In March 2026, the Business and Trade Sub Committee on Economic Security, Arms and Export Controls launched an inquiry to consider how domestic production and trade can support a secure supply of critical minerals for UK industry, and assess the likely impact of the proposals set out in the Government’s strategy. We made the following submission to the call for evidence on critical minerals.
Introduction
1. London Mining Network (LMN) is an alliance of human rights, development, environmental and solidarity groups aiming to hold London-based mining companies to account by working closely with mining-affected communities. We have worked on the issue of Critical Minerals and Just Transition for the past 7 years, amplifying the voices of communities and workers impacted by expansions in Critical Mineral mining.
2. We respectfully submit the following information and recommendations in response to specific questions outlined in the call for evidence.
To what extent are the priorities set out in the Government’s critical minerals strategy the right ones?
3. The Government’s Critical Minerals Strategy is closely aligned with the UK’s Industrial Strategy, seeking to support rapid industrial growth across a range of sectors including clean energy, advanced technology and military production.
4. The Strategy sets out targets for vast expansions in UK industrial Critical Mineral demands, including a near doubling of annual copper demand and eleven-fold increase in lithium demand by 2030.
5. We believe the focus on securing unprecedented expansions in Critical Mineral supplies to fuel industrial growth is the wrong one. Increased mineral demands would fuel rapid expansions of mining, which would fuel social and environmental injustices across global mineral supply chains. Mineral resources should be prioritised for decarbonisation, not military production or data centre expansions.
6. The risk of social and environmental injustices across the UK’s mineral supply chains requires strengthened environmental and social standards in the extractives sector and their fuller implementation. However, mining is an inherently destructive industry that transforms landscapes with often irreversible environmental harms and strengthened regulation is not sufficient to mitigate the risks.
7. Environmental harms include carbon emissions, the depletion and redirection of water systems, acid mine drainage, toxic waste, tailings dam failures and long-term legacy issues after extraction ends. UN experts estimate that a more than threefold increase in metal mining since 1970 means it contributes to 8% of global climate impacts and that 40% of mining activities globally occur in ecoregions with strong declining trends in ecological integrity.
8. Many minerals that are expected to be produced in greater quantities have ore grades of less than 1% (cobalt, copper, tungsten) and grades are declining as higher grade ores are consumed and the mining industry develops technologies to process lower grade ores. For each tonne of metal produced, more than 99 tonnes of tailings are generated. The generation of tailings slurry will be deposited in tailings dams, large, high-risk structures.
9. Social harms include land dispossession, intimidation, labour abuses, and the erosion of subsistence economies and cultural ways of living. Globally 69% of projects for energy transition minerals are on or near indigenous lands and/or peasant land.
10. The UK must minimise its demand for critical mineral supplies to mitigate the risk of fuelling social and environmental harms. Demand expansions quoted in the Strategy would take the UK’s consumption of several Critical Minerals to greatly inequitable and unsustainable levels. The Critical Minerals Intelligence Centre have estimated that the UK’s plans could require between 15 and 40 per cent of current global lithium production and between 10 and 29 per cent of current global graphite production.
11. Mining affected communities in Chile, Peru, South Africa, Indonesia and Northern Ireland have warned that the UK’s strategy, in fuelling increased demand for mining, would fuel social and environmental harms across global supply chains. Action for Ecology and People Emancipation have warned that ‘the UK Government’s Critical Minerals Strategy threatens to fuel land dispossession, seizure of indigenous territory, and labor exploitation by increasing demand for nickel’. Nickel mining in Indonesia, which supplies over 50% of the world’s nickel, has accelerated and expanded deforestation as local communities have their lands seized. Environmental defenders are being criminalised, while mine workers face ‘brutal exploitation’, with low-pay, long hours, poor health and safety standards, and the eradication of trade unions.
12. Demand management and the reduction of mineral demands are crucial in minimising social and environmental impacts across global supply chains and building resilience against future supply shocks. Industrial strategy should prioritise efficient use of raw materials, long life of products, ease of recycling and development of recycling systems. The National Engineering Policy Centre has found that through such interventions the UK could halve its material footprint.
13. Supply side solutions are also critical to tackling social and environmental harms. The UK should prioritise the introduction of mandatory due diligence standards for UK businesses.
How should the UK work with global partners to improve environmental, social and governance standards across the critical mineral sector?
14. The UK’s mining ecosystem plays an outsized global role in the global critical mineral sector. 171 mining companies are listed on the London Stock Exchange, including its secondary Alternative Investment Market for junior mining companies. Many of the world’s most powerful mining companies are headquartered or listed in London, including: Glencore, Anglo American, Rio Tinto, Antofagasta and Fresnillo. The UK also hosts the London Metals Exchange, the world’s largest market for industrial metals and the benchmark price-setter for key critical minerals.
15. British mining companies listed on the London Stock Exchange or headquartered in London are linked to numerous human rights abuses and allegations of social and environmental harm. Business and Human Rights Centre data shows that Glencore has had the joint highest number (80) of allegations of any mining company engaged in transition mineral mining. Anglo American has had 13 allegations. Rio Tinto has had 10.
16. The London Metals Exchange trades in metals sourced from environmentally and socially harmful mining. London Mining Network and Global Legal Action Network have alerted the London Metals Exchange and Financial Conduct Authority to the risk that copper sourced from the Grasberg mine in West Papua could constitute the ‘proceeds of crime’, since it is produced in circumstances that would breach UK criminal law if they were to occur in the UK. Increasing accountability and enforcement of British mining companies and the London Metals Exchange is crucial in improving environmental, social and governance standards across the critical mineral sector.
17. The UK should prioritise enforcing mandatory due diligence standards on UK listed businesses. The Financial Conduct Authority should ensure that UK-listed companies recognise and respect international human rights and environmental standards to which the UK is a signatory, including the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, the UN Declaration on the Rights of Indigenous Peoples and the Convention on Biological Diversity, and implement the highest environmental, social, cultural, labour, and health and safety standards.
18. Regulation of the Alternative Investment Market (AIM) is not sufficiently rigorous to prevent harm and should be improved to ensure that AIM-listed companies fully comply with the human rights, social, cultural, labour and environmental laws, regulations and conventions noted above.
19. The UK should introduce a Business, Human Rights and Environment Act, creating a legal requirement for UK companies, financial institutions and the public sector to prevent human rights abuses and environmental harm in their operations, subsidiaries and value chains.
20. The UK should avoid the trap of thinking critical mineral supply chain problems can be avoided through prioritising ‘good enforcement countries’.
21. It is important to consider the problems in governance, and performance, in supposedly safe jurisdictions. There are numerous cases of conflict and accusations of rights abuses involving local, primarily indigenous, communities within the likes of Canada, Australia and the USA. Many of these conflicts centre on whether communities can exercise their right to free, prior and informed consent. In Australia States have been criticised for a lack of legal rights for aboriginal people, following the disastrous destruction of the sacred site of Juukan Gorge by UK mining company Rio Tinto in 2020.
22. We thank the Government for the opportunity to submit evidence and look forward to further engagement.