• FINANCE
Additionally, investors assess the approach to human rights and governance factors within communities. The report notes that 35 % of executives acknowledge differences in values, such as approaches to human rights, supporting mining communities, or the ethical application of AI, as key challenges when setting up operations in new countries, indicating these are material considerations for investment decisions. Investors are also looking for data on the impact operations have on biodiversity, or the effects of biodiversity loss, with a specific focus on the ability to sustain and improve the quality of water, insofar as mining is concerned.
SM: How should mining houses approach scope 3 emissions measurement and disclosure when procurement data is limited?
BM: The report emphasises the importance of establishing robust data gathering and reporting frameworks early in expansion, stating that " locating and tracking the data needed to provide compliance is much easier when it ' s being done in real time." The report recommends investing in data consolidation systems that gather information from various sources, including procurement and vendor management, to support supply chain reporting, which will likely emerge as the next wave of important requirements for transparency, as more than 80 % of emissions currently sit in scope 3.
However, it is a complex process due to the varying maturity of suppliers and a likely shift away from spend-based supply chain emissions measurement to a more data-centric reporting requirement that more closely aligns with best practices on greenhouse gas emission protocols. Regardless of the reporting requirements, policies that require data transparency and accountability will only accelerate from this point. As such, the report stresses that companies should understand what data will be needed for compliance before starting operations rather than attempting to gather information retrospectively.
SM: What type of assurance do investors typically require to accept ESG claims?
BM: The report indicates that investors require transparent, regular and standardised reports that demonstrate good management, an accountability culture, and a consistent performance track record. Investors want confidence that selected KPIs make sense for the sector and are material to the size of the mining operation. Robust reporting speeds up due diligence by providing investors with readily available data, functioning " like building a database to streamline future fundraising." The report emphasises that transparency and consistency in combined financial and non-financial data-led reporting approaches help investors understand opportunities and risks.
SM: What are the common data gaps you see in African mining companies and the fastest, cost-effective ways to close them?
BM: The report highlights general challenges, including knowledge gaps when entering new international markets, particularly regarding complex compliance requirements. The report emphasises that many companies struggle with understanding how much relevant data sits within the organisation and where it ' s located. The recommended solution is successfully consolidating various data streams from HR, sales, procurement and vendor management through consolidated IT systems, then developing cohesive data strategies and streamlined data pipelines for easy access, organisation and analysis.
Data disintegration caused by immature processes and systems is another key issue. Mine operators must provide assurances on sustainability data and offer a similar or dual level of audit readiness applied to financial data, which requires ongoing investment into digitisation. Accurate data gives operators a strong starting point and gives their performance measures more credibility.
SM: How can miners balance cost and credibility when commissioning assurance?
BM: According to the report, it is imperative to develop data and reporting capabilities at the same pace as business growth, as this approach prevents the need for complicated, expensive and legally precarious retrofitting. The report warns that investment in office administration, data gathering and reporting capacity often takes a back seat to sales and marketing during growth phases, but this creates problems when international trading begins and regulations become more complex. Operators must consider sustainability data requirements when exploring digitisation and the strategic implementation of automation and AI to transform sustainability at a similar pace. The implication is that early, incremental investment in reporting infrastructure and human capital is more cost-effective than delayed comprehensive overhauls.
SM: What IFRS S1 and S2 and regional regulations are evolving and what should African miners start implementing now to avoid last-minute compliance costs?
BM: Many businesses have yet to reach IRFS S2 maturity, with the biggest gaps being climate risk assessment and scenario planning. The companies must articulate the physical and transitional risks – those that emerge during the transformation. Transforming sustainability and risk planning must happen within the operation’ s risk management framework, as this is a strategic tool in terms of risk assessment that gives mining companies the ability to futureproof their business to protect against future changes. Ultimately, businesses that are not undertaking this exercise remain vulnerable as these rapid changes emerge. In this regard, the report identifies several evolving regulatory frameworks, including the OECD Pillar Two framework requiring 15 % global tax on multinational enterprises and the Digital Operational Resilience Act( DORA).
SM: For a mid-tier miner with a limited budget, what are three immediate high-impact steps to start demonstrating true ESG impact to investors?
BM: Based on the report ' s key recommendations, the areas that require immediate focus include: 1. A comprehensive materiality assessment that revises the business and business’ resilience plans is the most critical and effective step. The mistake businesses make is looking at peers and treating this process as a desktop exercise. When done correctly, it will uncover the blind spot where operators can most effectively allocate capital and resources to support their sustainability journey.
2. Consolidate existing data streams from HR, procurement, vendor management, and operations to understand what relevant data already exists and where it ' s located, creating accessible data pipelines.
3. Implement real-time data capture for sustainability metrics, particularly carbon emissions and supply chain factors, as the report emphasises that " locating and tracking the data needed to provide compliance is much easier when it ' s being done in real time " rather than retrospectively, building credibility through consistent, transparent communication of outcomes. •
30 • African Mining • March 2026 www. africanmining. co. za