CMOC Group Limited.

Fair Pay & Worker Respect

As a large-scale mining company with significant operations in high-risk jurisdictions like the DRC, the company faces inherent challenges regarding worker safety and labor rights, but its core business model does not inherently mandate either the advancement or violation of fair pay and worker respect. CMOC Group Limited (603993.SSE) demonstrates a mix of strong structural labor protections and significant operational safety challenges based on 2023 and 2024 evidence.

The company reports that 54% of its global workforce is covered by collective bargaining agreements, with 100% coverage at its major DRC and Brazil operations. The voluntary staff turnover rate was reported at 7.3% in 2023 and 10.82% in 2024, which is strong for the mining sector, though contractor turnover is significantly higher (up to 41.5%) due to project cycles. Despite maintaining a low Total Recordable Incident Rate (TRIR) of 0.58 to 0.85 per million hours (which converts to approximately 0.12–0.17 per 200,000 hours), the company recorded multiple fatalities. In 2023, there were 3 fatalities, and in 2024, there were 5 fatalities. Under the rubric, any year with more than 3 fatalities results in the lowest tier (-100) regardless of the TRIR, reflecting extreme safety outcomes. The company provides comprehensive health insurance across all regions, including medical and dental for families in Brazil and expanded coverage in China, reaching near 100% of the formal workforce. Regarding labor violations, the company maintains a zero-tolerance policy for child and forced labor; while it was cited in a sector-wide human rights risk report regarding cobalt mining, no specific legal violations or fines were substantiated in the provided evidence. TFM and KFM operations passed RMI audits, and the company reported zero confirmed incidents of child or forced labor in 2023-2024.

Fair Trade & Ethical Sourcing

As a major producer of cobalt and copper in the DRC, the company operates in a high-risk region for human rights abuses, child labor, and artisanal mining encroachment, necessitating rigorous supply-chain oversight that is inherently challenging to verify. CMOC Group Limited (CMOC) demonstrates a robust framework for ethical sourcing, though it operates in high-risk environments. **Certifications & Clauses:** The company has achieved significant third-party validation, notably with its TFM operation becoming the first African mine to receive the 'Copper Mark' certification, meeting 100% of its 31 criteria.

100% of supplier contracts include enforceable ethical clauses through the mandatory Supplier Code of Conduct and integrity pacts. **Traceability & Audits:** CMOC utilizes the 'ReSource' blockchain platform for cobalt traceability and has achieved 100% external ESG assurance coverage across the Group. It pilots blockchain proofs for critical commodities, placing it at the -10 tier for traceability. Audit frequencies vary by site; while Brazil conducts monthly assessments, the general standard for tier-1 mining sites involves annual third-party audits (ISO and RMI), aligning with the -60 tier. **Labour & Remediation:** The company reported zero substantiated incidents of forced or child labour in 2023 and 2024, maintaining proactive risk assessments and ASM (Artisanal and Small-Scale Mining) monitoring. Its grievance resolution rate improved significantly to 91% in 2023, with most cases resolved, though the median closure time is approximately 90-120 days based on annual reporting cycles. **Risk & Diversity:** As a major cobalt producer (50% of global supply), CMOC has high exposure to conflict minerals. While it employs active controls like the RMI’s Risk Readiness Assessment, the inherent risk remains high (-60). Regarding supplier diversity, the company spent approximately $1.26 billion on local procurement in 2024, which represents roughly 16% of its total direct economic contribution (RMB 191 billion), placing it in the -10 tier for diverse spend.

Honest & Fair Business

As a large-scale multinational mining and trading firm, the company operates in a sector with high inherent risks regarding transparency, regulatory compliance, and supply chain ethics, but its core business model does not inherently mandate fraud or honesty. CMOC Group Limited demonstrates a structured approach to business ethics with significant third-party oversight, though some geographic gaps remain in its audit scope. **Ethics & Compliance:** The company maintains a robust whistleblower system featuring a 24/7 anonymous hotline operated by a third party, with a documented commitment to respond within 7 days.

In 2023, the Anti-Corruption Department investigated six cases of misconduct, leading to the dismissal of seven employees and the referral of five cases to judicial authorities, demonstrating active enforcement. Anti-corruption training reached 100% of directors and key staff in 2024. **Regulatory & Financial Integrity:** The company reported a clean record regarding corruption-related legal proceedings over the last three years. The only disclosed fine was a minor administrative penalty of approximately RMB 37,000 (approx. $5,100 USD) in Brazil for late payment of inspection fees. CMOC confirmed zero financial restatements for the 2023 reporting period, though it did perform minor data adjustments for GHG emissions in 2024 to align with new guidelines. **Transparency & Verification:** CMOC is recognized by major ESG benchmarks, holding an MSCI 'AA' rating and an EcoVadis Gold rating for its IXM subsidiary. It participates in the Extractive Industries Transparency Initiative (EITI). However, while its international mining sites (TFM, KFM, Brazil) and IXM undergo external assurance for the RMI Risk Readiness Assessment, its Chinese mining operations are currently excluded from this external scope, limiting total audit coverage to approximately 70-75% of assets/revenue. Grievance resolution improved significantly from a 44% rate in 2022 to 91% in 2023 (768 of 845 cases resolved), though the median resolution time is not explicitly stated in days, the high volume and 100% resolution reported in some 2024 segments suggest a functional mechanism.

Kind to Animals

As a large-scale mining company, CMOC's operations involve significant land use and extraction activities that inherently pose risks of habitat destruction and biodiversity loss, which directly impact wildlife and animal welfare. CMOC Group Limited (603993.SSE) is a global mining company specializing in non-ferrous metals (molybdenum, tungsten, copper, cobalt).

Based on the provided evidence, the company's operations do not involve animal testing, animal agriculture, or the use of animal-derived ingredients, rendering most animal welfare KPIs (cruelty-free certifications, testing policies, and agricultural ethics) Not Applicable (0). The only relevant KPI with substantive evidence is 'wildlife_conservation_impact'. CMOC demonstrates active habitat protection and biodiversity monitoring across its global operations. In Brazil, the company supports the 'Eco Detectives' program, which utilized 126 camera traps and 184 monitoring points to record 34,920 wildlife detections in 2025 to identify ecological corridors. In the DRC, the company conducts biodiversity baseline surveys and monitoring of flora and fauna in partnership with local universities. CMOC has set a target to implement biodiversity management plans for 100% of its operating mines by 2030. While these initiatives show documented improvements and strategic habitat protection for multiple species, the investment in ecological research and environmental management (RMB 39.53 million) represents approximately 0.02% of its 2024 direct economic contribution (RMB 191 billion), which aligns with the lower end of the qualitative descriptions for habitat protection efforts.

No War, No Weapons

As a major producer of metals like cobalt, copper, and tungsten, the company supplies materials essential for both civilian technology and military hardware, and its operations in conflict-prone regions like the DRC carry inherent risks of association with conflict-linked supply chains. CMOC Group Limited (CMOC) is primarily a mining company focused on copper, cobalt, molybdenum, and tungsten.

Based on the provided evidence, the company has no reported revenue from arms or defense contracts, and its core business does not involve weapons manufacturing. Governance and oversight are managed through a Board-level Strategic and Sustainability Committee, which explicitly oversees ESG and supply chain integrity, effectively excluding defense business from its core mandate. The company demonstrates strong alignment with the UN Guiding Principles on Business and Human Rights (UNGPs), with third-party assurance and annual reporting. Regarding conflict-affected areas, CMOC operates significant assets in the DRC (TFM and KFM). It conducts quarterly and semi-annual human rights due diligence (HRDD) and contractor risk assessments. In 2024 and 2025, its TFM and KFM operations achieved 100% certification as conformant copper and cobalt processors under the Responsible Minerals Assurance Process (RMAP), which is aligned with OECD Due Diligence Guidance. CMOC has codified 'ethical red lines' in its Responsible Production and Sourcing Policy (2023), which explicitly prohibits support for non-state armed groups and bans involvement in war crimes, genocide, and crimes against humanity. While it does not have a 'No War' declaration, it maintains a 'zero-tolerance' policy for child and forced labor and requires security forces to adhere to the Voluntary Principles on Security and Human Rights (VPSHR). All security personnel at its DRC sites are reported as unarmed. The company performs comprehensive annual and semi-annual reviews of partners and contractors in high-risk zones, with documented cases of suspending non-compliant suppliers.

Planet-Friendly Business

As a large-scale mining company, CMOC's core operations involve significant land disturbance, high energy consumption, and potential for ecological degradation, which inherently conflicts with proactive environmental stewardship despite the company's role in supplying minerals for the energy transition. CMOC Group Limited (CMOC) demonstrates a structured approach to environmental stewardship with significant disclosures across several KPIs, though its heavy industrial footprint results in high absolute emissions. In 2023, the company reported total Scope 1 and 2 emissions of approximately 1.59 million tonnes CO2e.

While it tracks Scope 3 emissions across multiple categories, the total footprint remains substantial. The company has committed to a Net Zero target for Scope 1 and 2 by 2050, but the lack of a 2030 net-zero goal or interim milestones for Scope 3 places it in a lower tier for this metric. CMOC has made notable progress in renewable energy, reaching a 41.4% share of total energy consumption in 2023, exceeding its 2025 target. It also maintains a strong waste mitigation hierarchy, recycling 86.9% of hazardous waste and 35.5% of non-hazardous waste in 2023, with zero-waste pilot initiatives mentioned. Environmental governance is a strength; the company is fully aligned with TCFD recommendations, having published a standalone TCFD report and conducted comprehensive climate scenario analysis using IEA and IPCC pathways (1.5°C, 2°C, and 3°C+). Biodiversity efforts are significant, with active conservation projects covering approximately 3,800 hectares in Brazil and successful restoration of copper flora in the DRC. Compliance is high, with only one minor administrative penalty reported in 2023 (a late fee in Brazil). However, climate adaptation financing remains a nascent area; while the company committed $1.5 billion to its carbon-neutral plan through 2050, specific spending on community adaptation currently represents less than 1% of total climate-related investment based on reported 2023 figures.

Respect for Cultures & Communities

As a major miner of cobalt and copper in the DRC, CMOC operates in a high-risk sector for human rights and community impacts, including documented concerns regarding artisanal mining encroachment, displacement, and the complex social challenges associated with large-scale mineral extraction in conflict-affected regions. CMOC Group (specifically its TFM subsidiary in the DRC) shows a complex profile of significant community harm balanced by high local economic integration. Regarding displacement, evidence indicates large-scale forced relocations.

Reports document the displacement of over 12,000 people since 2022 for mine expansion, with residents alleging they were forced to sign agreements before knowing compensation amounts (as low as $60). Another report cites 4,289 people displaced from the Kibalasani–Kalweji Road community. While the company reports following IFC standards, the scale and documented community grievances regarding the process warrant a -100 tier. Supply chain and operational community harm are severe. TFM admitted to spikes in toxic sulfur dioxide (SO2) emissions in 2023-2024 after years of denial. Independent monitoring found SO2 levels exceeding WHO guidelines, linked to respiratory illnesses and miscarriages in neighboring communities. Community protests have occurred, including collective complaints regarding air quality and violent confrontations between security forces and artisanal miners (ASM) on the concession. Grievance resolution is mixed; while the company claims a 75.6% resolution rate, NGOs report significant mistrust and lack of transparency. Positively, CMOC demonstrates industry-leading local economic contribution. In 2024, 88.2% of its 17,756-person workforce were local citizens, and 80% of procurement expenditure went to African suppliers. Revenue sharing is independently verified through the TFM Community Fund (0.3% of net proceeds), which has contributed $81.08 million cumulatively and is now managed by a joint committee including community representatives. Cultural heritage impacts appear isolated, with one documented instance of a grave relocation conducted in agreement with local chieftains.

Zero Waste & Sustainable Products

As a large-scale mining company, CMOC's core business involves significant resource extraction and the generation of large volumes of mine tailings and waste rock, which inherently conflicts with the principles of zero waste and circular resource management. CMOC Group Limited demonstrates established waste management practices across its global mining operations, though performance varies by waste stream. Regarding waste diversion, the company reported a 2023 recycling rate of 42.8% for non-hazardous waste and 53.4% for hazardous waste.

While some reports indicate higher hazardous recycling rates (86.9% in ), the consolidated non-hazardous diversion rate remains in the 30-40% range, placing it in the moderate category. Hazardous waste management is rated as 'Good' due to active reduction initiatives, such as upgrading granulation processes in Brazil and reusing reagent bags at TFM, though it still generates significant volumes (277 million tonnes in 2023). The company has implemented over 10 distinct waste reduction initiatives, including tailings recycling for road construction, sulfur recovery projects, and the use of drone monitoring for tailings storage facilities, resulting in a transformative rating for initiatives. Compliance is strong, with only one minor environmental penalty reported in 2023 (a ~RMB 37,000 fine for late payment of inspection fees in Brazil), and no major disposal violations in the past three years. Strategic oversight is evidenced by quantitative targets for specific streams (e.g., 10% slag recycling) and comprehensive supplier requirements. Suppliers must adhere to a Code of Conduct and the Responsible Production and Sourcing Policy, with direct monitoring in regions like Brazil. Customer and stakeholder education is addressed through participation in environmental forums and clear grievance mechanisms, though specific product-end-of-life education for industrial minerals is less documented than general environmental training.