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26 Avr 2022

Transition Minerals Tracker Methodology

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The Transition Minerals Tracker (Tracker) captures publicly reported allegations of environmental and human rights abuses against companies mining one or more of the following seven minerals: bauxite (since 2024), cobalt, copper, lithium, manganese, nickel, and zinc. Only allegations against globally significant producing mines (or recently closed) for each of the seven minerals are included. Other parts of the mine life cycle i.e. exploration or closure, as well as smelting/refining activities are not included in the Tracker.

The Tracker includes allegations arising from 2010 to present and is updated on an annual basis. The list of mines covered in the Tracker has also been reviewed and expanded in 2023 to ensure it captures top producing mines for each of the minerals, with the inclusion of 55 additional mines.


Allegations are primarily collected through a filtered search by company on the Business & Human Rights Resource Centre website. This includes allegations appearing in articles from international and local media outlets in all languages of the Resource Centre website, as well as NGO reports and lawsuits / regulatory action filed against the companies.  It is complemented by desktop research. The Tracker is predominantly based on materials available in English, Spanish and French, mainly due to the regional focus in our company selection process and organisational resource capacity.

What do we include?

Only publicly-reported allegations of specific incidents (date, affected parties), civil society action, attacks against Human Rights Defenders or legal/regulatory action against companies are captured and not information on general trends of abuse that cannot be tied specifically to one of the tracked companies’ operations. For example, reports on general trends within the mining sector that do not provide specific instances of abuse against a named company are not included.

For each allegation, we identify the parent company involved in the alleged abuse and, when the information is available, the responsible subsidiary and/or project name. One allegation can be associated with multiple impacts i.e., an incidence of water pollution may have other impacts, such as health impacts or impact on livelihoods.

The main categories of data we capture are:

  • the location of the incident;
  • the company against which the allegation is raised (including parent company, subsidiary and project-specific information);
  • the types of abuses being alleged;
  • the identity of affected groups;
  • the forms of activism used to bring the alleged abuse to light;
  • the timeframe of allegations.


We analyse each allegation against a set of 65 indicators of environmental & human rights abuses, which are sorted into 6 broad categories.

Identity of affected stakeholders

In order to protect personal information of affected parties, and avoid revictimization in the process of reporting, tracking and analysing allegations of human rights abuse, we identify for each allegation the affected parties according to general, impersonal qualifiers, namely:

  • Local community
  • Workers
  • Human rights defenders (HRDs)
  • Indigenous Peoples
  • Individual
  • Journalist, press or media
  • Lawyers
  • NGO
  • Union
  • Public entity (state prosecutorial services, regulatory authority acting on behalf of the public interest)
  • Ecosystem (for purely environmental abuses)

Attacks on HRDs in the context of transition minerals extraction

In 2021, we decided to explore the prevalence of attacks on HRDs, related to extraction of transition minerals.

In our HRDs database, and in this research, we used the Office of the United Nations High Commissioner for Human Rights’ definition of human rights defenders as “people who, individually or with others, act to promote or protect human rights… The actions taken by human rights defenders must be peaceful in order to comply with the Declaration on human rights defenders.” Applying this definition for our purposes, we document threats and attacks against people taking peaceful action to protect their labour, land, environmental, cultural or other rights, whether in their own personal capacity or professionally, that they perceive as being under threat by a business activity.

In our annual updates, we use our HRDs database dataset - which systematically documents attacks on HRDs, focused on business-related human rights abuses globally, since 2015 – as a starting point. We first check if companies or operations, covered in the Transition Minerals Tracker, appear in the database. We then record cases of attacks on defenders which were clearly acts of retaliation against defenders that raised human rights or environmental concerns about a specific private entity, already tracked in the Transition Minerals Tracker. Additional desk-based research is then carried out.

Because the HRDs database covers cases from 2015 onwards, while the Transition Minerals Tracker starts in 2010, we did additional desk research on all companies and operations covered in the tracker, to see if any defenders were intimidated, harassed, attacked and/or killed due to them raising human rights or environmental concerns about those private actors. We made sure we only captured attacks on those defenders that were raising concerns about extraction of one of the 6 transition minerals covered in the tracker at the time, and not another type of activity by any of the companies. In this second part of the research, we again relied on the information on the Business & Human Rights Resource Centre's website, which catalogues allegations in articles from international and local media outlets in all 10 languages of the Resource Centre website from 2006 onwards, but we also did additional desk research using media and NGO reports, including websites specialized in capturing attacks on human rights defenders.

Even though in the HRDs database we do include cases of attacks on defenders that stem from them raising concerns about the mining sector in general, in this research, we only include instances of incidents related to specific companies. Information on attacks on defenders, related to general trends of abuse within the mining sector, which could not be tied specifically to one of the tracked companies’ operations were not included.

Explore the methodology of the database of HRDs attacks

Timeframe of allegations

Many allegations in nature are a compilation of incremental impacts and can therefore be difficult to restrict to a specific timeframe. For each allegation we indicate the date when it was added (registered) to the Resource Centre website, reflecting the timeframe the alleged abuse was originally reported.

Seeking company responses

In line with the Resource Centre’s broader strategy and libel policy, we make every effort to reach out to companies accused of abuse and ask them to respond to allegations made using our Company Response Mechanism, unless the company has already publicly commented on the case, publicly declined to comment (we publish additional comments provided by companies when volunteered), or if the abuse is the basis of a lawsuit or regulatory action

Scope and limitations

The Tracker captures publicly reported information on alleged abuses committed by mining companies. Business & Human Rights Resource Centre does not independently verify the accuracy of the allegations. When relevant and possible, Business and Human Rights Resource Centre uses the Company Response Mechanism (see above) to seek responses from companies implicated in the commission of the alleged abuses. Similarly, the Business & Human Rights Resource Centre does not verify the accuracy of corporate statements on actions taken to respond.

The Tracker does not purport to provide comprehensive information on all allegations of abuses against all mining companies. Furthermore, it only includes publicly available information – which is a function of the state of media and civic freedoms. Restrictions in certain parts of the world, coupled with limited means of action for affected parties and fears of reprisals, can translate into under-reporting of abuses.

Each link is counted as one source of allegations unless it references different companies, or one company operating in multiple countries where the allegation is specific to different operations.

Only allegations against mining operations are included. Allegations relating to refining or smelting activities are not currently included, although Business & Human Rights Resource Centre acknowledges that there are numerous serious allegations of environmental and human rights abuses linked to those operations.