The majority of companies have made a formal commitment to prevent all forms of bribery and corruption, and have assigned board-level responsibilities for carrying out this commitment. A handful of companies have still to make a formal commitment on this issue. Most of the companies with formal commitments in place also show evidence of having assigned financial or staffing resources (e.g. dedicated teams or training programmes) to implement this commitment.

Most companies show some degree of tracking and disclosing data on the functioning of their measures to prevent bribery and corruption, although few disclose details about the types of incidents found or the actions taken. About half the companies have systems to conduct audits or reviews of the effectiveness of their anti-bribery and corruption measures, and a few companies show they have conducted these audits recently. There is very little evidence on any corrective measures being taken as a result of these audits.

While the vast majority of companies show evidence of having whistleblowing mechanisms in place, there is wide variation in the extent to which companies track, and make public, information on the functioning and uptake of these mechanisms. A few companies disclose detailed tracking information, including the number of cases raised, the issues covered, and the actions taken in response. A few companies demonstrate that they have undertaken recent reviews/audits of the effectiveness of their whistleblowing mechanisms, though there is little information on the outcomes of these reviews/audits.

Most of the companies have taken specific measures to ensure that clear roles and responsibilities for responsible business conduct on ESG issues are defined for individual board directors and/or senior managers. Less than half of the companies however show any evidence that they have taken measures to ensure that competency requirements re. ESG are in place for the positions involved. A handful of companies can demonstrate that individual board directors and/or senior managers responsible for such performance are held accountable via documented measures (e.g. integration of ESG performance in remuneration).

Only a few companies show evidence of tracking and disclosing data, against targets and across successive time periods, on the percentage of women at board and senior management levels. Likewise, only a few companies show evidence of auditing and/or reviewing the effectiveness of their interventions (programmes, initiatives, etc.) to improve gender balance at senior management level. Only one company shows (limited) evidence of taking responsive action, on the basis of the findings of these audits and/or reviews, to seek to improve its gender balance at senior management level.

With only a few exceptions, companies generally do not disclose legal titles (e.g. contracts, permits, licences, leases, conventions, agreements) that grant them the rights to extract mineral resources at their mine sites. Those that do, have disclosed for only a very limited number of mine sites. In the very rare cases where legal titles are disclosed, they are usually available in full and on the corporate websites.

Less than half of the companies disclose their corporate structure mentioning all tax jurisdictions where they have registered entities and under what names they are known in that place. A handful of companies formally report on their approach to tax transparency, including their position or strategy on tax optimisation. A few companies disclose data on all tax benefits, tax holidays, tax relief and/or tax credits they receive at both local and national levels.

Only one non-state-owned company discloses the names of all its ultimate beneficiary owners. Two-thirds of the companies disclose the names of the Directors owning shares, and the number of shares owned. None of the non-state-owned companies publicly identify any politically exposed beneficiaries.

Less than one-third of the companies disclose, on their corporate websites, all payments to national and sub-national governments on a project-disaggregated and annual basis. Most companies disclose payments to national governments, although most often not on a project-disaggregated basis.

About one-third of the companies disclose the names and responsibilities of some of those involved in their lobbying activities, for the most part in jurisdictions subject to related legal requirements e.g. the US, the EU or Canada. About one-third of the companies disclose the issues on which they engage but none of these companies disclose details of the outcomes sought. About half of the companies disclose the names of some of the public institutions or public officials engaged in the context of their lobbying activities.

While the vast majority of companies mention the existence of a responsible sourcing approach, only a few companies demonstrate they have formal systems in place to assess the human rights, labour and environmental issues associated with their suppliers and contractors. Other companies have set human rights, labour and/or environmental requirements for their current and potential suppliers and contractors but provide little evidence of pro-active due diligence on all such business partners, based on these requirements.