Implementing Our Indigenous Peoples Policy
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Our Implementation Framework for our Indigenous Peoples Policy continues to evolve based on practical experience, the scope and nature of our projects and operations, and the different requirements and interests of the Indigenous communities affected by our activities. As noted at the outset of this report, our approach to implementing this policy largely reflects the approach taken by our Liquids business in Canada and the U.S. for oil pipelines that cross Indigenous lands. We are currently integrating our Gas Transmission and Midstream business (obtained through our merger with Spectra Energy in 2017) in this framework to include natural gas pipelines that cross Indigenous lands. An overview of how we are implementing our Indigenous Peoples Policy is presented below.
| Implementation Framework for Enbridge’s Indigenous Peoples Policy | ||
|---|---|---|
| A. | Cross-Cutting Decision Making Structures | Strategy, execution and coordination across different Business and Functional Units |
| B. | Integration of Indigenous Peoples Policy Requirements in Key Management Systems | Policies, processes, practices and accountabilities |
| C. | Community-Specific Consultation, Engagement, Agreements and Collaborations |
Addressing local Indigenous involvement in:
|
| D. | Performance | Measurement and evaluation |
| E. | New Practices and Innovation | Special projects and initiatives |
A. Cross-Cutting Decision Making Structures
Enbridge’s Indigenous Peoples Policy is implemented based on a management system approach where accountabilities for identifying and addressing Indigenous-related opportunities and risks are distributed on an integrated basis across all key relevant business segments and functions.
| Cross-Cutting Decision Making Structures | ||
|---|---|---|
| Level | What’s in Place | Description |
| Board of Directors | Formal Board Processes for Strategy, Risk and Investment Review CSR Committee of the Board |
Our approach to Indigenous consultation and engagement is overseen by the Corporate Social Responsibility (CSR) Committee of our Board of Directors. The CSR Committee reports to our full Board. We also create opportunities for our full Board to engage directly with Indigenous leaders at strategy and planning sessions. The Executive Vice President and Vice President responsible for Indigenous Relations provide quarterly reports to the CSR Committee on Indigenous matters. The CSR Committee of our Board also oversees our public reporting on Enbridge’s performance on key social, environmental and governance issues. |
| Executive & Vice President | Enterprise-wide Indigenous Engagement Steering Committee | Our Indigenous Engagement Steering Committee sets the direction and establishes policies and strategies for Enbridge’s engagement with Indigenous Nations and groups. The Committee reports to the Executive Vice Presidents of our business units and the Executive Vice President & Chief Legal Officer. It is comprised of accountable Vice Presidents and Management from relevant business units and functions in Canada and the U.S. This senior level committee ensures broad discussion on Indigenous relations is taking place across all relevant internal disciplines and it steers on-the-ground Indigenous engagement with communities linked to achievement of critical milestones and outcomes. |
| Vice President & Director | Project and Regionally Based Integrated Steering Committees | These are integrated steering committees of Vice Presidents, Directors and other Management at the Business Unit and Functional level responsible for the development and execution of both project-based and regionally-based engagement plans, each of which includes specific provisions regarding Indigenous consultation and engagement. |
| Managers and Subject Matter Experts | Multidisciplinary Teams | Strategies and outcomes established through consultation or commitments to Indigenous Nations and groups are executed and delivered upon by managers and subject matter experts from, for example, Environmental Management, Regulatory, Human Resources, Business Development, Supply Chain Management, Public Affairs & Communications, and other functional units of the company. |
| Employees | Indigenous Employee Resource Group | Indigenous and other interested employees at Enbridge are provided with the opportunity to participate in an Indigenous Employee Resource Group that has been in place since 2014. The purpose of this working group is to support development of an inclusive working environment through improved awareness of Indigenous cultures among all employees. It is supported by an Executive sponsor at the Vice President level. |
B. Integration of Indigenous Peoples Policy Requirements in Key Management Systems
Enbridge’s Indigenous Peoples Policy is implemented based on a management system approach where accountabilities for identifying and addressing the impacts our operations have on Indigenous communities and their rights are distributed on an integrated basis across all relevant business units and functions. Our Vice President, Public Affairs & Communications has lead accountability across the enterprise.
| Integration of Indigenous Peoples Policy Requirements in Key Management Systems | ||
|---|---|---|
| Management System | Integration Objective | Accountability |
| Safety and Environmental Management | Inclusion of Indigenous communities in all relevant Enbridge strategies, plans and activities on pipeline safety, operational reliability and environmental management |
Chief Executive Officer Executive Leadership Team (including Executive Vice Presidents of all Business Units) Vice Presidents, Major Projects and Operations Vice President, Safety and Reliability Vice President, Public Affairs & Communications |
| Investment Review | Consideration of Indigenous impacts and opportunities in decision making on capital expenditures | Chief Executive Officer Executive Vice President & Chief Development Officer Executive Vice President & Chief Financial Officer Executive Vice President & Chief Legal Officer Vice President, Corporate Development & Investment Review Vice President, Public Affairs & Communications |
| Law and Regulatory | Compliance with all legal and regulatory requirements regarding Indigenous rights and participation in energy projects and operations | Executive Leadership Team Executive Vice President & Chief Legal Officer Vice President & General Counsel Vice President & Chief Compliance Officer (all Business Units) Vice Presidents, Major Projects & Operations Vice President, Public Affairs & Communications |
| Stakeholder and Indigenous Engagement | Development and execution of all plans and programs for Indigenous consultation, engagement and relationship building | Executive Vice President & Chief Legal Officer Vice Presidents, Major Projects & Operations Vice President, Public Affairs & Communications Directors, Stakeholder & Indigenous Engagement |
| Supply Chain Management (SCM) | Embedding expectations for Indigenous inclusion in all SCM strategies and programs, including RFP assessment criteria, direct awards and activities with contractors and suppliers | Executive Vice President, Corporate Services Vice President & Chief Supply Chain Officer Vice Presidents, Major Projects & Operations Vice President, Public Affairs & Communications |
| Human Resources | Employee and contractor awareness and training on Indigenous rights, history, traditions and culture Long-term strategy for recruitment and retention of Indigenous employees |
Executive Vice President, Corporate Services Vice President & Chief Human Resources Officer Vice President, Public Affairs & Communications |
| Performance Management | Incorporation of goals and metrics related to performance on Indigenous issues in relevant corporate scorecards and personal performance objectives | Executive Leadership Team Vice President, Human Resources & Chief Human Resources Officer Vice President, Public Affairs & Communications |
| Risk Management | Inclusion and alignment of Indigenous issues in Enterprise Risk Management Framework and processes | Vice President, Enterprise Risk Vice President, Public Affairs & Communications |
| Security | Alignment of Enbridge Security Policy with widely recognized principles for the protection of human rights in the provision of security for our business operations | Executive Vice President & Chief Legal Officer Chief Security Officer Vice President, Public Affairs & Communications |
C. Community-Specific Consultation, Engagement, Agreements and Collaborations
Direct consultation and engagement with Indigenous Nations and groups potentially impacted by Enbridge’s liquid pipeline projects and operations is fundamental to our ability to ensure that our plans and activities address issues of importance to those communities. We therefore also take a systems-based approach to identifying Indigenous communities impacted by our liquid pipeline projects and operations and their unique interests and concerns. Wherever possible, we work jointly with interested local Indigenous Nations and groups to mitigate risks and/or concerns and expand social, environmental and economic benefits. This includes re-routing and other changes to design and operation. Our experience has been, and continues to be, that community specific agreements help establish a framework that enables the trust required to build and ultimately maintain long-term relationships.
| Community-Based Consultation, Engagement, Agreements and Collaborations | ||
|---|---|---|
| Performance Area | Focus | Description |
| Consultation and Engagement on Project Planning and Development | Project Engagement Plans address requirements and opportunities specific to an individual project. Mandated activities include early consultation with Indigenous communities to secure their involvement in matters related to engineering, routing, cultural and environmental protection, construction, land management, procurement and the long-term operation. | Efforts to enhance the participation of Indigenous Peoples in risk assessment and mitigation planning create meaningful opportunities to influence project scope and design as well as ongoing strategies for safety, cultural protection and environmental stewardship. Project engagement plans are intended to be proactive and enable two-way interaction and problem solving designed to obtain local input on Enbridge’s projects and ongoing activities, and to ensure the company both understands and acts on that input. These plans identify and prioritize issues, tailor engagement methods according to community needs, and develop mitigation measures and processes to respond to specific issues and risks. Processes include mapping, impact assessment, objectives and target setting, and systems for information management and tracking Indigenous engagements and commitments. |
| Lifecycle Approach | Regional Engagement Plans address the need to maintain relationships with Indigenous communities at an operations level across the life cycle of the Enbridge’s assets. These plans also help ensure appropriate staffing (including staff and contractor training and continuity) to provide the basis for ongoing trust and mutual problem solving. | In order to take advantage of synergies between Enbridge’s different businesses (oil and gas pipelines, natural gas utilities, power and renewables), as well as geographic overlap between different Indigenous communities, these plans provide a consolidated approach at regional basis vs. an individual facility basis. They are a reflection of the company’s desire to move beyond transaction-based relationships during project development into more enduring and longer term relationships. |
| Economic Inclusion | Socio-Economic Participation Plans can be designed to meet the unique social and economic needs of different Indigenous communities. | Opportunities for economic inclusion can range from provision of direct training and employment programs that build transferrable skills, to procurement of goods and services from Indigenous businesses and/or individuals that provide opportunities for contracting and business development. |
| Community-Based Agreements, Collaboration | Issues addressed through community-based agreements and/or collaborations can include:
|
Enbridge also enters into community-specific agreements or collaborations that provide a platform for developing ongoing relationships. These can take the form of a formal agreement or a special initiative which can be short- or long-term, and project-specific or relationship-based. They are usually co-designed to enable both the company and the community involved to jointly address a range of interests, needs and opportunities over time. Focus areas can include capacity building, joint goals for economic and procurement opportunities, enhanced engagement on safety issues (such as safety roundtables, emergency response training and field trips that support awareness and oversight), and/or initiatives related to cultural protection and environmental stewardship. They can also involve mediation and negotiation on specific issues such as easement renewals, as well as provide agreed-upon mechanisms for addressing grievances and/or dispute resolution. |
| Community Investment | Aligning corporate commitments to community investment with community needs and corporate priorities. | Our community investment program seeks to identify opportunities that take into account cultural norms, are participative in nature and responsive to concerns and interests expressed by Indigenous communities. These investments can be part of our consultation and engagement plans at a project or regional level. Or they can be stand-alone agreements for community investment funding that Enbridge enters into with individual Indigenous communities. |
D. Performance
Measurement and evaluation provides the basis for performance improvement. Enbridge is adopting measures that are widely used in the energy and resource sector to track and evaluate outcomes from the Company’s policies, programs and practices on Indigenous issues. They are generally a mix of quantitative and qualitative indicators. However, because the number of meetings held with Indigenous communities does not provide a measure of the quality of the relationship, this is an evolving area for us as well as other companies in our sector.
| Performance | ||
|---|---|---|
| Key Performance Areas | Key Performance Indicators | |
| 1 | Consultation and Engagement | # of interactions; # and scope of changes made as a result of input from Indigenous communities; # of agreements and/or collaborations entered into |
| 2 | Joint Activities/ Projects | Safety, cultural and environmental protection |
| 3 | Community Benefits: Training and Education | # of participants trained/ # of dollars invested |
| 4 | Community Benefits: Employment, Contracting and Business Development | # of transactions created/ # of dollars involved |
| 5 | Community Benefits: Community Investment | Investment in self-defined community development goals |
| 6 | Legal Challenges | # of legal challenges and current status |
| 7 | Documentation and Delivery | Formal commitments and agreements documented and tracked internally for delivery |
| 8 | Quality and Assurance | Key findings from management and/or 3rd party reviews to understand, assess and improve adequacy and effectiveness of outcomes |
| 9 | Development of (New) Targets and Metrics | Increased impact through improved measurement and evaluation |
E. New Practices and Innovation
Because innovation and the development of new practices are both keys to performance improvement, Enbridge pursues opportunities to work with interested Indigenous communities on new approaches. The Company is currently engaged in joint projects or initiatives with Indigenous Nations and groups residing near our projects and operations that are co-designing and testing new approaches to monitoring, water protection, employment and supply chain management across the life cycle of our assets.
| New Practices and Innovation |
|---|
| Priority Areas for Co-Designed Projects and/or Initiatives |
| Monitoring, Water Protection, Employment, Supply Chain Management |
FIGURE 1: OVERVIEW – Implementation Framework for Enbridge’s Indigenous Peoples Policy
FIGURE 1: OVERVIEW – Implementation Framework for Enbridge’s Indigenous Peoples Policy
