New Research Reveals Mining Sector Lobbying on EU Due Diligence Directive Dominated by Trade Associations with Limited Company Transparency
Three-part analysis documents coordination among associations, geographic concentration of opposition, and governance gaps for investors
EIRIS Foundation’s Social LobbyMap today releases comprehensive research on metals and mining sector lobbying related to the EU’s Corporate Sustainability Due Diligence Directive (CSDDD). The three-part analysis examines lobbying by the 24 companies engaged by the Principles for Responsible Investment (PRI) Advance initiative, documents broader sector-wide patterns, and reveals how trade associations coordinated their engagement—findings that have significant implications for investor stewardship and EU policymaking.
The research shows that mining sector lobbying on the CSDDD was conducted almost exclusively through trade associations rather than by individual companies, with only one of 24 companies engaged by PRI Advance submitting its own consultation response. This reliance on trade associations, combined with limited company disclosure about association memberships and positions, creates transparency gaps that prevent investors and other stakeholders from assessing whether corporate lobbying aligns with stated human rights commitments.
Key Findings
From the flagship report on companies engaged by PRI Advance:
Of the 24 metals and mining companies engaged by PRI Advance, 15 are members of trade associations that lobbied around the CSDDD. The majority of these companies (10 of 15) have relationship scores indicating overall support for the directive based on their association memberships. However, only seven companies disclose having conducted any alignment assessment between their values and their trade associations’ lobbying positions—and of these, only one (Anglo American) assessed alignment on both climate and social issues. This means 71% of PRI Advance companies disclose no alignment assessment at all, and 92% have not assessed association alignment specifically on social and human rights lobbying.
Entities with more supportive positions showed significantly lower engagement intensity than those opposing the directive: the five most supportive entities averaged an engagement intensity score of 1.9, while the five least supportive averaged 4.8. This pattern of less visible support and more active opposition leaves progressive voices underrepresented in policy debates.
Case studies examining mining sector lobbying in Brazil, Australia, and Zambia reveal active engagement on Indigenous rights, labour rights, and community participation in these jurisdictions, demonstrating that limited CSDDD engagement reflects strategic choices rather than limited capacity to influence social regulation.
From the sector-wide analysis:
Expanding the analysis beyond companies engaged by PRI Advance to 17 total entities reveals geographic concentration in oppositional lobbying. German and EU-wide trade associations (11 of 17 entities) had an average organisational score of 30—significantly lower than both the sector average of 38 and the PRI Advance subset average of 41. This indicates that oppositional lobbying is geographically concentrated rather than sector-wide, with German employer federations playing a particularly prominent role.
The mining sector showed the lowest engagement intensity of any sector Social LobbyMap has analysed—averaging a score of 4 compared to 7-10 for other sectors. Most engagement was limited to consultation responses rather than the sustained, multi-channel lobbying observed in other sectors.
From the trade association coordination analysis:
Analysis of consultation responses reveals systematic coordination among trade associations, with multiple entities submitting identical language on key questions. For example, four associations (Ceemet, Gesamtmetall, Steelbel, and WSM) used identical language in opposition to stakeholder engagement requirements, arguing that “it should be up to the company itself to define which stakeholders are relevant.”
Two distinct coordination networks were identified. The first, centered on German employers’ federation Gesamtmetall, showed tight coordination and uniform opposition across consultation questions. The second, centered on Eurometaux (the European non-ferrous metals association), showed looser coordination with more diverse positions.
Evidence from the EU Transparency Register shows that associations also held individual and joint meetings with European Commission officials beyond public consultation processes, indicating lobbying activity that cannot be publicly assessed.
Implications
For investors: The research provides evidence-based analysis to support PRI Advance signatories and other institutional investors in engaging portfolio companies on lobbying transparency. Recommendations include requiring companies to disclose complete trade association memberships, conduct and publish alignment assessments covering social and human rights issues, and publicly differentiate from association positions where misalignments exist.
For policymakers: The findings raise questions about whether trade association claims to represent “the sector” reflect actual industry positions or the preferences of specific national employer federations. The geographic concentration of opposition suggests that the loudest voices in mining sector consultations may not reflect the sector’s center of gravity or the positions of companies selected by major investors for human rights engagement.
For companies: The analysis reveals a governance gap: companies rely heavily on trade associations for lobbying but provide minimal transparency about whether association positions align with corporate values. The research documents that no PRI Advance mining company has publicly differentiated from an association position, despite several belonging to associations that took oppositional or non-supportive positions—creating reputational risk when policymakers may assume all members support association lobbying.
Methodology
Social LobbyMap employs a rigorous methodology adapted from InfluenceMap’s approach to climate lobbying. Individual evidence items from consultation responses, position papers, and public statements are scored on a five-point scale against international human rights standards, including the UN Guiding Principles on Business and Human Rights. The analysis examined 17 metals and mining entities that engaged with the CSDDD, including 10 trade associations with ties to PRI Advance companies.
The research also draws on case studies of mining sector lobbying in Brazil (Indigenous peoples’ rights), Australia (labour rights), and Zambia (community participation), EU Transparency Register meeting data, and publicly disclosed trade association partnerships.
About the Publications
Flagship Report: “How major metal and mining companies lobbied the CSDDD” examines lobbying by the 24 metals and mining companies [engaged by PRI Advance] on the CSDDD through their trade association memberships, includes case studies of lobbying in Brazil, Australia, and Zambia, and provides recommendations for investor stewardship.
Analysis 1: “Lobbying Imbalance: A sector-wide analysis of mining engagement on the CSDDD” expands the examination to 17 total entities (adding six beyond those linked to PRI Advance companies), documenting the geographic concentration of oppositional lobbying and comparing sector-wide patterns to the PRI Advance subset.
Analysis 2: “Coordinated lobbying: How mining trade associations amplified their positions on the EU due diligence directive” reveals coordination mechanisms including duplicated consultation language, network partnerships, and joint meetings with officials.
Together, the publications provide the most comprehensive analysis to date of mining sector lobbying on human rights regulation.
About Social LobbyMap
Social LobbyMap is an EIRIS Foundation project that increases transparency and analysis around corporate lobbying on human rights and labour standards. The project assesses corporate political engagement against international standards to enable investors, civil society, and others to understand how businesses engage with human rights legislation. Previous analyses have examined financial, apparel, renewable energy, and utilities sectors’ lobbying on the CSDDD and cross-sectoral lobbying on the European Commission’s Omnibus proposal.
Note re PRI Advance
PRI Advance is a global investor stewardship initiative focused on advancing progress on human rights to support investors and protect risk-adjusted returns. The initiative identified 24 metals and mining companies for engagement due to their high-risk human rights profile, potential for investor influence, and critical role in the green transition.
Contact: social.lobbymap@eirisfoundation.org
Notes
- Company relationship scores are based on positions taken by trade associations to which companies belong, weighted by number and positions of those associations. Scores do not represent companies’ own lobbying positions, which in most cases are not publicly available.
- The three PRI Advance companies with exposure to non-supportive or oppositional association memberships are ArcelorMittal, Glencore, and Anglo American. ArcelorMittal was the only PRI Advance company to lobby directly, with an organizational score (31) more supportive than its relationship score (24) based on association memberships.
- The most prominent associations representing PRI Advance companies are ICMM (13 members, score 75), ICA Europe (9 members, score 63), and Eurometaux (5 members, score 44)—all taking relatively supportive or neutral positions.
- Verbatim language example: On stakeholder engagement, Ceemet, Gesamtmetall, Steelbel, and WSM all submitted: “we recognise that consultation of relevant stakeholders is important in the life of companies, but it should be up to the company itself to define which stakeholders are relevant.”
- The CSDDD originally entered into force in July 2024 but is subject to proposed revisions under the EU’s Omnibus simplification package, which would increase company size thresholds, remove the EU-level civil liability regime, and narrow stakeholder engagement requirements.
- Social LobbyMap scoring: Individual evidence items scored -2 (opposing) to +2 (strongly supporting), converted to 0-100 scale at entity level. Scores above 50 are supportive; scores below 50 are non-supportive or oppositional. Average sector score: 38 (non-supportive).
Statistical Highlights
- Only 1 of 24 PRI Advance companies lobbied directly on the CSDDD (ArcelorMittal)
- 15 of 24 PRI Advance companies linked to trade associations that lobbied the CSDDD
- 10 of 15 linked companies have supportive relationship scores; 4 neutral; 1 oppositional
- 71% of PRI Advance companies disclose no alignment assessment of trade association positions
- 92% have not assessed alignment specifically on social and human rights lobbying
- 11 of 17 total entities analyzed are German or EU-wide associations (average score: 30, oppositional)
- Engagement intensity: Most supportive entities averaged 1.9; least supportive averaged 4.8
- Mining sector engagement intensity (4) is lowest of any sector Social LobbyMap has analyzed (others: 7-10)
- 11 of 13 entities submitting to consultation phase 2 showed evidence of coordination in two distinct groups