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Twenty civil society organisations from Albania, Armenia, Azerbaijan, Bosnia and Herzegovina, Georgia, Mongolia, Uganda, Ukraine and Uzbekistan, as well as seven international environmental and human rights organisations, are calling on the European Bank for Reconstruction and Development (EBRD) to reconsider its approach to mining investments.

In their recommendations, civil society groups urge the Bank to do more to safeguard the environment and welfare of local communities and to take action to reduce the demand for critical raw materials.

The EBRD is currently in the process of revising its Mining Sector Strategy for 2024 to 2028. The draft document proposes an increase in investments in mining critical raw materials required for the green and digital transition, as well as the promotion of exploration.

On 15 September, civil society organisations submitted recommendations regarding the EBRD’s mining strategy, advocating for the following measures:

  • Prioritise the circular economy over just mining;
  • Focus on reducing material footprints and promote recycling;
  • Ensure that no mining investments are made in countries that do not enforce environmental laws;
  • Define no-go zones and prohibited technologies;
  • Guarantee Free Prior Informed Consent for Indigenous Peoples and consent from all affected communities;
  • Deliver tangible benefits to local communities in the countries where the EBRD operates.

Although the draft strategy highlights the importance of improving relations between mining companies and local communities, public consultations on the draft were conducted during the summer holiday period. A very small number of handpicked groups were invited at extremely short notice to local consultation events, seriously limiting public input.

The mining sector has a shameful track record of pollution, human rights abuses, community resistance and retaliation against activists around the world. It remains the most perilous sector for environmental defenders, with almost 30 per cent of annual attacks occurring within the industry. EBRD-funded projects in Armenia (Amulsar) and Bosnia and Herzegovina (Adriatic Metals) have already prompted complaints by affected communities to the EBRD’s Independent Project Accountability Mechanism (IPAM) due to environmental pollution and lack of public consultation.

Nina Lesikhina, Policy Officer at Bankwatch, says: ‘Business as usual is no longer an option. Relying solely on environmental and social safeguards is insufficient, given their gaps and inadequate implementation. The EBRD needs to consider each country’s capacity to implement mining projects sustainably and how to reduce demand for critical raw materials in the first place. The imperative for a green transition should not be used as an excuse to reduce efforts, but as a motivation to do more to ensure that the transition is truly green and equitable.’

Sukhgerel Dugersuren, Chair at Oyu Tolgoi Watch, Mongolia, says: ‘If the EBRD and other development banks increase financing for mining, corporations will scramble to secure critical and/or transition minerals. This will have further negative impacts on climate change, contaminating the environment, depleting water resources and deepening desertification processes. The Mongolian economy is dependent on a single sector – mineral extraction – which is closely tied to the Chinese market. Any future mining strategy must be guided by principles that balance economic, geopolitical and other risks.’

Gaelle Dusepulchre, Deputy Head of the Business, Human Rights and Environment Desk at the International Federation for Human Rights, says: ‘Mining projects are among the most harmful to human rights and the environment. Any mining strategy must promote a truly just transition. These projects not only require increased due diligence but also rely on the meaningful participation and consent of communities likely to be affected. Protecting human rights and environmental defenders is just as essential.’