…MiningWatch believes a credible independent review is critical in this case and should be undertaken as soon as possible…A key concern…remains the...withholding of individual remedy unless the Porgera rape victims are willing to provide Barrick with immunity from future civil suits…While we welcome your opinion that the presumption should be against [legal] waivers [in non-judicial grievance mechanisms], the phrase “as far as possible” creates ambiguity...Barrick was in breach of Guiding Principle 31 in developing the framework and...inclusion of the perspectives of victims [and other groups] might have prevented some of the breaches...[refers to Porgera Joint Venture]