Critical minerals in Africa

3. Responsible business conduct to support strategic investment

3.1. Persisting challenges are increasingly met with regional responses

The relationship between RBC and conflict prevention has become a defining feature of mineral governance since the early 2000s, with a strong connection to mining governance on the African continent. The Kimberley Process Certification Scheme (2003) was a landmark in preventing the financing of armed groups through trade of conflict diamonds. Its success inspired similar models in other minerals. The International Conference on the Great Lakes Region (ICGLR) regional protocol again the illegal exploitation of natural resources is another testimony to the continent’s acknowledgment of the need to address the persistent connection between mineral production and trade and risks of conflict financing, serious abuses of human rights and serious economic crimes.

In consuming markets, the United States’ Dodd-Frank Act (Section 1502, 2010) and the European Union’s Conflict Minerals Regulation (2017) expanded the regulatory landscape by introducing mandatory due diligence and traceability obligations across mineral supply chains, particularly for tin, tungsten, tantalum, and gold. More recent legislation – the European Union’s Corporate Sustainability Reporting Directive (CSRD, 2024) and the Corporate Sustainability Due Diligence Directive (CSDDD, 2024) – reflects a new era of convergence between sustainability and human rights law. Together, these measures compel companies to identify, prevent, and mitigate adverse human rights and environmental impacts throughout their operations and value chains.

However, applying such frameworks in fragile African contexts remains extremely challenging. ASM is a vital source of livelihood for millions but is often informal, underregulated, and vulnerable to exploitation by armed actors. When implemented through overly strict compliance approaches, due diligence and traceability requirements can inadvertently exclude artisanal producers, depriving communities of income and pushing trade underground.

3.2. Labour and human rights

Labour and human rights challenges such as child labour, unsafe conditions, and gender discrimination continue to undermine responsible mining in Africa, particularly in ASM communities. In response, a range of international, national, and community-based initiatives have emerged, including International Labour Organisation (ILO) programmes to eliminate child labour, UNICEF- and industry-backed funds in the DRC to support education and alternative livelihoods, and advocacy efforts to strengthen women’s participation and protection. Similar interventions across countries such as Ghana, Tanzania, and Côte d’Ivoire combine formalisation, labour inspections, education support, and local monitoring, reinforced by regional and multi-stakeholder responsible sourcing initiatives. While these efforts signal growing commitment, their impact is constrained by weak enforcement, inconsistent funding, and persistent poverty, highlighting the need for long-term structural reforms focused on education, livelihoods, and stronger local governance.

3.3. Environmental challenges

While most environmental issues linked to mining are common across all mining jurisdictions, there are several issues that are particularly acute or distinctive in the African context. These aspects include in particular mining in protected areas or biodiversity hotspots, water scarcity aggravated by mining’s high demand for water, and a history of poor mine closure and rehabilitation.

Mining in protected areas. Mine development is increasingly taking place within protected areas in Africa, due to undeveloped legal frameworks, insufficient government enforcement capacity, and corruption in issuing mining permits (Beevers, 2015[83]). Removing restrictions on protected land through downgrading, downsizing, and degazetting protected areas are keyways in which this is done. For example, the boundaries of the Selous (now Nyerere) Game Reserve in Tanzania, a UNESCO World Heritage site, were amended in 2012 to allow uranium mining in a wildlife corridor between Tanzania and Mozambique (McKee, 2012[84]). Similarly, a number of Namibia’s most notable uranium mines are located either within or close to the Namib-Naukluft National Park (El Obeid, 2021[85]). While the challenge of extractive projects within natural World Heritage sites is a global issue, Africa has a greater occurrence of this than any other region, with some 45% of African sites exposed to extractive projects (UNESCO; Church of England Pensions Board; Greenbank; International Union for Conservation of Nature; World Wide Fund for Nature, 2025[86]). Evidence suggests that mining areas in sub-Saharan African countries have 47.5% higher rates of deforestation than non-mining areas (Ahmed et al., 2025[87]). The indirect deforestation to make way for mining communities to live is 28 times larger than the area cleared directly for mining (Ladewig et al., 2024[88]). Illegal land grabs also become a prevalent issue in the wake of mineral deposits being identified. Among African countries, Ghana has the highest rate of mining-related deforestation on the continent (Stanimirova et al., 2024[89]).

Water scarcity. Mining operations have high water consumption requirements, with water generally being sourced from local water bodies, reducing its availability for local community needs, such as irrigation of agricultural crops. This is a particular problem for mining in Africa, as the continent is one of the driest in the world, with around 45% of its landmass being classified as dry lands (and around 40% of these dry lands constituting hyper arid or desert land) (Kigomo, 2003[90]). As a result, many of Africa’s mineral-rich countries in the Sahel, Horn of Africa, and Southern Africa are very susceptible to rainfall variability, drought, and groundwater depletion – a situation further aggravated by Africa’s notable vulnerability to climate change. Ascertaining whether sufficient water resources exist for a proposed mining project now precedes pre-feasibility studies in many African contexts, reflecting the reality that the water required for mine development is often simply not available (African Mining Market, 2024[91]). In some instances, such as Namibia, mining projects are mandated to use only desalinated sea water and also provide potable water for local communities.).

Poor mine closure and rehabilitation practices. Mine closure and rehabilitation are particular issues in many African countries, caused by mining companies not always being required or failing to set aside upfront funds for rehabilitation and governments failing to enforce legal obligations, including due to corruption (Dambe, 2020[92]). In South Africa alone, there is an estimated 6000 abandoned coal mines in need of rehabilitation, many of which pose environmental and physical hazards for local communities (African Business, 2022[93]). Increased attention is being paid globally to proper mine site restoration, evidenced by the December 2022 launch of the first global standards for mine site restoration, the International Principles and Standards for the Ecological Restoration and Recovery of Mine Sites (Mine Site Restoration Standards, MSRS), aimed at driving more holistic ecological recovery at mining sites (Society for Ecological Restoration, 2022[94]).

3.4. Continental and regional frameworks

As outlined above, the African Mining Vision embodies the continent’s aspiration to transform its resource wealth into broad-based, equitable, and sustainable development, calling for transparent and equitable benefit-sharing, diversification of economies beyond raw extraction, and the integration of mining into national industrialisation strategies. However, despite rhetorical commitment, implementation has often been inconsistent.

Regional mechanisms have also advanced African leadership in responsible sourcing. The ICGLR’s Regional Initiative against the Illegal Exploitation of Natural Resources (RINR) and the Lusaka Declaration (2010) institutionalised due diligence approaches and certification schemes for conflict-affected minerals. These frameworks, developed in collaboration with the OECD and multiple African governments, demonstrate how regional cooperation can anchor responsible supply chains. In parallel, the Extractive Industries Transparency Initiative (EITI) and the Voluntary Principles on Security and Human Rights have expanded across the continent, with 23 African countries now implementing EITI standards. The Voluntary Principles are a multi-stakeholder initiative guiding extractive industries to align security practices with human rights.1 Several African countries are advancing in-country implementation such as the DRC and Mozambique which are ‘engaged members,’ while Ghana is a government member. These initiatives promote greater disclosure of payments, contracts, and security practices, helping to build public trust and reduce opportunities for corruption.

Yet, despite these achievements, implementation challenges persist. Many African institutions lack the technical and financial capacity to enforce due diligence obligations or to monitor cross-border mineral trade effectively. In some countries, overlapping responsibilities between ministries or weak decentralisation structures lead to gaps in oversight. The effectiveness of RBC frameworks therefore depends not only on normative alignment but also on sustained investment in governance capacity and institutional coordination.

The increasing deployment of technological tools to support due diligence and traceability is an encouraging development. In specific contexts, blockchain, digital ledgers, and artificial intelligence can enable near real-time tracking of minerals from extraction to export, reducing opportunities for fraud and illicit trade. However, these new tools also raise new challenges. Digital traceability requires significant infrastructure investment, technical expertise, and reliable data systems – capacities often limited in fragile settings. For ASM, which often operates outside formal systems, the digital transition can deepen exclusion. Without targeted support, the shift to high-tech traceability may privilege multinational companies while marginalising the very communities most in need of inclusion.

Tech-driven traceability must therefore complement inclusive governance. Effective implementation depends on strengthening customs capacity, expanding access to finance for ASM operators, and fostering formalisation pathways that make digital systems beneficial rather than punitive.

3.5. Implementation and verification challenges

As mentioned above, RBC recommendations and standards are well acknowledged across the continent, in particular in countries in the Great Lakes Region. To enable the implementation of international and regional expectations on due diligence, transparency and accountability, global private sector led initiatives have been deployed in several African producing countries. However, verification remains uneven across the continent and major gaps persist in ensuring that production and trade of mineral resources meet responsible sourcing expectations. Multi-tiered supply chains involving informal intermediaries complicate due diligence implementation, which can become overly costly and technically demanding.

Durable progress requires an integrated approach combining legal enforcement, community development, and responsible market incentives. Capacity building for African customs and mining agencies, harmonisation of regional certification schemes, and sustained donor engagement are critical. Local communities should be seen not merely as beneficiaries but as co-regulators – actors with the knowledge and agency to ensure that RBC translates into tangible improvements in livelihoods and governance.

The evolution of RBC in African contexts demonstrates that responsible sourcing is both a developmental and a governance challenge. It demands an approach that balances ambitious expectations with practicality, enforces human rights without undermining livelihoods, and strengthens African agency within global governance systems. The success of RBC depends not only on compliance but also on building trust between companies, communities, and governments.

Inclusive, multi-stakeholder approaches that align global norms with local realities are essential. This requires investment in domestic regulatory capacity, partnerships for transparency, and traceability systems designed to empower rather than exclude. Emerging technologies offer powerful tools for transparency, but they must be deployed ethically, inclusively, and with safeguards against data misuse and inequality.

Continued collaboration between the European Union, OECD, African Union, and African regional organisations will be crucial to developing context-appropriate models that integrate responsible sourcing with industrialisation and value addition. Ultimately, implementation of RBC in Africa must move beyond compliance to embrace meaningful due diligence, with a view to supporting economic resilience, and peacebuilding. If effectively implemented, RBC can transform Africa’s mineral wealth from a source of fragility into a foundation for quality investments and long-term economic growth.

Note

← 1.  See Voluntary Principles on Security and Human Rights, https://www.voluntaryprinciples.org/.