Navigating TPRM Challenges in Mining: Best Practices for Teams Under Pressure

Third-party risk management (TPRM) has become one of the most complex, high-stakes responsibilities on a mining risk or compliance leader’s plate in 2026. When third parties go wrong, your team deals with the fallout (regulators, communities, investors, and the board) so the real goal is building a program that lets you anticipate issues, reduce surprises, and protect the business without slowing it down.​

The Challenges of TPRM in Mining

If you lead TPRM or compliance in mining, you are not just managing your own company, you are managing an entire ecosystem of partners. License brokers, logistics providers, EPC contractors, community consultants, joint venture partners, and security firms all sit between your policies and what actually happens on the ground, usually across multiple high-risk jurisdictions.​​

You feel this pressure in several ways:

Evolving governance

In many cases, you operate in countries that rank poorly on Transparency International’s Corruption Perceptions Index, where “how things get done” often involves informal payments and opaque processes. The people closest to these interactions are rarely your employees, they’re agents, local consultants, and other third parties, but regulators still hold your company responsible when something crosses the line.

ESG expectations have also moved the goalposts. It is no longer enough to manage only your own operational footprint; investors, NGOs, and regulators now expect you to show that the entire value chain operates responsibly, including environmental performance and human rights practices among your third parties. That means your supplier, contractor, and intermediary choices are increasingly viewed as an ESG decision, not just a commercial one.

On top of that, rules such as the EU Corporate Sustainability Due Diligence Directive (CSDDD), the EU Forced Labor Regulation, and France’s Corporate Duty of Vigilance Law explicitly focus on harms linked to your business partners, not just your own entities. As these frameworks mature, your third-party program becomes a core part of both your ESG and legal strategy rather than a side process.

You are also navigating a dense mesh of environmental and ABAC regulations across the same third parties. U.S. laws like the Clean Air Act and Clean Water Act, the EU’s Circular Economy Action Plan, and anti-bribery regulations such as the FCPA, UK Bribery Act, CFPOA, Sapin II, and regional laws in Africa, Latin America, and Asia-Pacific all converge on the partners that support your operations. This forces your program to reconcile multiple rule sets every time you engage or renew a relationship.

High demand, fragile ecosystems

Meanwhile, demand for critical minerals like cobalt, copper, lithium, and nickel is exploding. The International Energy Agency projects an approximately ninefold increase in minerals needed for EV batteries between 2024 and 2050, and more than 350 new mines may be required by 2035 to keep up. That level of growth stretches your supplier and contractor base, making it harder to be selective and increasing the temptation to accept higher-risk partners just to keep projects moving.

Finally, geopolitical and climate shocks have exposed how fragile your logistics really are. Events like the 2024 Houthi attacks in the Red Sea and drought-related disruptions in the Panama Canal showed how quickly shipping routes can be compromised. When third parties cannot deliver because of these disruptions, the operational, financial, and compliance impacts land squarely on your team.

When all of this is tracked in spreadsheets and emails, your team is constantly reacting instead of steering. The good news is that many of these pain points can be eased by reframing TPRM around a few practical risk domains and then building processes that work for your people and partners.​​

Major TPRM Risk Domains in Mining

Most mining companies face similar patterns: ABAC and licensing risk, ESG and human rights risk, operational resilience risk, and governance/data risk. Thinking in these four buckets helps you move away from “everything is urgent” to “this is where we really need to be excellent.”​​

ABAC and license-related risk: where regulators look first

If you ask, “Where could we end up in the headlines?” ABAC and licensing is usually a top TPRM risk in mining. You rely on third parties for concessions, permits, land access, environmental approvals, customs clearance, and local content, exactly the places where corruption risk spikes.​​

What you’re up against:

• Agents and consultants who manage relationships with public officials on your behalf, often in environments where “informal” payments are normalized.​​

• If they cross the line, you are on the hook under the FCPA, UK Bribery Act, CFPOA, and Sapin II, regardless of how strong your internal code of conduct is.​​

• An enforcement landscape that’s shifting, not disappearing. As of early 2025, the U.S. Department of Justice paused some FCPA enforcement. Even with this pause, ABAC experts emphasize that the law hasn’t gone away and global expectations haven’t softened.​​

How you can start to regain control:

• Move due diligence from “box-ticking” to “decision support.” Instead of just screening names, build a risk-based process.​

• ABAC clauses, audit rights, and clear termination and remediation steps should be standard for high-risk intermediaries, and you should revisit them regularly instead of treating them as one-time legal boilerplate.​

Both steps give you something you can show to regulators, boards, and partners: not perfection, but a defensible, risk-based approach that shows you’ve thought through where corruption risk actually lives in your third-party ecosystem.​​

ESG, human rights, and social license beyond your own fence line

Even if your own sites are well controlled, ESG issues often emerge where your oversight is weakest, through contractors and partners. This is especially true in mining, where operations are close to sensitive ecosystems and vulnerable communities.​​

Typical challenges you face:

• Third parties running activities like contract mining, waste and tailings management, or logistics that drive a large share of your environmental footprint yet sit outside your direct operational control.​​

• Security providers, community liaison firms, or local subcontractors interacting daily with Indigenous and local communities, making decisions that can either build or destroy your social license.​​

• New and emerging rules that explicitly expect you to identify and address human rights and environmental harm in your value chain.​

• Voluntary expectations from frameworks which your investors and customers increasingly treat as a baseline.​

How you can make this more manageable:

• Treat ESG risk assessment as part of TPRM, not a separate project. When you assess a third party, factor in their environmental practices, community track record, and human-rights exposure alongside ABAC and financial risk.​​

• Build simple proof points. Collect evidence like certifications, audit results, and grievance data for key partners and link it to their third-party profile.​

This approach helps you show that ESG is embedded in how you choose and manage partners, not just something you report on once a year.​​

Operational and supply chain resilience: when compliance and continuity collide

Your job is not only to avoid fines; it’s also to keep the business running when the world doesn’t cooperate. The same third parties that create compliance exposure can also be single points of failure in your operations.​

You probably see issues like:

• High dependence on a small set of suppliers or partners in certain regions, particularly as global demand for critical minerals ramps up and capacity tightens.​

• Vulnerability to shocks (geopolitical, sanctions-related, or climate-driven) that disrupt logistics corridors and dramatically increase freight costs or lead times.​

• Fragmented visibility across functions, where no one sees the whole picture for each critical third party.​​

To reduce these surprises, invest in a TPRM solution that allows for a single inventory of third parties so you can quickly see where high-risk and high-dependency overlap.​ This allows you to talk to your executives in business language: “Here are the third parties that could cause both a shutdown and a regulatory issue, and here’s what we’re doing about it.”​

Governance, data, and disclosures: making the program defensible

From a leadership perspective, one of the biggest worries is, “If something goes wrong, can we show we had a reasonable system in place?” That’s where governance, data, and disclosure management come in.​

Common pain points include:

• Trying to track COI, gifts and hospitality, sponsorships, and outside roles through scattered forms, email approvals, and local practices that vary site by site.​

• Increasing reporting expectations under EITI, Canada’s Extractive Sector Transparency Measures Act (ESTMA), and EU sustainability rules, which demand clean, consistent data on payments and supply chain practices.​

• A lack of central visibility into who disclosed what, which red flags were escalated, and how issues involving third parties were handled.​​

Practical steps that help you sleep better:

• Create one system of record for TPRM-related data so you can pull a complete picture for any third party or region when needed.​

• Connect disclosure workflows to your third-party records, so repeat patterns (for example, recurring hospitality with high-risk officials tied to a particular intermediary) are visible and can trigger action.​

This doesn’t just make audits easier; it also reduces your personal exposure as a leader by showing that you have structured, documented processes in place.​

Build a Practical, Problem-Solving TPRM Program

Once you frame TPRM through these domains, the next challenge is execution, how to make the program work for your team and your sites. That usually comes down to connecting systems, prioritizing risk, deepening due diligence where it matters, strengthening reporting channels, and enabling people in the field.​​

Build a connected, centralized TPRM framework

Many mining leaders are moving away from scattered tools and point solutions to a connected TPRM platform approach. The goal is simple: one place where you can see your third parties, the risks they carry, and the actions your teams have taken.​​

When you can pull up a third party and see everything in one view, conversations with regulators, auditors, and executives become much more straightforward.​​

Make third-party due diligence useful, not just compliant

Third-party due diligence should help you decide who to work with and how, not just generate a PDF to file away.​​

A more useful model:

• Start with broad screening (sanctions, watchlists, adverse media), then go deeper on high-risk cases with beneficial ownership, PEP status, and enforcement history checks.​

• Use external and open-source data to illuminate ownership and unusual corporate structures, especially in jurisdictions known for weak transparency.​

• Refresh risk profiles periodically or when something important changes rather than leaving them static after onboarding.​​

• Tie the results directly to decisions: onboarding, contract language, monitoring intensity, and training requirements, so high-risk partners are managed more closely by design.​

This turns due diligence into a living part of how your company chooses and manages partners, rather than a one-time hurdle.​​

Turn disclosures and whistleblowing into early-warning systems

If you are only hearing about issues once they’ve become crises, your reporting channels are not working for you.​

To change that:

• Use a consistent, digital process for disclosures (conflicts of interest, gifts and hospitality, sponsorships) from employees and, where appropriate, from third parties themselves.​

• Make whistleblowing channels easy to access and trustworthy for employees, contractors, and even local communities, with anonymous options where legally allowed.​​

• Feed incidents involving third parties directly into their risk profiles so that patterns drive real changes, more monitoring, new controls, or ultimately ending the relationship.​​

• Use analytics across disclosures, incidents, and due diligence to spot emerging themes, such as recurring issues with a particular vendor or a specific country.​

This shifts your posture from “we respond when something blows up” to “we see the smoke before the fire.”​

Make it easy for people in the field to do the right thing

Most of the real risk decisions are made far from headquarters, at remote sites, border crossings, and community meetings. If those teams don’t have simple tools and clear guidance, even the best policy won’t help.​

When people understand both the “why” and the “how,” they are much more likely to act as an extension of your compliance and risk team rather than an unmanaged risk.​

How GAN Integrity Supports Mining Leaders on TPRM

For many mining organizations, the missing piece is not intent, it’s infrastructure. GAN Integrity’s TPRM solution is built to give risk and compliance leaders the visibility and tools they need to manage third-party risk in a way that is both robust and workable in a mining context.​​

Interested in learning more? Speak with our TPRM experts today.