New Research: Mining Sector Lobbying on the EU Corporate Sustainability Due Diligence Directive
Today, Social LobbyMap publishes its flagship metals and mining sector research report, “How major metal and mining companies lobbied the CSDDD“
This research provides the most comprehensive assessment to date of metals and mining sector lobbying on the EU Corporate Sustainability Due Diligence Directive (CSDDD), with a particular focus on the 24 companies engaged under the PRI Advance initiative.
For investors committed to advancing responsible business conduct, understanding how investee companies engage with human rights regulation — both directly and through trade associations — is essential. This report provides evidence-based analysis to support effective stewardship and engagement.
Why this research matters
The metals and mining sector presents a unique combination of:
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- High human rights risk exposure
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- Significant political and financial resources
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- Strategic importance to the global energy transition
As mandatory human rights due diligence regimes emerge globally, investors face a critical question:
Are companies’ lobbying activities aligned with their stated human rights commitments?
This report helps answer that question.
Key Findings
1. Trade associations dominate lobbying activity
Lobbying on the CSDDD was conducted almost entirely through trade associations rather than directly by companies. Only one of the 24 companies engaged by PRI Advance submitted its own consultation response.
This reliance on associations — combined with limited transparency — creates material governance and alignment risks for investors.
2. Support varies significantly by provision
While many associations supported the concept of mandatory human rights due diligence in principle, support weakened substantially around key accountability mechanisms:
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- Civil liability provisions were opposed by the majority of assessed entities
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- Comprehensive value chain coverage received limited support
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- Stakeholder participation requirements saw predominantly negative engagement
This pattern suggests that even relatively supportive actors often resist the most substantive enforcement mechanisms.
3. “Quiet support, loud opposition”
Entities with more supportive positions tended to engage less visibly and less intensively in the legislative process, while more oppositional actors demonstrated higher engagement intensity.
This imbalance risks skewing regulatory outcomes and leaves supportive positions underrepresented in policy debates.
4. Significant transparency gaps
Most companies disclose limited information about:
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- Their trade association memberships
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- Alignment between corporate commitments and association lobbying
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- Indirect engagement conducted “behind closed doors”
Of the 24 companies assessed:
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- 71% disclose no trade association alignment assessment at all
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- 92% have not assessed alignment on social or human rights lobbying specifically
For investors, this represents a clear stewardship challenge.
5. Broader patterns of influence
The report also includes case studies from Brazil, Australia, and Zambia, illustrating how mining companies and their associations have engaged on Indigenous rights, labour rights, and community participation in national legislative processes.
These cases demonstrate that limited engagement on the CSDDD does not reflect limited lobbying capacity — rather, it highlights strategic selectivity in where and how influence is deployed.
What this means for investors
The PRI Advance initiative brings together over 250 institutional investors representing approximately $35 trillion in AUM. Political engagement is one of its stated stewardship priorities.
This research identifies practical engagement opportunities, including:
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- Requiring greater transparency on direct and indirect lobbying
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- Extending trade association alignment reviews beyond climate to cover social and human rights issues
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- Addressing inconsistencies across multiple association memberships
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- Encouraging companies with supportive positions to engage more visibly
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- Considering direct engagement with key trade associations
As human rights due diligence regimes evolve, misalignment between corporate commitments and lobbying activity presents material governance, reputational, and regulatory risk.
Coming Next: Two Further Analyses
This flagship report is the first in a three-part research series examining mining sector lobbying on human rights regulation.
Next week, Social LobbyMap will publish:
Analysis 1: “Lobbying imbalance: A sector-wide analysis of mining engagement on the CSDDD”
An expanded assessment of 17 metals and mining trade associations, adding six entities beyond those linked to PRI Advance companies.
This piece examines geographic concentration of oppositional lobbying and compares sector-wide patterns with the PRI Advance subset.
Analysis 2: “Coordinated lobbying: How mining trade associations amplified their positions on the EU due diligence directive.”
This research reveals evidence of coordination mechanisms, including:
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- Verbatim consultation language
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- Network partnerships
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- Joint meetings with EU officials
Together, the three publications provide the most comprehensive picture to date of how influence is exercised within the metals and mining sector on human rights regulation.
Read the Report
Read the full flagship report “How major metal and mining companies lobbied the CSDDD”.
We encourage investors, policymakers, and civil society organisations to review the findings and engage with us on strengthening transparency and accountability in corporate political engagement.