for FPIC for ‘any plan, program or proposal affecting the rights or living conditions of indigenous peoples.’21 The UN Declaration has been established as ‘a point of reference’ for reaching agreement on the outstanding articles.22 The African Commission on Human and Peoples Rights affirmed that the requirement for FPIC flows from both the rights to property and development under the African Charter on Human and Peoples Rights.23 In its 2009 ruling in the case of the Endorois v Kenya in the context of the right to development the African Commission held that for any development or investment projects which could: ...have a major impact within the Endorois territory, the State has a duty not only to consult with the community, but also to obtain their free, prior, and informed consent, according to their customs and traditions.24 The African Commission unambiguously affirmed the requirement for consent in the context of the right to property affirming that: ‘In terms of consultation, the threshold is especially stringent in favour of indigenous peoples, as it also requires that consent be accorded.’25 In 2012 the African Commission issued a resolution on a Human Rights-Based Approach to Natural Resources Governance confirming: …that all necessary measures must be taken by the State to ensure participation, including the free, prior and informed consent of communities, in decision making related to natural resources governance.26 International environmental law Article 8j of the Convention on Biological Diversity, addressing benefit sharing arrangements with indigenous peoples, has been interpreted by the Convention’s Conference of Parties as requiring indigenous peoples’ consent for access to their traditional knowledge.27 The 2004, the Akwé: Kon guidelines for the implementation of Article 8j of the Convention,28 recognized prior informed consent as being of fundamental importance in the context of protection of indigenous peoples’ cultures.29 The guidelines have been cited by human rights bodies as illustrative of best practice for impact assessments involving indigenous peoples in the context of extractive projects.30 The requirement for indigenous peoples’ prior and informed consent was also included in the Convention’s 2011 Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization.31 The Nagoya protocol refers to the need to promote indigenous peoples’ FPIC protocols as a mechanism to ensure that consultation and consent seeking are consistent with indigenous peoples own practices and institutions. The UN Framework Convention on Climate Change Conference was also opened for ratification at the 1992 Earth Summit. To date its most tangible outcome is the Collaborative Programme on Reducing Emissions from Deforestation and Forest Degradation in Developing Countries, under the secretariat of the UN Development Programme.32 The programme is currently developing guidelines for FPIC processes for its activities, with discussion arising in relation to the extension of the requirement to include local communities.33 The 2012 Conference on Sustainable Development (Rio +20) report, The future we want, extends this recognition of the requirement for indigenous peoples FPIC by recognizing: ...the importance of the United Nations Declaration on the Rights of Indigenous Peoples in the context of global, regional, national and subnational implementation of sustainable development strategies.34 Specific standards pertaining to corporate engagement with indigenous peoples Over the course of the last decade multinational mining companies have placed increasing emphasis on engagement with indigenous peoples as part of their policies. This has gone hand in hand with efforts within the UN to formulate and develop internationally applicable standards and guidance Making Free, Prior and Informed Consent a Reality 9

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