International Cyanide Management Institute Suspends Two Auditors and an Audit Firm from Participation in Cyanide Code Audits

The International Cyanide Management Institute (ICMI) today announced that it has suspended two auditors and an audit firm from participation in Cyanide Code audits for failure to complete an audit within the prescribed deadline, failure to submit an Auditor Credential Form by a prescribed deadline, and submission of notarized Auditor Credential Forms misrepresenting an auditor’s experience.

Cyanide Code audits of signatory operations must be conducted by independent, third-party auditors that must meet certain requirements established by ICMI.  The operations contract directly with the auditors, and ICMI is not a party to negotiations or the contract.  While ICMI is not a party to the negotiations nor the contract, it does determine which auditors are acceptable to perform audits.  Auditors performing a Cyanide Code audit are required to furnish an Auditor Credentials Form with the final audit documents submitted to ICMI, stating experience, expertise and the absence of conflicts of interest.  The form must be signed and notarized and include an attestation by the auditor as to its accuracy.

In August, ICMI was contacted by a mining operation regarding difficulty it had encountered with the auditors it contracted for a Cyanide Code audit of that operation.  The operation contracted with ISOSURE, a consulting firm in Lima, Peru to perform the audit.  Two auditors from ISOSURE, Mr. Luis Torres Argandona and Mr. Carlo Vargas Bolivar, visited the mine in December 2017 to conduct the necessary site inspection.  According to the mine’s management, the auditors did not submit to them the completed audit report and have failed to respond to repeated inquiries from the company about the status of the audit.  Similarly, ICMI’s attempts to reach the auditors and the audit firm by email, couriered letter, and telephone were not successful.  As more than nine months have now passed since completion of the site inspection portion of the audit, ICMI would not accept the audit report if it were submitted leaving the company in the position of beginning the process anew.

Compounding this problem is the failure of ISOSURE to furnish an Auditor Credentials Form for another audit that was conducted in March 2018, which has delayed the finalization of that operation’s certification.  Although the finalized audit report includes the necessary auditor signatures and statements regarding auditor qualifications, a hard copy of the Auditor Credentials Form was not included with the finalized reports sent by the auditors.  ICMI’s attempts to contact ISOSURE and the lead auditor for that audit, Mr. Vargas, regarding this matter have been unsuccessful.

Further, several notarized Auditor Credentials Forms submitted earlier this year by Luis Torres Argandona appear to incorrectly state that he participated in a Quality, Environmental, and Safety Management Systems audit at a particular mine.  The mine’s management has informed ICMI that no such audit was conducted.  As noted earlier, lead auditors attest to the accuracy of the information contained in the Auditor Credentials Form, and misstated or false information can potentially erode stakeholder confidence in the Cyanide Code program.

Given the above described circumstances, ICMI has indefinitely suspended Mr. Luis Torres Argandona and Mr. Carlo Vargas Bolivar, and the firm ISOSURE S.A.C., from performing any Cyanide Code audits.

The Cyanide Code is a voluntary industry program for companies involved in the production of gold and/or silver using cyanide and companies producing and transporting this cyanide.  It was developed under the aegis of the United Nations Environment Programme by a multi-stakeholder Steering Committee.  The Cyanide Code is intended to complement an operation’s existing obligation to comply with the applicable laws and regulations of the political jurisdictions in which the operation is located.

ICMI has been established to administer the Cyanide Code, promote its adoption, evaluate its implementation, and manage the certification process.  A detailed list of the operations covered by signatory companies’ applications, along with the full text of the Cyanide Code and its implementing and administrative documents, are available at

Tuesday, October 23, 2018