The Transition Minerals Tracker (Tracker) captures publicly reported allegations of environmental and human rights abuses against companies mining one or more of the following nine minerals: bauxite (since 2024), cobalt, copper, iron ore (since 2024), lithium, manganese, nickel, rare earth elements (since 2025), and zinc. Only allegations against globally significant, large scale producing mines (or mines that have recently closed or will imminently commence production) for each of the nine 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 (299 as of 2025) has also been reviewed and expanded in 2025 to ensure it captures top producing mines for each of the minerals, with the inclusion of additional mines. The full list of mines is available in the downloadable file on the Tracker page.

Sources

Allegations are primarily collected through a filtered search by company on the Business and Human Rights Centre website. This includes allegations appearing in articles from international and local media outlets in all languages of the 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.

The Business and Human Rights Centre’s Just Transition Litigation Tracking Tool (JTLTT) is a hub for lawsuits against companies undertaking, and/or states authorising, transition mineral mining or renewable energy projects. Lawsuits and regulatory action in the Tracker include lawsuits that are not part of the JTLTT because they do not fit the JTLTT methodology  or have not been selected to be profiled at this stage. Additionally, some mining-related lawsuits included in the JTLTT are not included in the Tracker because they concern mines that do not meet the criteria in the Tracker methodology.

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.

The methodology for our database of HRD attacks was updated in 2025. The cases published in our database are illustrative and do not include all cases we have documented of attacks on defenders raising concerns about business-related risks and harms. Starting in 2025, the database includes cases where both defenders and companies are named in public sources and the defender has consented to the inclusion of the attack in the database. All attacks we have documented are included in our aggregate statistics and analysis. 

Explore the methodology of the database of HRDs attacks

Timeframe of allegations

Many allegations are, by nature, a compilation of incremental impacts and can therefore be difficult to restrict to a specific timeframe. For each allegation we indicate the date when the alleged abuse was originally reported.

Seeking company responses

In line with the 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. In the case of joint venture ownership of a given project accused of abuse or harm, we do contact the joint venture, since we expect them having discussions with their parent companies. In certain cases, where we cannot find joint venture contacts, we contact instead the participant with major shares in the joint venture.

Human rights policies 

Our analysis includes an assessment of whether each of the mining operations in the Tracker is covered by a human rights policy. A parent company’s general human rights policy will not be considered to cover a particular mining operation unless the policy explicitly says that it applies to subsidiaries. In the case of joint ventures, an operation will be considered to be covered by a human rights policy if the joint venture entity has a human rights policy, or if shareholder/s that own over 50% of the joint venture have a human rights policy that applies to joint ventures. If joint venture participants’ human rights policies indicate that the company will seek to influence its joint venture partners, rather than apply the policy to joint ventures, the operation will not be considered to be covered by a human rights policy.

Scope and limitations

The Tracker captures publicly reported information on alleged abuses committed by mining companies. Business and Human Rights Centre does not independently verify the accuracy of the allegations. When relevant and possible, Business and Human Rights Centre uses the Company Response Mechanism (see above) to seek responses from companies implicated in the commission of the alleged abuses. Similarly, the 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 the Centre acknowledges that there are numerous serious allegations of environmental and human rights abuses linked to those operations.