Insights

Double materiality in the South African mining industry

March 2026

Some large mining companies such as Anglo American, Valterra Platinum, Exxaro Resources, Sibanye-Stillwater and African Rainbow Minerals have incorporated structured processes that assess both financial and impact (or non-financial) materiality. However, adoption across the sector (including smaller or non-listed entities) is not yet universal.

Regulatory guidance from the JSE, as well as global developments such as ISSB (International Sustainability Standards Board) and GRI (Global Reporting Initiative) standards, are accelerating the shift to double materiality in South Africa.

Importance of double materiality in the mining industry

Double materiality requires companies to assess:

  • Financial materiality — how ESG (environment, social, governance) risks and opportunities affect enterprise value, and
  • Impact materiality — how the company’s activities impact society and the environment.

For mining companies, assessing these risks is critical given their significant environmental footprint (GHG emissions, water use, biodiversity impacts) and social footprint (employment, community impact, labour relations).

Climate-transition risks, carbon-pricing exposure, regulatory compliance, and access to capital are financially material. In contrast, emissions, water use, community impacts, and worker health and safety are material impact issues that directly affect stakeholders and, by extension, a company’s sustainability.

Applying the double-materiality approach therefore ensures that sustainability is embedded in core strategy, risk management and capital-allocation decisions rather than treated as a reporting exercise.

Mapping material topics into incentive remuneration

To drive real accountability, material ESG risks should be translated into performance metrics in executive and management incentive structures. Examples include:

  • Scope 1, 2 and relevant scope 3 emission-reduction milestones
  • Progress toward accepted global benchmarks, such as Science Based Targets initiative (SBTi) commitments
  • Energy-efficiency improvements and transition to renewable energy
  • Water stewardship
  • Biodiversity protection targets
  • Workplace health and safety metrics
  • Community development outcomes.

When climate-related material topics are weighted in short- and long-term incentive plans, executives are directly accountable for transition outcomes. This alignment reduces the so-called greenwashing risk and enhances credibility in capital markets. It also signals to investors that sustainability performance is treated with the same discipline as financial performance.