Mining: Ethics, compliance and human rights consultancy services

GoodCorporation has worked internationally for some of the world’s largest mining companies, testing and strengthening their codes of conduct, legal compliance frameworks and responsible management practices.

Our work covers key risk areas such as bribery and corruption, fraud, sanctions, human rights, community and environmental impacts, stakeholder engagement and governance.

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Understanding and mitigating integrity risks in the mining sector

Mining activities are often in higher‑risk jurisdictions, delivered through complex contractor and third‑party networks. As such, they can be exposed to integrity and compliance risks throughout the project lifecycle, from early‑stage permitting and licencing decisions to final project closure.

In particular, mining can be exposed to:

How we support mining companies

GoodCorporation works with companies to identify and mitigate the integrity, human rights and compliance risks associated with mining activities.

We carry out independent assessments, including site-level work, to understand how ethics, compliance and human rights frameworks operate in practice. This includes reviewing anti-corruption programmes, evaluating third-party and supply chain risk management systems, conducting human rights impact assessments and evaluating the risks of operations in higher risk and conflict-affected areas.

Our work focuses on providing an evidence-based view of risk and performance and strengthening controls where needed to embed best practice in mining projects and across companies’ wider activities.

We conduct structured assessments of ethics and compliance programmes across group, business unit and site level. This includes reviewing policies, controls and implementation, and benchmarking performance against our database of assessments to provide comparative insights into programme effectiveness.

This approach provides a clear view of how frameworks operate in practice and identifies gaps in areas such as anti-corruption controls, third-party oversight and governance arrangements.

We support companies in identifying risks across operations and value chains. This includes anti-corruption risk assessments, human rights risk mapping and supply chain analysis.

We conduct due diligence on suppliers, contractors and intermediaries, assessing their integrity programmes and the effectiveness of their controls. This helps organisations take a structured approach to managing third-party risk.

We conduct human rights impact assessments to identify the actual and potential impacts of mining activities on workers and communities. These assessments are carried out on site and involve stakeholder engagement with employees, contractors, workers, local authorities and community representatives. We also offer tailored human rights assessments for conflict-affected and high-risk areas (CAHRAs), with conflict-specific due diligence aligned with the United Nations Development Programme’s (UNDP’s) methodology of heightened human rights due diligence​.

Our work is used for the development of effective human rights governance, ensuring that risks are identified and addressed systematically, including in conflict-affected and high-risk areas.

Our human rights impact assessments (HRIAs) are used by mining clients to support applications for The Initiative for Responsible Mining Assurance (IRMA) certification.

Our human rights work often involves evaluating private security operations to ensure security arrangements are aligned with the Voluntary Principles on Security and Human Rights (VPSHR)​

We support organisations in strengthening ethics and compliance frameworks through programme development. This includes reviewing and drafting codes of conduct and supplier codes of conduct and aligning them with internationally recognised best practice.

We design and deliver communication and training programmes to ensure that policies are understood and applied across operations and third-party relationships.

We carry out confidential investigations into allegations of fraud, corruption, workplace misconduct and third-party breaches. Our approach focuses on establishing the facts, identifying root causes and supporting remedial action.

This work is often linked to broader programme improvements, helping organisations strengthen controls and prevent recurrence.

Our work with mining companies

Human rights impact assessment to prepare for IRMA certification

Challenge: A mining company preparing for IRMA certification needed a clear understanding of the actual and potential human rights impacts across operations.

What we did: Conducted an on‑the‑ground human rights impact assessment, aligned with the UN Guiding Principles, engaging workers, contractors and communities.

Outcome: A practical action plan to address salient risks and strengthen governance in line with IRMA expectations.

Human rights saliency assessment in metals and mining

Challenge: A global metals and mining organisation needed to prioritise human rights risks across multiple geographies and business activities.

What we did: Delivered a structured human rights saliency assessment, mapping severe risks across operations, value chains and geographies, including high‑risk jurisdictions.

Outcome: Clear prioritisation of salient human rights risks to inform due diligence, mitigation and reporting.

A mining truck loaded with rocks in a tunnel.

Anti‑corruption evaluation for a global mining organisation

Challenge: A large mining organisation required an objective view of the effectiveness of its global anti‑corruption framework.

What we did: Conducted an independent anti‑corruption compliance assessment, benchmarking policies, controls and implementation against recognised good practice and adequate procedures under the UK Bribery Act.

Outcome: A targeted improvement roadmap to strengthen controls across high‑risk operations and third‑party relationships.

Standards and frameworks

GoodCorporation’s assessment frameworks draw on internationally recognised standards and regulatory expectations. These frameworks are used to structure our assessments and to evaluate how ethics, compliance and human rights programmes operate in practice.

Our work is aligned with established guidance and relevant legislation, including the following:

  • UN Guiding Principles on Business and Human Rights (UNGPs) — Global standard for managing adverse human rights impacts;
  • UK Bribery Act (adequate procedures) — Risk-based expectations for preventing bribery across an organisation’s operations;
  • Foreign Corrupt Practices Act (FCPA) — Requirements for preventing and detecting bribery of foreign officials through effective compliance, record-keeping and internal controls;
  • OECD Due Diligence Guidance for Responsible Business Conduct — Practical guidance for identifying and addressing risks across complex and high-risk value chains;
  • OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas — Guidance for responsible mineral sourcing and managing risks in mineral supply chains;
  • Voluntary Principles on Security and Human Rights (VPSHR) — Framework for managing security arrangements responsibly;
  • UK Modern Slavery Act — Requirements for addressing modern slavery risks in business operations and supply chains;
  • CSDDD — Mandatory due diligence requirements for companies within scope, including relevant mining companies;
  • Extractive Industries Transparency Initiative (EITI) — Global standard for improving transparency and accountability in the extractive sector;
  • ICMM Mining Principles — Principles for responsible mining, covering environmental, social and governance performance;
  • IFC Performance Standards — Framework for managing environmental and social risks and impacts associated with projects and investments.

Frequently asked questions

What is human rights due diligence for mining companies?

Human rights due diligence is the ongoing process of identifying, assessing, preventing and mitigating a company’s actual and potential impacts on people. For mining companies, this means engaging with workers, worker representatives, contractors, affected communities, authorities and, where appropriate, civil society organisations to understand human rights risks across operations and the value chain. The findings should inform risk-based, prioritised action plans, with measures to track whether they are effective and provide remedy where the company has caused or contributed to harm.

Mining companies are expected to implement risk-based anti-corruption programmes that prevent, detect and respond to bribery risks arising from their operations. This includes conducting risk assessments, performing due diligence on third parties, maintaining effective controls and training, keeping accurate records and monitoring compliance. Under the UK Bribery Act, organisations may rely on a defence of having “adequate procedures” to prevent bribery, while the Foreign Corrupt Practices Act (FCPA) places more emphasis on preventing bribery of foreign officials and maintaining robust books, records and internal controls. Together, these frameworks establish expectations for proportionate, risk-based anti-corruption compliance across mining operations.

Under OECD guidance, conflict-affected and high-risk areas (CAHRAs) are locations affected by armed conflict, widespread violence or other conditions that increase the risk of serious human rights abuses. Mining companies operating or sourcing from these areas are expected to carry out heightened due diligence, including enhanced risk assessment, meaningful engagement with affected stakeholders, strengthened controls and ongoing monitoring. The findings should inform risk-based, prioritised action plans to prevent or mitigate adverse impacts. These approaches are also consistent with the expectations of the Corporate Sustainability Due Diligence Directive (CSDDD) for managing severe human rights and environmental risks.

An integrity and compliance assessment is independent and evidence‑based, testing how systems operate in practice and benchmarking performance. It complements legal advice by identifying practical improvements.

Yes, we conduct confidential, rigorous investigations into fraud, corruption, harassment, third-party breaches and safeguarding issues, supporting boards with credible, evidence-based findings.