FPIC negotiations, without interference from companies, the State or other actors. These may be traditional elders or they may be representatives selected and authorized by the community for the specific purpose of negotiating with the company on the terms, conditions and conduct of FPIC. Indigenous guidelines for FPIC implementation Points in the development process when should FPIC be obtained It was pointed out that the UN Declaration on the Rights of Indigenous Peoples (UN Declaration) recognizes FPIC at the “Companies, working in our level of policies or laws, programs and projects. Thus, before the country act in compliance with government initiates an FPIC process at a project level, there should national legislation. If those be FPIC at the policy and program levels. Indigenous peoples’ laws don’t protect indigenous would have to give consent for their territories to be designated as mining areas, before the government can even consider entering peoples’ rights, the companies into investment agreements with, or issuing mining concessions, will ignore them but still look exploration permits or licenses to, mining companies. Both the like they are not doing anything State authorities and mining companies would need to exert due against the law. If they are bound diligence to ensure that there is FPIC before the issuance of a by criteria of international mining concession in indigenous peoples’ areas. donors or certifications, they attempt to reach consent with Many representatives argued that it makes a good case in the moral and cultural sense, as well as in the business sense, to seek local communities, otherwise, FPIC at the earliest time possible. Consultations need to be done they don’t.” at the very early inception and planning stages of a mining project Quote from Valentina as an investment or insurance against future risk. Even before Semyashkina, Izvatas from entering indigenous territory, the company would have to talk to Komi Republic, Russia the people to explain what it is they plan to do. The earlier they do it, the easier it is for them to develop good faith in any subsequent negotiations. FPIC should be an on-going and iterative process, and should be obtained at every major step of the mining development process, for instance from exploration, to feasibility, operation and postoperation. A major step would be defined as one which has a potential impact on an indigenous communities’ enjoyment of their rights. The community and the company would have to negotiate different conditions and requirements for each stage. The indigenous representatives expressed the view that FPIC is non-transferrable, and is not for sale at any point in the mining process. If a company pulls out of a project, this would signify abandonment. If another company takes over or buys the project or company, this should require another FPIC process to be negotiated between the community and the new entity. They regarded this as necessary to protect indigenous peoples from concessions being acquired by companies with a poor track record in relation to respect for indigenous peoples’ rights, and to negotiate the terms of agreements with the new entity. Extent of FPIC consultations Indigenous interviewees emphasized that FPIC processes must include all the indigenous communities to the extent in which impacts occur in their territories. Indigenous representatives pointed out that the communities are the only ones who can assess the extent of most social, cultural, spiritual and, certain types of, economic impacts. All indigenous communities directly and indirectly affected would need to be included in the FPIC process. Particular emphasis was placed on this in contexts where projects may impact on water resources or culturally significant areas. FPIC is also an indispensable requirement for all projects involving relocation of indigenous peoples. 20 Making Free, Prior and Informed Consent a Reality

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