Advancing Security and Transparency for the Governance of Critical Raw Materials in Central Asia

2. Advancing Responsible Business Conduct (RBC) standards in mineral supply chains

Abstract

Governments in Central Asia have begun adopting measures to promote responsible business conduct (RBC), including policies that support the implementation of OECD standards in the mining and metals sector. Policies that enable RBC with respect to labour standards, stakeholder engagement, social and community dialogue, anti-corruption, and due diligence of mineral sourcing can help the region position itself as a trusted extraction, trade and processing hub for critical minerals.

Introduction

Central Asia has a significant mining sector and is gradually adopting measures on responsible business conduct to enhance the sector’s contribution to sustainable development. This comes against a backdrop of increasing interest among policymakers in enhancing the resilience of critical minerals value chains (see Chapter 1).

This dynamic has led to the emergence of a range of government-backed initiatives spanning blended‑finance facilities, strategic stockpiling, export and development finance, price floor mechanisms and collaboration with commodity traders, all of which will also play a role in supporting G7 Standards-based Markets for Critical Minerals. In this context, RBC has a dual purpose: in addition to ensuring the mining sector develops in sync with expectations on decent work, the environment and public integrity, it can also help the region access new investment in critical minerals from more diverse sources by supporting smoother deployment of blended finance and related government-backed initiatives.

The European Union, the United States and the United Kingdom have already established memoranda of understanding with Kazakhstan and Uzbekistan on critical minerals. In the course of recent OECD work in the region, including multi-stakeholder consultations in Kazakhstan, the Kyrgyz Republic, and Uzbekistan, a consistent finding has emerged: investors, traders, and public finance institutions will only scale up engagement where responsible business conduct, due diligence, and transparency are sufficiently robust to manage corruption, and environmental and community‑level risks that can delay, disrupt, or derail mining projects.

Central Asia therefore has an opportunity to align national policies with OECD standards already embedded in market requirements such as the London Metal Exchange’s responsible sourcing rules. The recommendations in this report represent entry points for de‑risking investment, increase eligibility for blended‑finance tools, and helping the region integrate more seamlessly into standards‑based markets.

Chapter outline

Although the mining sector in Central Asia has traditionally been dominated by domestic state-owned enterprises (SOEs), foreign public and private sector involvement has been increasing, notably in minerals like graphite in Kazakhstan, antimony in the Kyrgyz Republic or copper in Uzbekistan. This diversification has been accompanied by increased expectations for enterprises to address the adverse impacts linked to their activities, contribute to the social and economic well-being of local communities and adopt more sustainable mining practices. These expectations, which underpin a “social license to operate”, increasingly apply to the traditionally dominant SOEs, as the adoption of a number of sustainable practices are now required for obtaining international financing of major projects (Daryo.uz, 2023[1]). In this context, it is important for enterprises operating in and sourcing from the Central Asian mining sector to observe responsible business conduct (RBC) standards.

The chapter will cover three major RBC topics:

• Governance in the mining sector: this includes an overview of existing RBC policies relevant to the mining sector, as well as risks spanning corruption and anti-competitive practices.

• Labour rights: this includes government and SOE policies to promote RBC with respect to labour rights in the mining sector.

• Meaningful engagement of local communities: this includes policies of governments and practices of mining companies regarding consultation of local communities and their involvement in decision-making around mining projects to mitigate adverse social and environmental impacts of mining.

The chapter begins with an overview of RBC standards and how they intersect with institutional developments in the region, then addresses the three topics above in the context of the mining sectors in Kazakhstan, the Kyrgyz Republic and Uzbekistan followed by recommendations.

OECD standards on RBC for multinational enterprises and SOEs

The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (MNE Guidelines) are expectations by governments for how companies should address actual and potential adverse impacts of their operations, products and services, and supply chains on people, the planet and society. They apply to businesses and investors of all sectors, sizes and ownership structures, and cover all key sustainability issues – from climate change to technology, from anti-corruption to human rights and labour standards (OECD, 2023[2]). OECD standards on RBC expect companies to carry out risk-based due diligence, which consists of six steps:

• embedding responsible business conduct into their policies and management systems;

• identifying and assessing actual or potential adverse impacts on people, planet and society;

• ceasing, preventing or mitigating these impacts;

• tracking implementation and results;

• communicating how impacts are addressed; and

• providing for or co-operating in remediation of impacts when appropriate.

  Meaningful stakeholder engagement is important throughout the due diligence process, in particular when the enterprise may have caused or contributed to an adverse impact. The OECD has developed sector-specific guidance to complement and operationalise the MNE Guidelines, including the Due Diligence Guidance for Responsible Mineral Supply Chains (OECD Minerals Guidance) and the Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector (OECD Stakeholder Engagement Guidance). Like the MNE Guidelines, these documents are OECD legal instruments and are recommendations addressed by OECD members and other adhering countries to businesses operating in or from their territories. While the standards themselves are voluntary, the Minerals Guidance has been integrated into legal requirements, commodity exchange rules or other market expectations for 15 minerals and metals around the world, including for metals traded on the London Metal Exchange.

  Governments that adhere to OECD standards on RBC are also required to set up a National Contact Point (NCP) for RBC. NCPs are national agencies established by the 52 adherent governments to promote and support responsible business conduct. They raise awareness of the Guidelines, provide guidance to stakeholders, and function as a non‑judicial grievance mechanism by handling “specific instances” involving alleged non‑observance by companies. NCPs may also support their governments’ policy efforts on RBC and must operate according to OECD effectiveness criteria, including visibility, accessibility, transparency, accountability, and impartiality. Kazakhstan became an Adherent to the OECD Guidelines for Multinational Enterprises on RBC in 2017 and created an NCP (see Box 2.2).

The OECD has also developed Guidelines on Corporate Governance of State-Owned Enterprises (SOE Guidelines) (OECD, 2024[3]). SOEs often act as market shapers in mining-dominated economies. Their practices can set de facto standards for private operators and suppliers. The state’s dual role as owner and regulator, creates both opportunities (i.e. policy alignment, direct implementation of national development priorities) and risk (i.e. conflicts of interest, weakened regulatory oversight) (OECD, 2025[4]). The SOE Guidelines address the public policy rationale for state ownership, transparent governance to avoid conflicts of interest, competitive neutrality, disclosure and integrity. The 2024 update to the SOE Guidelines added provisions on sustainability across the following issues:

• adopting and communicating the state’s expectations on RBC via the ownership policy

• ensuring a strict separation between the state’s ownership and regulatory functions to avoid conflicts of interest and ensure a level playing field;

• ensuring that the board is composed of qualified, independent, and professional members with the authority and autonomy to exercise objective judgment and oversee management effectively.

• aligning sustainability reporting and disclosure with high-quality, internationally recognised standards;

• integrating sustainability considerations into SOE risk management and  internal control systems, including by conducting risk-based due diligence; and

• developing and encouraging meaningful stakeholder engagement, particularly from persons or groups that may have an interest in or could be impacted by an enterprise’s activities.

Enabling policy conditions for responsible business conduct

Governance in the mining sector

The OECD has developed tools and provided recommendations for governments to ensure better governance. Some of these are not mining-specific but are relevant to the sector. These include an independent and specialised anti-corruption body (OECD, 2025[5]) that can conduct investigations, including of SOEs; integrating RBC as part of core business decision-making for SOEs as an effective risk management tool (OECD, 2022[6]); a sound and transparent public procurement framework which ensures accessibility to public procurement processes, fair competition among suppliers, and effective monitoring of contract execution (OECD, 2025[7]); and adherence to, promotion, and monitoring of RBC instruments, such as the Guidelines for Multinational Enterprises on RBC and sectoral standards like the OECD Minerals Guidance (OECD, 2016[8]) and the OECD Stakeholder Engagement Guidance (OECD, 2017[9]). The Recommendation on the Role of Government in Promoting Responsible Business Conduct includes taking appropriate measures so that those affected by non-observance of RBC standards by companies have access to effective judicial or non-judicial remedy mechanisms (OECD, 2022[10]). OECD RBC instruments also set out due diligence expectations for companies’ supply chains, ensuring the integrity of mineral trade through companies’ sourcing decisions.

RBC expectations apply to SOEs just as they do to private enterprises and can play a particularly important role in sectors like mining where SOEs are often dominant, to the point of having quasi-regulatory functions. SOE policies on RBC can help set a good example for private enterprise peers, for example through consistent disclosure of RBC-related information and how they have conducted their due diligence (OECD, 2023[2]), in addition to environmental assessments, and the existence within SOEs of internal controls, ethics and compliance programmes to effectively prevent, detect and address corruption, especially in large SOEs where situations of conflict of interest may occur.

Box 2.1. The Extractive Industries Transparency Initiative (EITI)

The Extractive Industries Transparency Initiative (EITI) is a multi-stakeholder initiative that promotes transparency, accountability and open management of natural resources, particularly in the oil, gas and mining sector. Established in 2003, it is intended to address situations where revenues from resource extraction are lost to corruption or mismanagement.

Within the EITI, each implementing country forms a multi-stakeholder group composed of government representatives, civil society members and industry stakeholders to oversee the implementation of the EITI process. The countries produce annual EITI reports which include data on contracts, licenses, production volumes, revenue allocation and expenditures related to extractives sector.

The EITI standard, last updated in 2023, sets the criteria that countries and companies must meet to be considered as EITI-compliant: this standard was set to cover transparency through the entire value chain, from the granting of licenses and contracts to revenue collection and distribution. Countries are assessed on a scale going from “satisfactory” to “inadequate”.

Kazakhstan and the Kyrgyz Republic are EITI implementing countries.

Source: (EITI, 2025[11]) (UK EITI, 2025[12])

Labour rights

Upholding labour rights, including freedom of association and collective bargaining, is integral to responsible business conduct, including in the mining sector. According to the OECD MNE Guidelines, enterprises are expected to respect workers’ rights in line with the ILO Declaration on Fundamental Principles and Rights at Work, including the freedom of association and right to collective bargaining, the effective abolition of child labour, the elimination of all forms of forced or compulsory labour, non-discrimination in employment and occupation, and promoting a safe and healthy working environment. These principles and rights have also been developed in the form of specific rights and obligations in ILO Conventions.

Effective labour protection required that several policy frameworks be in place, starting with a clear legislative framework or government strategy on labour protection (OECD, 2025[7]), within which the government engages with businesses and trade unions, and effective dialogue between management and workers on labour, safety and employment issues takes place. Other conditions include effective grievance mechanisms to ensure fair compensation to accident victims and prevent future workplace accidents; and adequately staffed agencies with a mandate to conduct unannounced labour inspections (OECD, 2025[7]). Governments can play a role in defending these rights, and mining SOEs can set an example in upholding them.

Meaningful consultation of local communities

Meaningful stakeholder engagement is a key component of the due diligence process in the mining sector and helps prevent conflict with local communities and supply chain disruptions. In some cases, stakeholders have a right to be consulted. Clear expectations for mandatory risk assessment processes include Environmental Impact Assessments (EIA), Strategic Environmental Assessments (SEA) and Social Impact Assessments (SIA) of mining projects. For large mining projects, stakeholder engagement can take many forms including public consultations with publicly accessible outcome summaries, participating in and sharing results of on-site assessments, and ensuring a fair distribution of benefits with local communities.

Corporate and social responsibility (CSR) programmes commonly rely on philanthropic approaches to managing company-community relationships. While such activities may complement RBC efforts, they can also fall outside the scope of RBC standards and do not replace due diligence focussed on actual or potential adverse impacts an enterprise may cause, contribute to or be directly linked to through its business relationships. In certain contexts, CSR initiatives can nonetheless support community well-being, local acceptance, and risk management.

Governance in Central Asia’s mining sector

Kazakhstan is advancing RBC and minerals governance but could address corruption risks, illicit mining and high‑risk supply chains more effectively

Kazakhstan has taken steps to adopt RBC standards in recent years. It is the only country in the region to adhere to the OECD Declaration on International Investment and Multinational Enterprises and the OECD Guidelines for Multinational Enterprises on RBC (OECD, 2025[13]). Accordingly, Kazakhstan has had a National Contact Point for RBC since 2017, see Box 2.2 (OECD, 2026[14]). Kazakhstan also adhered to the OECD Council Recommendations for the OECD Minerals Guidance in 2017 and the OECD Stakeholder Engagement Guidance in 2017, as well as for the OECD Due Diligence Guidance for Responsible Business Conduct in 2018 (OECD, 2018[15]) and to the Recommendation on the Role of Government in promoting Responsible Business Conduct in 2023. In October 2024, Kazakhstan committed to developing a declaration on RBC with expectations for investors (OECD, 2025[7]).

Box 2.2. The National Contact Point (NCP) in Kazakhstan

Kazakhstan’s NCP is hosted by the Economic Research Institute under the Ministry of National Economy. The NCP has a multipartite structure, including representation from government, business, and civil society. Representatives from trade unions are called upon to participate on a case-by-case basis.

The NCP has been increasingly active since 2020. It has published the OECD Guidelines and Due Diligence Guidance on its website and has (co-)organised promotional events on RBC. It has received seven specific instances regarding alleged non-observance of the Guidelines (all in 2021-2023). Of these:

• five were not accepted for further examination;

• one was concluded without agreement as the company did not agree to participate in the NCP process; and

• one resulted in agreement between the parties.

The NCP is also playing a growing role in policy coherence on RBC in Kazakhstan For example, the NCP is also the secretariat of the National Action Plan for Business and Human Rights working group.

Source: (OECD, 2025[7]).

Kazakhstan has been a member of the EITI since 2007 (EITI, 2025[11]). In its 2025 Validation, Kazakhstan achieved a somewhat low score (56 points) in implementing the 2019 EITI Standard. The Validation noted progress for high-level public commitments to the EITI process, the establishment of a comprehensive regulatory framework for the sector, and improved transparency related to SOEs. Nonetheless, it recommended further efforts to strengthen the enabling environment for civil society participation in EITI processes and revisit broad policies on confidentiality of beneficial ownership, contract disclosure, production and exports, and signature bonuses. Kazakhstan has joined the US-led Minerals Security Partnership to boost resilience of critical mineral supply chains and participated in the launch of its successor, the Forum on Resource Geostrategic Engagement (FORGE) in February 2026 (US Dept of State, 2026[16]).

While the government has responded to instances of illegal mining, more could be done to address related risks. Kazakhstan has used remote monitoring to detect illegal mining since 2021. According to the Ministry of Digital Development and Artificial Intelligence, in 2025, satellite monitoring identified 1,845 sites of illegal subsoil use, while 2,500 cases were recorded in 2024 (The Times of Central Asia, 2025[17]; Dprom.kz, 2026[18]). According to the Ministry of Interior, as many as 4,000 illegal miners are apprehended each year (World Bank, 2023[19]). In 2026, the Ulytau regional court sentenced a man for the illegal mining and export of over 16,000 tonnes of manganese ore over three years, and related laundering of the proceeds of crime (Caspian Post, 2026[20]). A pre-trial investigation in Karaganda revealed that one enterprise in the region had been extracting iron ore without a license and illegally exporting it abroad for four years (Caspian Post, 2026[21]). Illegal operations involving foreign nationals and gold extraction are also routinely targeted by law enforcement (Tengri News, 2025[22]; Iz.ru, 2024[23]). The Subsoil Code contains certain aspects to facilitate artisanal and small-scale mining, such as simplified procedures for granting licenses and lighter requirements in terms of project documents and reclamation security, among others. Yet, coordination between regional administration and the central governments, as well as clear oversight when licences are issued is hampering actual formalisation of the sector (World Bank, 2023[19]; InBusiness.kz, 2026[24]).

Despite some progress on a range of integrity initiatives, corruption in public administration, public procurement and large-scale infrastructure remains a major concern. Kazakhstan adopted a Concept and Action Plan for 2022-26 which is monitored by the Anti-Corruption Agency, set up a whistleblower protection mechanism, and introduced mandatory corporate governance codes, bringing the country closer to international standards in many governance areas. The license allocation stage is particularly vulnerable to governance risks. In 2023, the Vice Minister of Industry and Infrastructure Development was convicted of abuse of office in connection with the illegal granting of mining rights for a nickel and cobalt deposit without competitive tendering at an artificially low price to a company affiliated with him (OECD, 2025[25]). The remaining challenges in the country’s anti-corruption framework remain closing the regulatory gaps on issues such as lobbying, conflict of interest and asset declaration, lobbying and institutional independence, as well as moving beyond legal reform to implementation (OECD, 2025[5]; OECD, 2024[26]).

Enterprises sourcing from or operating in Kazakhstan have adopted RBC policies or undergone assurance processes. Some large mining companies have begun to implement supply chain due diligence in line with OECD standards. Kazzinc, a major integrated zinc producer with significant production of copper, gold, silver, zinc and lead, has been successfully assessed by the Copper Mark against the Joint Due Diligence Standard for Copper, Lead, Molybdenum, Nickel, and Zinc (JDDS) in 2023. The JDDS itself has been recognized by the London Metal Exchange as an accepted audit programme for meeting the LME’s responsible sourcing requirements. Kazzinc is also a Good Delivery Refiner for both gold and silver under the London Bullion Market Association (LBMA) responsible sourcing audit programme (Kazzinc, 2025[27]). The silver refinery Kazakhmys is also included in the LBMA Good Delivery List for silver and has introduced a KPMG-designed ESG roadmap including tailings-water recirculation and mandatory mine-ventilation upgrades (agmp.kz, 2024[28]). The Ulba Metallurgical Plant, a significant smelter of tantalum, niobium and beryllium, is among the Responsible Minerals Initiative's Conformant Tantalum Smelters. Metalkol’s smelting operations in the Democratic Republic of the Congo belonging to the Kazakh-owned Eurasian Resources Group (ERG) have successfully been audited by the Responsible Minerals Initiative, and its tailings reprocessing operation underwent The Copper Mark assurance process. ERG’s activities in the DRC were extended in early 2026 to cooperation with SOE Entreprise Générale de Cobalt to cover formalisation of artisanal and small-scale mining (Omirgazy, 2026[29]). Deploying the capital and know-how of a large-scale mining firm to connect informal supply into legitimate trading channels through progressive formalisation and risk mitigation could help set an example for similar initiatives to further diversify supply chains.

However, allegations concerning Kazakh companies continue to be reported. ERG has been subject to allegations of non-compliance with local subcontracting laws (Autorité de Régulation de la Sous-traitance dans le secteur Privé, 2024[30]), environmental pollution (Njini and Rolley, 2023[31]), corruption (Kotkamp, 2025[32]) and disputes over mining project development in the DRC (Africa Mining Intelligence, 2024[33]). The company has variously denied its involvement in environmental damage and disputed NGO claims of poor labour practices, while reaching a settlement and compensation with regulators on mining project development (Reuters, 2025[34]) and local subcontracting (Actualité.co, 2024[35]). The recent increase in tantalum imports from Central African countries into Kazakhstan has drawn attention, particularly in light of the fact that many tantalum-producing areas in the DRC have been affected by the expansion of the M23 rebel group during 2023-2025 (OECD, 2025[36]). More broadly, despite longstanding concerns about structural under-reporting of tantalum originating from the DRC and Rwanda, no significant market disruption has been observed following the escalation of conflict in producing areas. This may indicate that production from areas controlled by non-state armed groups continues to reach international markets through established processing hubs.

While Kazakhstan’s mining sector is somewhat open to foreign investment, it is dominated by SOEs, in particular by Tau-Ken Samruk, created in 2009 and controlled by the Samruk-Kazyna National Welfare Fund. Until recently, Tau-Ken Samruk enjoyed priority over private companies for acquisition of subsoil rights. Privately-owned enterprises with significant state participation, such as ERG and Kazzinc, also tend to be favoured. In Kazakhstan, some ministries with ownership functions are also regulators of their respective sectors: this entails a high risk of conflict of interest, as ministers can hold positions in companies they are responsible for regulating, as well as a high risk of unfair competition practices as state actors may favour domestic incumbents over junior companies or foreign investors. Kazakhstan’s EITI membership helped advance transparency in the use of mining revenues by the National Fund of the Republic of Kazakhstan, but the scope for discussion between the government, business and civil society on mining sector issues has reportedly decreased in recent years (World Bank, 2023[37]).

The Kazakh government has embarked on a substantial reform efforts aimed at enhancing the governance and performance of SOEs, but the reform plans can benefit from continued commitment to ensure their implementation. The government could remove regulatory functions from ministries that exercise shareholder rights in SOEs or shift their ownership functions out of the ministries. The development of a unified ownership entity would support informed and active state ownership, and more effective oversight of entities like Samruk-Kazyna. The majority composition of boards by government officials raises concerns about objective decision-making and the need for professionalised, independent and autonomous boards (OECD, 2024[38]). Given the risks linked to gold and tantalum supply chains, there is a need to enhance due diligence of mineral sourcing from third countries to mitigate conflict financing risks, for example through increased scrutiny of refiner due diligence audits.

The government of the Kyrgyz Republic is initiating steps to advance RBC, but increased state participation has undermined the transparency of the mining sector

RBC implementation in the Kyrgyz Republic remains at an early stage, although recent policy initiatives signal growing recognition of its importance. There are only a few examples of human rights-related corporate policies in the country. Such policies are often developed based on documents from manuals or on similar experience from other enterprises. In the mining sector, the Kyrgyz Republic was an early adopter of the EITI, and it discloses detailed data on production, revenues and license holders, but its latest EITI validation in 2024 rated overall implementation as “fairly low” (57.5 points) under the 2019 Standard, with weaknesses in outcomes, impact and stakeholder engagement (EITI, 2024[39]). In its new Strategic Development Programme for Critical Minerals through 2030, the government aims to achieve a “high” EITI rating in the mid-term through more transparent reporting. Enterprises are not widely observed to conduct assessments of the impact of their activities on human rights (UNDP, 2024[40]). Under the Law on the Subsoil, a social package is included in the project impact assessment and approval process; however, its requirements are not clearly specified, and measures to mitigate the socioeconomic impacts of projects are not delineated (International Institute for Sustainable Development, 2018[41]).

Although the Kyrgyz Republic has established formal anti-corruption frameworks such as the National Anti-Corruption Strategy 2021–24 and related agency plans, implementation remains uneven, with gaps in areas such as conflict of interest enforcement and whistleblower protections, while recent legislative changes have undermined transparency efforts (OECD, 2024[42]). The mining sector is exposed to corruption risks. In 2025, a former Minister of Natural Resources was sentenced to eight years in prison for abuse of office through an entity financed by mining company Kumtor’s profits and tasked with supporting environmental projects (The Diplomat, 2025[43]).

Licensing for artisanal and small-scale gold mining (ASGM) production is currently suspended, with only 21 individual licenses active despite an estimated 25,000-75,000 people working in the sector. The Kyrgyz Republic never ratified the Minamata Convention1, a concern considering the significant production of mercury in the country. The gold buying sector was liberalised in 2015 and around 40 operators (mainly jewellers and dentists) are licensed to process unrefined gold for domestic use. While it is difficult to obtain exact data, internal purchases amount to an estimated 2.5 tonnes of unrefined gold, indicating a non-negligible level of activity. Discrepancies between declared jewellery production and suspiciously high related scrap (which is reportedly exempt from tax) also merit additional scrutiny. According to expert interviews, despite allegations regarding Russian gold transiting through the country, the mineral trafficking cases prosecuted by the Kyrgyz Republic only involved neighbouring countries. Nevertheless, the discrepancy in the reported value of non-monetary gold trade between the Kyrgyz Republic’ declared exports and partner-reported imports reached USD 4 billion in 2024 (UN Comtrade, 2026[44]). While Comtrade data are subject to limitations, such as reporting lags, differences in national customs classifications, and the exclusion or separate treatment of certain transactions such as monetary gold, these discrepancies point to the need for further scrutiny.

State influence on the Kyrgyz Republic’s mining sector has significantly increased since the nationalisation of the Kumtor gold mine in 2022. This has led to a decline in the sector’s transparency, making major international mining companies reluctant to invest (World Bank, 2022[45]). Nevertheless, the Kyrgyz Republic’s membership in the EITI allows for wide disclosure of information on the impacts of mining. Kyrgyzaltyn is the main SOE active in mining and refining, which operates mines directly or in joint venture with Chinese and Turkish companies. Kyrgyzaltyn’s gold refinery is audited annually by the LBMA and has been reinstated on the Good Delivery List after it was suspended for failures related to its responsible sourcing programme.

The government could consider progressively raising awareness and promoting the implementation of relevant OECD RBC standards, such as the OECD Guidelines for Multinational Enterprises for Responsible Business Conduct and the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas.

Uzbekistan is strengthening RBC and anti-corruption frameworks; however, it must further tackle corruption risks, supply chain due diligence gaps and transparency shortcomings

RBC considerations are increasingly important in Uzbekistan’s policy agenda. Uzbekistan recently applied for adherence to the OECD Declaration on International Investment and Multinational Enterprises (Ministry of Investment, Industry and Trade of the Republic of Uzbekistan, 2026[46]). The overall awareness of RBC is also growing in Uzbekistan, with both government and businesses working towards promoting RBC through regular events and financing. The government committed to adopt a National Action Plan on Business and Human Rights, which presents an opportunity to promote RBC in the mining sector (OECD, 2025[7]). A high-level working group on RBC has been created under the Foreign Investors Council, and the government is encouraging sustainability risk management in SOEs (OECD, 2025[7]).

The fight against corruption has intensified in recent years, notably with the creation of a dedicated anti-corruption agency in 2020 and the strengthening of SOE governance through the establishment of a merit-based selection system for board and leadership appointments. The Uzbekistan 2030 Strategy includes government commitments to reduce adverse impacts of business operations such as corruption. As corruption remains a significant risk for potential investors, public institutions in the mining sector are paying increased attention to the issue, with Navoi MMC and the Ministry of Mining Industry and Geology scoring the highest in a ranking of corruption prevention mechanisms by the Anti-Corruption Agency (Qalampir, 2025[47]). The largest mining SOEs, Almalyk MMC (AMMC), Navoi MMC (NMMC) and NavoiUran, have adopted the International Financial Reporting Standards for their financial statements (ESG Foundation, 2025[48]).

Nevertheless, while corruption incidents in mining are rarely reported, perceptions of corruption persist (Anti-Corruption Agency of the Republic of Uzbekistan, 2023[49]). Investigative journalists found that AMMC awarded over $200 million in procurement contracts since 2022 to a network of companies incorporated in the United Kingdom, Georgia, and Singapore, many of which have unclear or seemingly inactive corporate records and are linked through common individuals, including an Uzbek table tennis official and others with no mining experience, raising questions about whether these are shell companies for proxies benefiting from political connections rather than legitimate suppliers (OCCRP, 2026[50]). Investigations such as these were enabled by Uzbekistan’s procurement transparency reforms, highlighting how greater openness has given a potential boost to accountability. The application of the recently enacted legislation on conflict of interest is also seen as central to mitigating some of these risks in practice (OECD, 2024[51]) (OECD, 2025[7]). Unlike Kazakhstan and the Kyrgyz Republic, Uzbekistan is not an EITI member, but it is exploring the potential for membership (UzDaily, 2025[52]).

At the enterprise level, some Uzbek mining and metallurgical companies, also dedicated to processing and smelting, are voluntarily aligning with global sustainability benchmarks: NMMC has begun publishing sustainability reports in 2019, and it became the first Uzbek mining company to obtain an independent ESG rating in 2025 (Minex Forum, 2025[53]). NMMC has also designed roadmaps for the integration of the Responsible Gold Mining Principles and the International Code for Cyanides Management with the help of independent consultants. Both AMMC and NMMC started providing publicly accessible non-financial reporting, notably on workplace accidents. Both AMMC and NMMC hold the Good Delivery List Status at the London Bullion Market Association (LBMA) (London Bullion Market Association, 2026[54]).

Concerns have been raised on the possibility that sanctioned Russian gold is entering jurisdictions such as Switzerland or the United Kingdom, which have imposed sanctions, via countries in Central Asia such as Uzbekistan and Kazakhstan (Turuban and Soguel, 2024[55]). The Central Bank of Uzbekistan has rejected these allegations and underlined that the country did not purchase gold from abroad (Kun.uz, 2025[56]). Uzbekistan recognised artisanal mining in its legal framework in 2019, subject to licensing, and increased sanctions for illegal mining in 2024 introducing criminal responsibility for unauthorised extraction of minerals that is committed repeatedly after prior administrative penalties or for artisanal mining without proper permits. (The Times of Central Asia, 2024[57]; Kun.Uz, 2024[58]).

In 2024, AMMC underwent a CopperMark assessment of several RBC social and environmental criteria. The assessment identified partial gaps in a range of areas, including stakeholder engagement, business partner relationships, working hours, employee grievance mechanisms, biodiversity and protected areas, mine closure and reclamation, community health and safety, human rights, land acquisition and resettlement, cultural heritage, and, notably, significant gaps in due diligence in mineral supply chains (The CopperMark, 2026[59]).

AMMC is currently addressing these gaps, including on the development of better systems and processes for due diligence of their supply chain. The main gaps relate to how the company identifies high-risk suppliers in countries of origin or transit. The assessment reported that AMMC’s copper suppliers are traders, highlighting the need of enhanced checks to identify countries of origin and transit and address any related risks.

Uzbekistan could promote the implementation of relevant OECD RBC standards, as well as the EITI. This would allow better visibility on mineral flows (and potentially related illicit financial flows), enhanced transparency for investors and better dialogue with different stakeholders in the mining sector. Ongoing governance reforms and board professionalisation of SOEs are an emerging good practice but should be sustained and amplified.

Labour rights

Labour safety is a long-standing issue in Kazakhstan, which the government is beginning to address

Recent revisions to Kazakhstan’s labour code improved the country’s labour rights framework, but gaps persist. The current legislation integrates a wide range of provisions to guarantee the safety of life and health of employees. It also includes provisions for the training of personnel on occupation health and safety measures (World Bank, 2023[37]). However, significant concerns remain regarding the effective protection of workers’ rights, especially for migrant workers, who face heightened risks of discrimination, wage theft, harassment, and coercive labour practices (Global Detention Project, 2025[60]). Collective bargaining and the right to strike are not guaranteed (Human Rights Watch, 2025[61]), while the country has yet to ratify ILO Convention No. 190, a treaty aimed at safeguarding workers against violence and harassment (ILO, 2026[62]). Between2021 and 2022, the number of appeals on labour rights violations grew from 53 to 288.

Kazakh trade union representatives claim that the official statistics on the mining industry underestimate the number of accidents (World Bank, 2023[37]). Kazakhstan’s mining sector has continued to record industrial accidents and fatalities linked to poor labour conditions. According to the prosecutor for the East Kazakhstan region, between 2019 and 2022 174 of the 688 accidents in the region occurred in mining companies, resulting in 66 fatalities (Sergienko, 2022[63]). In 2023, 46 miners died following a methane gas explosion at the Kostenko coal mine in Temirtau, where workers had long demanded better working conditions (The Diplomat, 2023[64]). The mine, which was operated by ArcelorMittal at the time, was subsequently nationalised (RFI, 2023[65]). Conflicts linked to labour conditions have erupted in other Kazakh mines as well (Vlast.kz, 2025[66]). In 2024, 43 labour abuse allegations were recorded in Kazakh mines: occupational health and safety issues accounted for 22 allegations. These included 14 workplace death cases, eight of which were caused by one accident at the Karaganda ferroalloy plant. The copper industry faced 21 allegations linked to copper mining sites, 11 of which targeted the copper giant Kazakhmys; several Kazakhmys mines were also the subject of protests and strikes due to unpaid or underpaid wages, as well as poor labour conditions (Business and Human Rights Resource Centre, 2025[67]).

The government is stepping up efforts to improve working conditions. It recently adopted the 2024-2030 Concept of Safe Labour to improve working conditions and reduce workplace accidents, most of which occur in mining and construction. As further steps, the government could consider strengthening labour protections in the mining sector by enhancing overall safety oversight, promoting transparency around incident reporting, and providing the inspection authorities with adequate capacity and a clear mandate allowing unannounced inspections. Providing clearer minimum requirements for operational safety measures, supported by proportionate enforcement, would help to improve safety outcomes. In parallel, making complaint and grievance mechanisms more accessible and effective, including in the local languages spoken by affected workers and communities, would ensure that concerns can be raised safely.

The government of the Kyrgyz Republic supports local employment in mining but needs to strengthen labour rights protection

Accidents in the Kyrgyz mining sector result in 10-15 deaths per year (World Bank, 2023[68]). Under Kyrgyz labour legislation, employers – including mining companies – are required to take comprehensive measures to safeguard the life and health of employees while performing their duties. The existing grievance mechanism is reported to be ineffective due to bureaucratic complexity and a perceived lack of interest from officials. Chinese companies operating in the Kyrgyz Republic have frequently been accused of discriminatory employment practices towards Kyrgyz workers (World Bank, 2023[68]). The 2022 reform mandating all mining projects to employ 90% of Kyrgyz workers is also reported challenging to comply with during the design and construction stages. In its new Critical Minerals Programme, the government recognises that this provision has also limited the talent pool in the mining sector. Despite this fact, the Programme targets to create 30,000 new jobs in CRM mining by 2040.

The Kyrgyz Republic could also consider strengthening the existing grievance mechanisms and providing its labour inspection body with greater capacities and a clear mandate to carry out unannounced inspections.

Uzbekistan is improving its labour standards, but gaps remain in health, safety, freedom of association and gender equality

Uzbekistan’s labour rights framework has improved, but challenges remain. Uzbekistan has acceded to several ILO conventions in recent years, and the labour code was substantially updated in 2023. The government increased financing for labour inspections and installed digital safety monitoring systems in mines. However, limited freedom of association remains an issue. The threshold for forming a union stands at 3 000 workers, limiting this possibility for many occupations; moreover, operating a union independently from the Federation of Trade Unions of Uzbekistan remains difficult. Gender equality also remains a significant challenge, the gender pay gap being as high as 39% in 2024 (compared to 20% in Kazakhstan) (OECD, 2025[7]). The number of abuse allegations has increased in Uzbekistan’s mining sector, though the meaning of this is hard to interpret: it may be a result of greater willingness to report, as opposed to increasing instances (Business and Human Rights Resource Centre, 2025[67]). In the first six months of 2024, 728 violations of health and safety measures were recorded by Uzbek authorities at AMMC plants. AMMC, the country’s second-largest mining SOE in terms of revenue, has a substantial record of abuse allegations and fatal workplace accidents.

The government could continue reforming its labour rights framework by easing the restrictions on trade union organisation and making it easier for trade unions to operate outside the Federation of Trade Unions of Uzbekistan. Finally, the authorities could consider enhancing the involvement of different stakeholders, including independent NGOs, in deliberations about mining projects, to better assess the potential risks and impacts of mining projects.

Meaningful engagement of local communities

Local community engagement is required by law in Kazakhstan, but transparency is lacking on decision-making and compensation

The participation of local communities in mining projects in Kazakhstan is ensured by the Environmental Code and the Code on Subsoil and Subsoil Use (hereinafter “SSU Code”). The Environmental Code requires any project with environmental impact (including mines) to undergo comprehensive Environmental Impact Assessments (EIA) with at least 30 days of public consultations and outlines general provisions for community consultations, notably through the Rules for Conducting Public Hearings. Local communities should be informed about the localisation of the project as well as about all the modalities of the public hearings. The SSU Code mandates the participation of local executive and environmental bodies to all the stages of the EIA process. Local authorities are required to publish the minutes and recordings of public hearings on their website, and the comments and suggestions made during the hearings are to be taken into account by the competent authority conducting the EIA.

Nevertheless, civil society actors report that many EIAs are not fully disclosed or are hard to access on frequently changing government websites (World Bank, 2023[19]). Local authorities often do not have the capacity to conduct public hearings and fail to provide hearing records to the public, while companies often under-advertise public hearings, schedule hearings during working hours, do not take into account the comments made during the hearings, and provide incomplete or unclear information (World Bank, 2023[37]). Moreover, enforcement agencies often lack capacity or will, resulting in inconsistent application of penalties. For instance, high environmental fines exist on paper but have rarely been used effectively, reducing their deterrent effect (OECD, 2025[7]).

The SSU Code states that if a mining project is located 1 km or less away from a settlement, the project initiator must enter into a Community Development Agreement with local government bodies and establish measures to support the affected population. However, the current legislation does not specify the measures that should be considered for economic and social support to these populations, and the absence of a standard form of such an agreement impedes adequate assistance. The Community Development Agreements are concluded between companies and the local government bodies (akimats), often without the participation of local communities as such; this has led to non-transparent expenditures of social contributions from companies to akimats, while akimats themselves often tend to spend these funds with limited accountability to the local communities and, critics claim, use the funds outside of their intended purpose. As the amount of social contributions is determined by the akimats, this raises corruption risks and may incentivise the satisfaction of immediate financial needs. Meanwhile, the absence of local communities during the negotiation process can lead to agreements which neglect labour and environmental impacts of mining projects (World Bank, 2023[37]) (Business and Human Rights Centre, 2024[69]).

There is no formal obligation to carry out Social Impact Assessments and there are no clear guidelines for compensating or resettling communities affected by mining projects, which can lead to conflicts, unreasonable compensation demands, or community grievances (Business and Human Rights Centre, 2024[69]). Community benefit agreements are informal – mining companies contribute 1-2% of project costs to local budgets by law, but this process lacks transparency and there have been complaints from communities about where the money goes (World Bank, 2023[37]).

While victims of adverse impacts are increasingly turning to Kazakhstan’s NCP, other non-judicial grievance mechanisms are also available. The 2011 Law on Mediation offers avenues for protection and redress in cases involving violations of human rights and freedoms. Although mediation is not mandatory in legal proceedings, courts strongly encourage parties to attempt mediation before pursuing litigation. At the individual firm level, most large companies report having mechanisms in place to receive and address grievances. However, according to the National Baseline Assessment conducted under the NAP BHR, only about half of surveyed companies publicly provide information on their grievance mechanisms. Public commitments to remediate adverse impacts are rare, and few companies disclose clear information on the procedures governing how grievances are handled. (OECD, 2025[7]).

The government could consider requiring mining companies to take into account the results of public hearings and to provide an explanation in case of refusal to implement a suggestion made during the hearing. The government could consider more support for local government bodies for them to be able to organise regular public consultations and provide full accessibility to the relevant documentation. Finally, the government could consider involving local communities and relevant NGOs during the negotiations on Community Development Agreements, which would permit a more transparent allocation of social contributions.

The Kyrgyz Republic has a well-established community involvement framework for mining projects, but its perceived ineffectiveness undermines stakeholder trust

The Kyrgyz Republic has a record of involving local communities in mining process, although it has been less pronounced in recent years. The introduction of social package agreements in 2012, which mandated subsoil users to reach an understanding with local self-government bodies over mining projects, was an important step forward in terms of local community involvement into mining. The introduction of these agreements also led mining companies to be more involved into social and economic projects aimed at improving the living conditions of local communities, such as educational training, infrastructure projects and employment (World Bank, 2023[68]). The government has reportedly demanded specific requirements from large investors, such as quotas on local employment and seats on the boards of directors (U.S. Department of State, 2025[70]). The new Strategic Development Programme for Critical Minerals mandates social impact assessments (SIA) for mining projects. However, some Kyrgyz NGOs claim that the government has tried to weaken civil society and tighten its grip on the mining sector in recent years, resulting in less dialogue between mining companies and communities: civil society representatives fear that the consultation processes might be emptied of their substance by the government if it decides to conclude major new mining projects (PWYP Kyrgyzstan, 2024[71]).

Local communities appear to be wary of foreign mining companies, which are seen as exploitative, while trust in public officials is also low (World Bank, 2023[68]). Integrity mechanisms are not well defined in the current legislation, and relevant laws are reported to not work in practice (World Bank, 2023[68]). There exists a widespread belief that government bodies grant licenses and permits to foreign companies through corrupt practices, while not sharing mining revenues with the local population. Conflicts between local communities and Chinese companies have been frequent in recent years, with the companies accused of corruption and lack of transparency (World Bank, 2023[68]; Furstenberg, 2021[72]).

Overall, concerns remain that local communities are excluded from discussions on mining projects: although they can communicate with mining companies through village councils, citizens complain that companies use legal ways to avoid fulfilling their promises and to ignore the local communities’ proposals. The dialogue with the government is also unsatisfactory, as it lacks regularity and often involves a small number of activists, without considering the larger communities. Beyond the social package agreements, community development agreements exist only between large mining companies and public authorities, which creates opportunities for corruption and revenue misuse. Companies are also reported to only hold regular public hearings in the early stages of mining projects to obtain a “social license” to operate from the local population and then consult exclusively with public authorities during the following stages (World Bank, 2023[68]).

The Kyrgyz Republic provides for public participation in the Environmental Impact Assessment (EIA) process. According to current legislation, any member of the public can request a public review of the process. This public review, although it should be self-funded and should not take longer than a month, provides local communities and NGOs with a platform for comments, suggestions and inputs. However, the public review is only advisory, the state having no other obligation besides publicly acknowledging that it has occurred. In addition, there is no public record of any mining project in the Kyrgyz Republic not being approved as a result of an EIA (World Bank, 2023[68]).

Several companies operating in the Kyrgyz mining sector have developed Corporate Social Responsibility (CSR) programmes aimed at improving the well-being of local communities and revitalising local economies. The SOE operating the Kumtor mine has developed a programme revolving around the development of local agriculture, the support for SME growth, the collaboration with young people for the development of local educational initiatives, and the protection of the local environment (World Bank, 2023[68]). Among foreign investors, the Turkish Eti Bakir which operates the Tereksay gold mine has also developed an ambitious programme of water resources, flora and fauna protection, while getting involved in the social life of the local community: the company is currently financing the construction of a new school which will host 225 students.

The government could consider ensuring a regular public dialogue between local communities and local public authorities on mining projects, as well as involving local communities into community development agreements with large mining companies. The government could also consider ensuring that mining companies continue the dialogue with local communities beyond the early stages of mining projects, and enforcing penalties if companies fail to do so. Finally, the government could consider extending the one-month-deadline for submitting the EIA public review and making the results of this public review mandatory.

Local community involvement in Uzbekistan’s mining projects remains limited, despite recent progress

Traditionally, local communities in Uzbekistan have had little voice in decision-making for mining projects, given the centralised decision-making and limited civic space. However, laws such as the Law on Environmental Impact Assessments mandate early consultations for high-risk projects. Similarly, the new Law on the Subsoil explicitly requires public consultation prior to the commencement of mining projects. In practice, stakeholders report that consultations are not always carried out, and current regulations do not ensure stakeholder engagement in line with international standards, such as participatory monitoring (OECD, 2025[7]).

The new law on Environmental Expertise, which entered into force in 2025, provides for public consultations during the environmental assessment stage of mining projects (under the name of “Public Environmental Expertise”); however, these public hearings only serve a consultative purpose, without any obligation for the state to take their results into account (Lex.uz, 2025[73]). There is no publicly available record of recent local community backlash against any mining project: some wariness may be observed towards Chinese gold mining companies investing in Uzbekistan, but it remains largely confined to the online sphere, without any repercussions on the ground (Global Voices, 2025[74]).

While Uzbekistan does not have a dedicated grievance mechanism specifically for RBC issues, the Ombudsman plays an important role in remedying violations. In 2025, the Ombudsman received 26,372 appeals. (Uzbekistan Authorized Person of the Oliy Majlis for Human Rights, 2026[75]) State-owned enterprises, like other public institutions, are legally required to establish complaint mechanisms, and some provide public information on how they handle complaints. By contrast, grievance mechanisms appear to be less systematically established and disclosed among private commercial enterprises (OECD, 2025[7]).

The government could consider making the Public Environmental Expertise results mandatory for consideration during the environmental assessment process. The government could also consider introducing some mechanisms of public dialogue between mining companies, local public authorities and local communities around mining projects, which would allow for better information about the projects’ risks and potential impacts and better consideration of local communities’ needs.

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[22] Tengri News (2025), Gang involving 19 foreign nationals detained in East Kazakhstan, https://en.tengrinews.kz/kazakhstan_news/gang-involving-19-foreign-nationals-detained-in-east-269398/.

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[55] Turuban, P. and D. Soguel (2024), “Sanctions enforcement: Bern ‘cannot rule out’ Switzerland gets Russian gold via Central Asia”, Swissinfo, https://www.swissinfo.ch/eng/swiss-politics/sanctions-enforcement-bern-cannot-rule-out-switzerland-gets-russian-gold-via-central-asia/88498901 (accessed on  January 2026).

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[12] UK EITI (2025), What is EITI?, https://www.ukeiti.org/what-eiti (accessed on 2 September 2025).

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[19] World Bank (2023), Mining sector diagnostic - Kazakhstan, https://documents.worldbank.org/en/publication/documents-reports/documentdetail/099081823001539573 (accessed on 9 January 2026).

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[45] World Bank (2022), Kyrgyz Republic Mining Policy Note, https://documents1.worldbank.org/curated/en/099081623044037394/pdf/P17582907073f002087b000c68f70d8da6.pdf.

Note

← 1.  The Minamata Convention on Mercury is a global treaty aimed at protecting human health and the environment from the adverse impacts of mercury pollution. It was adopted in 2013 and entered into force in 2017.