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|The Code for Environmental Management of Marine Mining (the Code) was adopted in 2001 by the International Marine Minerals Society (IMMS) following extensive and wide-ranging consultation, and updated in 2002. The Code provides a framework and benchmarks for development and implementation of an environmental program for a marine exploration or extraction site by marine mining companies, and for stakeholders in governments, NGOs and communities in evaluating actual and proposed applications of environmental programs at marine mining sites. The Code provides for its review by IMMS after five years, with a focus toward possible modifications based on experience with its implementation and in light of developments in the field of marine mining and associated environmental practices, in consultation with the marine mining industry and with other stakeholders at marine mining operations. As the review of the Code is now due, to begin the process, this paper will present an analysis of the Code and initial suggestions for its modification. Keywords: marine mining, marine environment, sustainable development, marine environmental risk management|