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ESG and Compliance

MMG places a strong emphasis on responsible environmental and social performance, underpinned by robust governance. These commitments are integral to our growth strategy and support:  

  • Risk management: We proactively manage reputational and regulatory, and operational risks through integrated ESG governance and compliance systems.  
  • Cost control and efficiency: Responsible practices reduce inefficiencies and support long-term cost management. 
  • Stakeholder relationships: Transparent engagement and disclosure build trust with investors, communities, and regulators.  
  • Talent attraction and retention: Our ESG commitments enhance our ability to attract and retain skilled and values-aligned employees. 

ESG Reporting and Materiality  

MMG’s ESG reporting is guided by the Global Reporting Initiative (GRI) Standards, the International Council for Mining and Metals (ICMM) Mining Principles, and the Hong Kong Stock Exchange (HKEX) ESG Code. In 2024, we completed a materiality refresh, reducing our material topics from 17 to 13 to better reflect stakeholder priorities, global trends and operational impacts. Key features of our ESG reporting include: 

  • Materiality assessment: Conducted in line with GRI 3 and ICMM guidance, our assessment identifies ESG risks and opportunities that influence business performance and stakeholder expectations. 
  • External assurance: Elements of our Sustainability Report are externally assured in accordance with the ICMM Assurance Procedure and includes, but is not limited to, disclosures aligned with IFRS S1 and S2, TCFD, and the Taskforce on Nature-related Financial Disclosures (TNFD).  
  • Data governance: ESG data automation and governance controls are being strengthened across all sites to meet audit-level rigour required by IFRS S1 and S2. 

Additional Information: For further details on MMG’s approach to health and safety, social performance, environmental performance, stakeholder relationships, and compliance with laws and regulations, visit our website at www.mmg.com  

Corporate Governance 

We maintain a high standard of corporate governance through several key practices. These include a quality Board, robust internal controls, transparency, and accountability to shareholders. However, our commitment to good governance extends beyond the Boardroom. Our executive management ensures that governance practices are embedded throughout the organisation. 

Key points regarding MMG’s corporate governance approach are as follows: 

  • Principles of good governance:
    MMG adheres to the principles of good corporate governance outlined in the Corporate Governance Code of the Hong Kong Listing Rules and those established by the ICMM. These principles guide our decision-making processes, risk management, and overall governance structure ensuring transparency, accountability, and ethical leadership.  
  • Committees and frameworks:
    Our Audit and Risk Management Committee and the Governance, Remuneration, Nomination, and Sustainability (GRNS) Committee operate under clear terms of reference. Additionally, we have various executive management committees, including the Executive Committee, Disclosure Committee, Investment Review Committee, Mineral Resources and Ore Reserves Committee, and Code of Conduct and People Committee.
    The Executive Committee specifically reviews safety, health, environmental, and social performance to enhance efficiency and effectiveness. The Board also addresses specific SHEC (Safety, Health, Environment, and Community) matters, including material issues, incidents, and remediation strategies. 
  • Sustainability Framework
    MMG’s Board formally endorsed the Sustainability Framework in 2023, establishing a structured and organisation-wide approach to sustainability governance. The Framework is aligned with the ICMM Mining Principles and guides the identification, review, and oversight of all material sustainability issues across MMG’s operations. It integrates with MMG’s Integrated Business Planning processes and cascades key performance indicators (KPIs) to relevant business functions. The Framework also reflects MMG’s commitments to external reporting standards and disclosure requirements, including those informed by GRI, the UN Global Compact, and other internationally recognised best practices
  • Informed Approach:
    Our corporate governance approach is informed by various policies, including the Corporate Governance Policy, People Policy, Shareholder Communication Policy, SSHEC Policy, and Human Rights Policy. While there is no universal formula for good corporate governance, MMG emphasises compliance with internal standards, as well as external obligations set by the CG Code of the Hong Kong Listing Rules and the ICMM. 

MMG’s Approach to Mineral Contract Transparency 

As part of our ICMM membership commitments and our alignment with the Extractive Industries Transparency Initiative (EITI), MMG respects the right of governments to make decisions about revenue transparency and we recognise the benefits increased transparency can provide to enhancing governance, combating corruption, and driving more sustainable growth. 

In line with the ICMM’s Transparency of Mineral Revenues Position Statement, MMG commits to disclosing any mineral development contracts granted or entered into from 1 January 2021 in all countries in which we operate. 

At this stage, MMG has not entered into any new contracts or amended any existing contracts or licences since 2021.  

Two of our operations’ contracts are currently publicly available online: 

MMG will disclose additional contracts as new ones are signed or amended and will make them available here in line with our transparency commitments. 

For more information about MMG’s commitment to the sustainable development of the regions in which we operate, as well as the social, economic and institutional benefits of mining, please see our 2024 Tax and Community Contribution report. 

Compliance 

The Governance, Remuneration, and Nomination Committee holds the responsibility for formulating and evaluating the Company’s policies and practices related to corporate governance, including the Code of Conduct. Additionally, the committee oversees MMG’s adherence to the Listing Rules and other relevant legal requirements. 

Meanwhile, our Executive Committee diligently monitors our performance, ensuring alignment with the Group’s policies, standards, and regulatory obligations concerning safety, health, environment, and community matters. 

Business Ethics 

MMG’s core values and Code of Conduct underpin our commitment to ethical business practices and responsible stakeholder engagement. These principles guide our long-term relationships with communities, employees, governments, investors, and suppliers, and are embedded across our governance structures and operational processes.  

Code of Conduct Oversight 

Our Code of Conduct sets behavioural expectations for all MMG employees, contractors, and suppliers. It addresses key areas including: 

  • Conflict of interest 
  • Fraud prevention 
  • Anti-corruption 
  • Legal and regulatory compliance 
  • Respect for human rights 

Oversight of the Code is provided by the Code of Conduct and People Committee, chaired by the Executive General Manager, Corporate Relations. This committee ensures that ethical standards are upheld across the organisation and that any breaches are addressed transparently and consistently. 

In 2024, MMG commenced a comprehensive review of the Code of Conduct to strengthen its alignment with modern slavery legislation and international human rights standards. Updates include clearer guidance on managing ethical risks in high-risk jurisdictions and expanded training modules for employees and directors.  

Whistleblower Framework 

MMG maintains an independent, confidential Whistleblower Service available to employees, contractors, suppliers, and external stakeholders globally. The Whistleblower Framework outlines: 

  • How to report improper conduct 
  • Protections for whistleblowers 
  • Investigation procedures 
  • Remedial actions 

This framework is integral to MMG’s Corporate Legal Compliance Standard and is aligned with GRI 102-17 and ICMM Performance Expectations. It complements our stakeholder grievance mechanisms, which allow anonymous reporting and strengthen protections for those raising concerns. 

Our Whistleblower Framework can be found here. 

Anti-corruption Measures: 

All MMG personnel, including directors and senior management, are required to comply with our Anti-Corruption Standard and Framework. This includes: 

  • Mandatory online and face-to-face training 
  • Annual declarations of compliance 
  • Integration of anti-bribery controls into procurement and contracting processes 

In 2024, MMG reported zero confirmed cases of corruption or significant non-compliance with the Code of Conduct. Our anti-corruption practices are aligned with GRI 205, HKEX ESG Code, and S&P Global’s governance criteria. 

Performance Monitoring: 

MMG tracks performance against key ethics indicators, including: 

  • Completion rates for ethics and anti-corruption training 
  • Timeliness and resolution of grievances 
  • Whistleblower case outcomes 

These metrics are reviewed quarterly by the Executive Committee and the Governance, Remuneration, Nomination and Sustainability (GRNS) Committee. Results are disclosed in our Sustainability Report and ESG Databook. 

Addressing Human Rights Challenges: 

We recognise that some jurisdictions where we operate present complex human rights risks. MMG addresses these through: 

  • Participation in the EITI 
  • Integration of human rights into our Code of Conduct and Supplier Code of Conduct 
  • Open dialogue with host communities and civil society organisations 

Our Supplier Code of Conduct was updated in 2024 to include stronger provisions on modern slavery, child labour, and collective bargaining rights. Suppliers are required to conduct due diligence aligned with the OECD Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. 

Read more about MMG’s Human Rights Framework. 

Strengthening ESG and Compliance Governance 

MMG continues to evolve its ESG and compliance practices to meet the expectations of stakeholders, regulators, and ESG rating agencies. In addition to our existing frameworks, we have introduced several enhancements to reinforce governance, transparency, and accountability across the organisation. 

Board ESG Expertise and Diversity 

MMG’s Board composition reflects a commitment to diverse perspectives and ESG competence. In 2024, Board ESG oversight was expanded through the appointment of members with expertise in climate risk, human rights, and sustainable finance. The Board includes independent directors with backgrounds in mining, law, and international development, supporting informed decision-making on ESG matters. 

Executive Remuneration Linked to ESG 

Executive remuneration is directly linked to ESG performance. Key performance indicators (KPIs) include safety outcomes, emissions reduction, community satisfaction, and ethical conduct. These metrics are reviewed annually by the Governance, Remuneration, Nomination and Sustainability (GRNS) Committee and disclosed in our Directors Report, which is part of MMG’s Annual Reports. 

Cybersecurity and Data Privacy Governance 

MMG has strengthened its cybersecurity governance framework, including: 

  • Annual cyber risk assessments across all sites 
  • Mandatory data privacy training for employees 
  • Incident response protocols aligned with ISO/IEC 27001 

No material breaches were reported in 2024, and systems are subject to regular third-party penetration testing. 

ESG Risk Integration in Enterprise Risk Management 

ESG risks are fully integrated into MMG’s Enterprise Risk Management (ERM) framework. Climate change, community relations, and regulatory compliance are assessed alongside financial and operational risks. Risk registers are updated quarterly, and mitigation plans are reviewed by the Executive Committee. 

Tax Transparency and Responsible Tax Practices 

MMG adheres to responsible tax principles, including: 

  • Transparent reporting of tax contributions by country 
  • Alignment with OECD Base Erosion and Profit Shifting (BEPS) guidelines 
  • Annual publication of the Tax and Community Contribution Report 

MMG supports the Extractive Industries Transparency Initiative (EITI) and discloses mineral contracts in line with ICMM commitments. 

ESG Training for Board and Employees 

 MMG recognises that building ESG capability across all levels of the organisation is essential to delivering on its sustainability commitments. ESG training is embedded in MMG’s governance model and is overseen by the Governance, Remuneration, Nomination and Sustainability (GRNS) Committee, which ensures that ESG performance is integrated into executive scorecards and remuneration. 

  • Board-Level ESG Training 
    • Directors receive regular briefings and training on ESG risks, regulatory developments, and stakeholder expectations. 
    • ESG topics are incorporated into Board strategy sessions, with a focus on climate risk, human rights, and governance standards. 
    • The GRNS Committee reviews ESG-linked KPIs quarterly, including safety outcomes, emissions reduction, community satisfaction, and ethical conduct, as disclosed in the MMG Directors’ Report 2024. 
  • Employee ESG Training 
    • All employees complete mandatory ESG training modules, including: 
      • MMG’s Code of Conduct 
      • Anti-Corruption Standard 
      • Human Rights and Modern Slavery Awareness 
      • Environmental and Social Risk Management 
    • Site-specific workshops are conducted to address local sustainability priorities and risks. 
    • ESG training is tracked through MMG’s compliance systems, with performance monitored and reported quarterly. 

ESG Ratings and Benchmarking 

MMG monitors its performance across multiple ESG rating platforms, including CDP, S&P Global, and WIND. These ratings inform strategic planning and highlight areas for improvement. MMG aims to maintain or improve its standing through continuous enhancement of disclosures and practices. 

Forward-Looking ESG Targets 

MMG has established forward-looking ESG targets, including but not limited to: 

  • 30% reduction in Scope 1 and 2 emissions by 2030 
  • 50% local procurement at all sites by 2026 
  • 40% female representation in leadership roles by 2027 

Progress is tracked quarterly and reported in the ESG Databook and Sustainability Report. 

Alignment with Global Standards 

MMG’s ESG and compliance practices are designed to meet and exceed global expectations for responsible mining and corporate governance. Our approach is aligned with the following international standards and initiatives: 

Global Reporting Initiative (GRI) 

  • MMG’s ESG reporting is guided by the GRI Standards, including GRI 3 for materiality assessments, GRI 102-17 for ethics and whistleblower protections, and GRI 205 for anti-corruption. The full list of our GRI-aligned disclosures can be found in the MMG 2024 Sustainability Databook. 
  • Our Sustainability Report and ESG Databook disclose performance against these standards, with selected data externally assured. 

International Council on Mining and Metals (ICMM) 

  • MMG is a member of the ICMM and adheres to its Mining Principles, Performance Expectations and Position Statements, including commitments to human rights, transparency, and environmental stewardship. 
  • Our Sustainability Framework, approved by the Board in 2023 and updated in 2024, is aligned with ICMM guidance and cascades ESG KPIs across the organisation. 

Hong Kong Stock Exchange (HKEX) ESG Code 

  • MMG complies with the HKEX Corporate Governance Code, integrating ESG oversight into Board and committee structures. 
  • ESG performance is reviewed by the Governance, Remuneration, Nomination and Sustainability (GRNS) Committee, with executive remuneration linked to ESG outcomes. 

IFRS S1 and S2, TCFD, and TNFD 

  • MMG’s climate and nature-related disclosures are aligned with IFRS S1 and S2 and the Taskforce on Climate-related Financial Disclosures (TCFD). From 2025 onwards we will begin to disclose against the Taskforce on Nature-related Financial Disclosures (TNFD). 
  • We conduct annual risk assessments, financial impact modelling, and integrate ESG risks into our Enterprise Risk Management (ERM) framework. 

Extractive Industries Transparency Initiative (EITI) 

  • MMG supports the EITI and discloses mineral contracts in line with ICMM’s Transparency of Mineral Revenues Position Statement. 
  • We publish our Tax and Community Contribution Report annually to promote fiscal transparency and inclusive growth. 

OECD Due Diligence Guidance 

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