The Responsibility Of The Buyer Deserves More Attention
I have a problem with the ease with which we demand responsible mining while expecting somebody else to absorb the cost. It feels like I have principals, but someone else must pay for it!
We want to know that the people producing our minerals are safe, that their water is protected and that the land will be rehabilitated when the mining ends, yet we seem reluctant to let those requirements interfere with getting a good price. Having spent much of my working life in mining, I am hardly a disinterested observer, but I do think the people buying the product have enjoyed a rather comfortable position in this argument.
They get to set the standard and negotiate the price, while the producer must explain why the two are proving difficult to reconcile.
Before my mining friends get too comfortable, this is no excuse for running an expensive operation badly and sending the customer a bill for our good intentions. We have enough responsibilities of our own, including the obligation to produce efficiently and to account for the damage we cause. A mine does not become responsible because its annual report says so, and a high production cost is certainly no proof of virtue.
What interests me is the point at which a buyer can see that a lower price depends on somebody else carrying a cost, but continues to treat that price as the proper benchmark for everybody. The same buyer may demand stronger proof of responsible sourcing and still benchmark its offer against Chinese supply, without checking whether the same costs and obligations are included in that price.
The argument about the now fatigued ESG has allowed us to spend a great deal of time discussing the label, rather than what it fundamentally means.
Morningstar’s figures show money leaving sustainable funds in 2025 and some returning in the second quarter of 2026, which seems a poor basis for either a funeral or a victory speech. I recommend that you investigate references [1] and [2]. I am quite happy for the investment industry to sort out what it wants to call its products; but a mine has got to still manage its water and protect its people while that discussion continues.
My objection to the acronym was never that those responsibilities were unimportant, but that putting them into a presentation could be mistaken for having dealt with them.
Critical minerals have given this old problem a new urgency, because governments now worry about where their supply comes from as well as how it is produced. The IEA reports that investment in critical minerals fell by 9% in 2025, despite the strategic attention being paid to them.[3] That does not tell us that every proposed project deserves funding, but it should make us question how much commercial weight all this enthusiasm actually carries.
If a government wants a new source of supply for reasons of national security, the company building it needs to know what that preference is worth when prices fall and the existing supplier becomes cheaper again.
I can understand a manufacturer buying from the cheapest reliable supplier, just as I can understand a government wanting alternatives to a supplier on which it has become too dependent. The difficulty comes when we expect a new mine or refinery to solve the second problem while being paid entirely on the terms of the first. Established producers may have better infrastructure, greater scale and years of operating experience, none of which a newcomer acquires by being declared strategically important.
If the additional source of supply has value to the customer, I would expect that customer to bring something more useful to the negotiation than encouragement.
We also need to be honest about what responsible production costs, without pretending that every environmental improvement is a financial sacrifice. Better equipment and safer operating practices can improve productivity, while avoiding a serious incident. This is good business by any sensible definition.
Some obligations nevertheless require spending that cannot be recovered through just another efficiency exercise, whilst insisting that they must all pay for themselves eventually becomes a polite way of refusing to pay for them at all. A community should not have to accept polluted water because the buyer and the producer have agreed that the commodity price leaves no room to treat it.
Artisanal gold makes the consequences harder to keep at a comfortable distance. Although gold has a different market from the minerals needed for batteries and electricity networks, it exposes the same difficulty with demanding standards without making compliance commercially possible.
The World Bank estimates that artisanal and small-scale mining directly employs at least 45 million people across 80 countries.[4] When a formal buyer decides that this sector is too difficult to deal with, those people still need to earn a living, and the gold will still find buyers who may be much less interested in asking questions.
I am uneasy with a definition of responsible sourcing that allows us to stop examining the consequences once the difficult supplier has been removed from our books. There are abuses that must rule out a purchase, and nobody should be expected to overlook child labour or violence in the name of protecting a livelihood. But where improvement is possible, somebody has to do the slower work of helping a legitimate producer qualify for the formal market.
Otherwise, we may have improved the appearance of our own supply chain without doing much for the person whose circumstances made us uncomfortable in the first place.
The LBMA’s work on routes for artisanal miners into formal markets, including progressive improvement, deserves attention for precisely this reason.[5] It recognises a practical problem that a pass-or-fail certificate cannot solve on its own: a small producer needs a way to reach the required standard and a reason to stay there.
The partnership announced between Rand Refinery and Ghana’s Gold Coast Refinery is worth watching in that context, because it proposes technical and operational support for local refining and responsible sourcing.[6] I would judge it by what producers can actually do differently as a result, rather than by the reassuring language of the announcement.
If formal participation brings additional expense, slower payment and more scrutiny without a worthwhile commercial benefit, then we should at least understand why a miner might continue selling through an informal trader. Understanding that decision does not mean approving of everything that happens along that route; it means taking the economics seriously enough to offer a credible alternative. I find it difficult to be impressed by our commitment to inclusion if the only people able to meet our entry requirements are those who never needed much help getting in anyway.
For larger critical-mineral projects, a buyer can make its intentions more credible through a purchase agreement long enough to support investment, or by sharing some of the price risk that would otherwise prevent the project from proceeding. A government seeking supply security can put money behind that objective, with conditions that protect the taxpayer and consequences if the producer fails to deliver.
In South Africa, a reconstituted AEMFC (the State Mining Company of which I have just been reappointed as the Chair) could provide patient minority equity to develop qualifying projects alongside private investors, with IDC financing projects once they become bankable.
These are choices about who carries risk, and they deserve proper scrutiny, but they also require the customer to accept some responsibility for creating the supply it says it needs. Another request for the producer to demonstrate commitment will not do that job.
South Africa needs to approach this with some commercial self-respect, as well as a clear view of our own shortcomings. We cannot expect a customer to pay for every failure in our electricity, logistics or management infrastructures, but neither should we confuse another country’s interest in our resources with a commitment to invest in them. Before we build a business case around somebody else’s strategic ambitions, we should establish what they are prepared to buy and, on what terms and for how long.
Being wanted is flattering; but it is also an inadequate basis on which to commit capital to.
I would like the next conversation about responsible minerals to spend rather more time on the purchasing decision. We are entitled to demand better of mining companies, and I have no interest in lowering those expectations, but the buyer who knowingly rewards a price made possible by unsafe work or unaccounted-for environmental damage is making a choice too. If we can recognise that responsibility when we inspect a mine, we ought to be able to recognise it when we sign a contract.
How ethical we want our minerals is a question for everyone who earns from them, including those who have become very good at asking it of somebody else.
~ Z. B. S,
References
- Morningstar, ESG Funds 2025 Closes With Continued Outflows Amid Persistent Headwinds, February 2026.
- Morningstar Sustainalytics, Global Sustainable Fund Assets Reach New High in Q2 2026, updated 21 August 2026. Global figures are estimates with regional reporting lags.
- IEA, Global Critical Minerals Outlook 2026, executive summary.
- World Bank, Achieving Sustainable and Inclusive Artisanal and Small Scale Mining, 2024.
- LBMA, Supporting ASM Progress, Sustainability and Responsible Sourcing Report 2025.
- Ghana Gold Board, Rand Refinery Celebrates Partnership with Gold Coast Refinery and GoldBod, January 2026.




























































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