Conflict Minerals and ESG: From Risk to Responsibility

By Christopher Burke

The global race for “clean” energy runs through some of the planet’s most fragile and violent places.

• In Eastern Democratic Republic of Congo (DRC), cobalt and copper extraction poisons rivers and soils.
• In northern Mozambique, ruby and graphite mines overlap with insurgency, deforestation and dust pollution.
• In Sudan, an artisanal gold boom accelerates land degradation and toxic contamination amid civil war.
• In Burkina Faso, small-scale gold mining introduces cyanide and mercury into waterways that sustain farming communities.

Environmental, social, and governance (ESG) frameworks must evolve from shielding investors from reputational risk to protecting ecosystems and people from extractive harm to be relevant in such environments.

These challenges are not confined to local operators; they extend to foreign-listed firms whose access to capital and licenses increasingly depends on demonstrable ESG performance in fragile contexts.

Cobalt’s Toxic Footprint

The DRC supplies 70 percent of the world’s cobalt, most as a copper by-product from the south of the country. Recent investigations link industrial operations feeding global battery supply chains to water contamination, acid mine drainage and local health risks. Georges Kasay, a geologist and Visiting Senior Lecturer at Universite de Goma in the DRC explains that the interface of tailings, overburden dumps and local water use is precisely where the weakening of ecosystems and the exacerbation of contamination are most acute.

Jacob Akuei Abuol of UNDP in South Sudan argues that independent monitoring could transform accountability. He suggests adopting field-based, third-party environmental monitoring, especially in conflict-affected and high-risk areas, would be a strong step toward more meaningful accountability and help to uncover issues across the entire lifecycle from exploration through operations to closure. In Eastern DRC, real-time monitoring of water near tailings could reveal risks ignored by static compliance reports adding transparency where governance is fragile. For publicly traded companies, failure to demonstrate credible environmental monitoring exposes them to shareholder pressure and regulatory review. This underlines the need for proactive compliance strategies that go beyond meeting the minimum host country requirements.

Mines in a Deforestation and Dust Belt

Cabo Delgado in northern Mozambique highlights how environmental and security risks amplify one another. Around Montepuez, satellite data reveal recent forest losses linked to ruby mining and settlement expansion. At Balama, environmental assessments flagged airborne particulates and risks to water sources requiring dust suppression, lined waste facilities and robust monitoring to protect communities.

Yet these controls are missing; in a province destabilized by insurgency, inadequate safeguards compound displacement and livelihood shocks for farmers and fishers.

The commercial consequences are clear: projects that fail to anticipate ESG expectations risk suspension, financing difficulties or steep reputational penalties that outweigh short-term cost savings.

Conflict Gold, Toxic Land

Sudan’s civil war has turbocharged artisanal and small-scale gold mining (ASGM). Gold production hit 64 tonnes in 2023, a 53 percent increase, generating US$1.57 billion in official exports while an unknown volume is smuggled abroad enriching armed factions. On the ground, mercury and cyanide use drives soil erosion, water siltation and toxic exposure across Darfur and beyond.

Jonas Lwamuguma Bagaluza, Assistant Manager at the Vinmart Foundation and Lecturer at the University of Lubumbashi in the DRC notes “the widespread use of mercury and cyanide not only exacerbates contamination and accelerates the weakening of ecosystems, but deepens the precarious situation of artisanal miners and surrounding communities.” The war economy ties chemicals and smuggling networks directly to violence, linking environmental collapse to conflict dynamics.

Cyanide, Mercury and the Food–Water Nexus

Researchers in Burkina Faso have documented cyanide contamination in surface and groundwater at mining sites such as Zougnazagmiline in the central north of the country and Galgouli in the southwest threatening irrigation, livestock and household sources. Mercury and cyanide use in processing carries severe neurotoxic and ecosystem risks.

Moussa Ouedraogo, Land Law Expert, member of the Scientific and Technical Committee of the Inter-ministerial Group for the Monitoring and Verification of the Mining Sector (CST-IGMVSS) in Burkina Faso and environmental and/or social consultant with the African Development Bank warns “alerts must be raised concerning the weakening of ecosystems, the intensification of pollution and contamination (notably mercury, cyanide, etc.), and the worsening precariousness of artisanal miners’ working conditions (social conflicts, inequalities and poverty, public health).”

He stresses that the urgent priority is documenting how these combined pressures undermine climate adaptation, natural resource management and livelihoods in a country already stressed by insecurity and climate change.

For international operators, these dynamics underscore the importance of aligning local practices with global standards. Failure to do so not only fuels environmental harm, but jeopardizes access to export markets governed by strict ESG rules.

Responsible ESG in Conflict-Affected Mining

Today’s ESG efforts too often stop at financiers’ paperwork audits, reducing them to what Jacob Akuei Abuol calls a “box-ticking exercise rather than a deep, ongoing commitment.” More credible accountability requires field-based, third-party monitoring that generates real-time insights, especially in fragile governance contexts. In Eastern DRC, that could mean systematic water testing downstream of tailings; in Cabo Delgado, dashboards tracking dust and groundwater co-managed with local councils; and in Sudan and Burkina Faso, independent audits of chemical use alongside closed-loop processing to curb mercury and cyanide exposure.

Traceability systems designed to exclude “conflict minerals” should also measure environmental externalities—tailings safety, water quality, dust levels and reclamation progress. Buyers who refuse materials lacking verified environmental metrics would create commercial incentives for companies to contain waste, treat water, and rehabilitate land, even where state oversight is absent. Voluntary adoption of recognized ESG protocols can reassure investors and lenders, reducing the cost of capital while strengthening long-term license to operate.

Because communities are the first to bear environmental costs, they should also be empowered to define risk thresholds. ESG frameworks could formalize community “stop-work” triggers, suspending operations if cyanide levels at village water intakes or blasting-related dust exceed agreed limits. Joint committees of companies, communities, and independent experts could verify mitigation measures, while benefit-sharing agreements should be tied directly to environmental key performance indicators. In this way, local livelihoods would improve in step with cleaner operations, aligning community well-being with responsible resource extraction.

The Green Transition’s Credibility Test

Minerals extracted through deforestation, toxic releases and degraded watersheds cannot be “laundered” into clean technologies with glossy ESG reports. In Eastern DRC, cobalt and copper sites leave polluted soils and streams. In Mozambique, inadequate dust and wastewater controls undermine farming and fishing. In Sudan and Burkina Faso, ASGM’s toxic chemistry collides with climate fragility, eroding food systems and health.

This is not an argument against mining, but an argument against extractive amnesia.

The tools already exist:

• Government-backed due diligence through the Organisation for Economic Co-operation and Development (OECD),
• Tailings safety under the Global Industry Standard on Tailings Management (GISTM) and
• Rapidly advancing supply-chain traceability systems such as the International Tin Supply Chain Initiative (ITSCI).

These frameworks, standard and traceability systems must be conflict-proofed: funded, independently verified and enforced in contexts where violence and weak institutions otherwise make corner-cutting routine.

• For investors, this means conditioning off-take agreements on environmental transparency and third-party verification.
• For governments, it requires ring-fencing resources for independent monitoring and protecting community whistleblowers.
• For companies, it demands treating environmental protection as a core operating cost rather than a discretionary CSR line item.

While stronger accountability is essential, solutions cannot be one-size-fits-all. Rather than prescribing catch-all solutions, recommendations should clarify the conditions under which they apply, so that mechanisms are feasible and provide the assurances needed in each context.

The urgent priority is to document how combined pressures—pollution, ecosystem fragility and social precarity—undermine adaptation practices critical for climate resilience, natural resource management and community well-being.

Embedding independent field verification into ESG frameworks is the practical step needed to move beyond box-ticking toward genuine responsibility. Without such continuous, field-based monitoring, ESG risks remain a reputational shield rather than a safeguard for ecosystems and communities. If these gaps persist, the green transition will rest on brown foundations: cobalt with acid-burned streams, graphite with dust-choked villages and gold with poisoned wells.

ESG in conflict-affected mining must evolve into a model that changes operations on the ground so that the minerals of tomorrow are not mined at the expense of the lands and waters that sustain life today.

The lesson is clear.

Companies that embed ESG responsibility into core operations, rather than treating it as compliance, are best positioned to secure resilience, maintain market access and contribute to a truly sustainable energy transition.

 

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Christopher Burke is a senior advisor at WMC Africa, a communications and advisory agency located in Kampala, Uganda. With almost 30 years of experience, he has worked extensively on social, political and economic development issues focused on environment issues, extractives, governance, policy formulation, communications, advocacy, conflict transformation, international relations and peace-building in Asia and Africa.