following the Mount Polley mine disaster and in response to findings by the B.C. Auditor General, the Mine Audits Unit was announced by the provincial government in 2019. It was part of a series of initiatives to strengthen mining regulation. The unit was presented as a team of mining experts – individuals with expertise in mining technical disciplines who could provide detailed evaluations of mining regulation and targeted recommendations.
While the Mine Audits Unit is unique, with an exclusive focus on mining regulation, its creation is part of a broader trend of growing audit functions throughout the public sector. With public demand for transparency and accountability on the rise, audit functions are being established at all levels of government across Canada (e.g., Auditor General for the City of Vancouver, the now-closed Auditor General for Local Government in B.C., and the Inspection Verification Office at the Canadian Food Inspection Agency).
There are opportunities and challenges that come with building a new audit function. It’s exciting to have the space to create, but it can also be daunting to start from scratch.
As with anything, there’s no one-size-fits-all blueprint for getting a new audit function off the ground. However, we have identified some key learnings from our experience of building the Mine Audits Unit that may be useful to others who are (or will be) responsible for doing the same.
When setting up something new, it’s easy to get overwhelmed. There are staff to hire and onboard, mandates and processes to define, interested parties to engage, and projects to start. It can be a lot to manage while trying to meet high expectations for the audit function to quickly deliver results.
But you don't need to have everything figured out right away. A well-defined audit function takes time. Put the essentials in place, lean into the uncertainty, and allow the function to iteratively develop as you move through the process.
In creating the Mine Audits Unit, we hit the ground running. We promptly chose two audit topics, put a basic process in place, and got to work, knowing we would build credibility faster by engaging with partners and stakeholders through ongoing projects than by waiting to have everything fully developed.
We also launched a website for the Mine Audits Unit as early as possible. At first, it was just a single landing page with a short description of the audit function and a couple of supporting documents. It quickly developed into a central hub for information-sharing, and over time, it has helped build confidence in our role as a transparent, reputable audit office.
Ask For Help
It’s important to recognize that you don’t have to build everything from scratch. Auditing is a well-established discipline, and even if your mandate is unique, there are extensive resources available to help you set up your audit framework. Auditors are also a collaborative, helpful group – don’t be afraid to ask for help, input, and feedback.
We secured memberships with audit associations, pursued training with organizations like the Canadian Audit and Accountability Foundation, and hired an external advisor to support us. We also built relationships with other audit teams across the provincial public service. In addition to being a resource for audit templates, tools, and best practices, our fellow auditors have been an excellent sounding board as we face new challenges and opportunities.
Build A Diverse Team
An audit function is only as strong as the people conducting the work. To maintain objectivity and infuse creativity and innovation into your work, it can be helpful to build a team of individuals with a range of experiences and backgrounds.
Since its creation, our team has consisted of individuals from different technical disciplines in mining, such as mining engineering, geoscience, environmental science, and industrial hygiene. Working collaboratively as a diverse team, combined with training in audit best practices, has helped us ensure our work is objective and comprehensive.
Over time, we have pushed this diversity even further, more recently hiring individuals without a mining background. These team members have added further value to our work by bringing additional skillsets and experiences (e.g., qualitative research, Indigenous engagement), questioning assumptions, and helping ensure our work remains accessible to a general audience.
Establish and Maintain Meaningful Relationships
It’s important for audit functions to establish and maintain mutually respectful, transparent relationships with key interested parties. These relationships are critical to establishing credibility and encouraging open participation throughout the audit process.
Our team has worked hard to build relationships with our key partners and stakeholders, including Ministry staff, Indigenous peoples, the mining industry, labour representatives, other regulatory bodies, non-governmental organizations and civil society. I started meeting with interested parties during my first week on the job – before the Mine Audits Unit was a fully formed team with a clear mandate and approach. We were clear during those early engagements that the Mine Audits Unit was under development, and we were able to adapt and refine our approach in response to what we heard.
Throughout the audit process, impacted groups are given the opportunity to hear, understand, and comment on our work before it gets publicly released, helping build trust and ensure our work is responsive to a diversity of interests. In one recent case, we were even able to co-author a piece with a civil society member to raise the profile of our work and highlight the value of continuous improvement.
Aligning with B.C.’s commitments to Indigenous reconciliation, we are currently focused on expanding our relationships with Indigenous peoples across the province and getting them more directly involved in our work. In May 2021, we signed a Memorandum of Understanding with the B.C. First Nations Energy and Mining Council that sets out commitments for bilateral dialogue and collaboration throughout the audit process. Our Indigenous partners have unique insights about the impacts of mining throughout their traditional territory that need to be considered in our audits and inform recommendations to government.
Set the Auditee Up for Success
Audits are meaningless without an engaged, accountable auditee that is positioned to respond to audit recommendations. In busy organizations, where audits can create more work for an already overtaxed system, it can be easy for audit work to slip through the cracks. As a result, it’s important for audit teams to work with their auditees to set up mechanisms for accountability and ensure that audit recommendations are actionable and adding value.
In 2021, we signed a Memorandum of Understanding with the Ministry of Energy, Mines and Low Carbon Innovation, under which the Ministry has committed to providing our team with access to information, producing a public response to each audit, and providing annual progress updates on work to address previous audit recommendations. The Ministry has also created a dedicated team outside the Mine Audits Unit to help coordinate and support Ministry efforts in relation to audits.
To support the Ministry in responding to audits, our team has shared certain types of information and analyses from our audits (e.g., jurisdictional scans, analyses of Ministry data), while also being mindful of any confidentiality considerations. This approach has helped the Ministry avoid duplicate work and zero in on some of the identified risks. In our current audits, we are also engaging more regularly with potentially impacted Ministry staff to understand their concerns and ideas for improvement so these can be considered when developing recommendations.
Commit to Continuous Improvement
As noted in Learning #1, building a new audit function can be daunting, and you almost certainly won’t get everything perfect at the outset. You need to leave space for the function to iteratively evolve, and you need to have mechanisms in place to support continuous learning and improvement.
Our team takes advantage of internal retrospectives and debriefing sessions throughout the audit process. We actively seek feedback through formal and informal channels with the Ministry and other interested parties. Though we were only created in 2019, these feedback loops have already contributed to several substantive program improvements.
Every audit provides an opportunity to learn and improve – both for the auditee and the audit team. We are still evolving, but we are excited about the program we have built and the two audits we have delivered so far, which are already contributing to improvements in mining regulation in B.C.
If you want to explore how to track the performance of an audit office look up our Discussion Paper on The Impact of Performance Audits: Defining, Measuring and Reporting Impact.
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