Conceptualizing Corporate Responsibility in the Context of Climate Adaptation

This Element identifies central procedural and distributive RBC principles in the context of adaptation. These principles can help to prevent, or at least mitigate, the adverse effects of business activities amid climate change. Clarifying these responsibilities is important, as it facilitates more transparent and inclusive corporate responses to climate risks and supports the development of robust public policies and accountability mechanisms that align corporate adaptation strategies with societal needs. We begin by discussing the three procedural principles, followed by the distributive principle.

Assessments of climate risks to society enable companies to identify, prevent, and develop measures to address potential climate-related harms associated with their business activities before they occur, rather than merely reacting after the damage has already been done. Such climate risk assessments for society refer to an adequate evaluation of the societal risks associated with companies’ activities in a context of climate change, which may lead to restrictions of business activities. While many companies already assess their own exposure to climate risks, RBC requires a shift in focus toward the socio-environmental risks stemming from their business activities and adaptation strategies. Companies can achieve this by integrating climate adaptation into existing risk management processes, such as Environmental Impact Assessments (EIAs) and HREDD. More generally, human rights and environmental risk assessments are a core component of soft and hard law frameworks on RBC, such as the United Nations Guidelines for Business and Human Rights (UNGPs) (OHCHR 2011), the OECD Guidelines (2023), as well as binding laws building on these frameworks.

Through meaningful stakeholder participation, affected groups can influence how their perspectives and adaptation needs are integrated into corporate adaptation responses. By participation we mean the engagement of relevant, affected stakeholders at various stages of adaptation interventions (Eriksen et al. Reference Eriksen, Schipper, Scoville-Simonds and Vincent2021), including the assessments of climate risks, the planning of responses, and the implementation of adaptation interventions. In the context of the extractive industries, companies can, for example, integrate climate adaptation into EIAs and participatory water monitoring, thereby leveraging their existing institutionalized processes for stakeholder involvement. Stakeholder involvement throughout the process of assessing and addressing environmental and human rights risks is a cornerstone of the soft law frameworks of RBC, such as the UNGPs and the OECD Guidelines.

Transparency is important, as it can empower affected groups and governmental agencies to critically evaluate the risks associated with business activities in a context of climate change. This is particularly important in high-risk situations, where such activities may expose surrounding communities and environments to severe risks. We define transparency as companies’ obligation to inform affected groups and governmental agencies about their exposure to climate risks and the adaptive measures they have taken to address them (cf. OECD 2023). Along with risk assessment and stakeholder participation, transparency about risks associated with business activities and how companies monitor and respond to them is another core component of the soft law frameworks of RBC.

Finally, CSR investments can enable companies to move beyond a “do no harm” approach and make positive contributions to adaptation in the countries where they operate. This principle falls into the category of resource distribution, rather than the procedurally oriented principles outlined in HREDD frameworks. CSR investments typically involve the provision of public adaptation goods such as early warning systems, capacity building, and water infrastructure. When channeled through partnerships with public authorities and civil society organizations (CSOs), CSR can help build institutional capacity and support the implementation of adaptation plans (cf. UNEP 2021). However, companies often use CSR investments as strategic tools to legitimize their business activities and buy off opponents. In such cases, CSR can lead to the fragmentation of CSOs and the closure of public debates on climate-related risks and adaptation solutions that companies perceive as threatening to their interests (cf. Amengual Reference Amengual2018; Gustafsson Reference Gustafsson2018).

In sum, if meaningfully integrated into corporate adaptation responses, these four RBC principles promise preventing, or at least mitigating, the adverse impacts of corporate adaptation, and clarifying where restrictions of business activities are needed. As we elaborate in Section 2, our framework leaves out RBC principles in international frameworks, such as corporate governance and access to remedy, which are important in general but which is beyond the scope of our inquiry. Instead, we focus on those principles that are particularly relevant for preventing harm and developing regulatory policies addressing the intersecting impacts of climate change and business activities. Companies are unlikely to integrate these principles and change their behavior unless there are strong external incentives and/or regulatory pressures in place.

Regulatory and Political Factors Shaping Responsible Business Conduct in Adaptation

The second part of our theoretical framework explains how regulatory and political factors shape RBC in adaptation. We privilege three factors: public governance, civil society advocacy, and participation in voluntary adaptation initiatives. The private governance literature has highlighted that these factors matter for companies’ more general sustainability practices (Bartley Reference Bartley2018b; Lambin and Thorlakson Reference Lambin and Thorlakson2018; Thorlakson et al. Reference Thorlakson, Hainmueller and Lambin2018a, Reference Thorlakson, De Zegher and Lambin2018b), but to date they have not been examined in relation to climate adaptation. We build on this debate by theorizing how these external factors, both individually and in combination, affect how companies incorporate RBC into their responses to climate risks.

Public governance can influence RBC through soft steering and legal requirements. We refer to public governance as any hard or soft regulatory activities aimed at fostering RBC. For example, governments can introduce legal requirements to assess and address climate risks in different types of sectoral policy instruments, such as EIAs and water licenses. In some cases, this may lead to restrictions for business activities linked to substantial socio-environmental risks (cf. Bartley Reference Bartley2018a; Odell et al. Reference Odell, Bebbington and Frey2018). Governments tend to be reluctant to enforce stringent regulatory controls on businesses and instead use partnerships, support, and soft steering to influence company behavior (cf. Abbott and Snidal Reference Abbott and Snidal2009; Eberlein Reference Eberlein2019). To effectively steer and regulate company behavior, public authorities require capacity and robust monitoring systems to be able to assess the impacts of business activities in the context of climate change (cf. Lambin and Thorlakson Reference Lambin and Thorlakson2018).

In the absence of robust governance frameworks, voluntary adaptation standards can contribute to diffusing norms and contribute to learning about RBC in adaptation (cf. Grabs Reference Grabs2020). Such standards include multistakeholder initiatives, certification schemes, and private standards that set requirements for RBC (cf. Marx et al. Reference Marx, Depoorter, Fernandez de Cordoba and Verma2024). Yet, a large body of research shows that these standards frequently lack stringency, are unevenly applied, and are poorly incorporated into firms’ management structures (Bartley Reference Bartley2018b; LeBaron et al. Reference LeBaron, Lister and Dauvergne2017). Unlike climate mitigation, adaptation is covered by relatively few voluntary standards, and it remains unclear to what extent and how effectively these existing standards require companies to incorporate RBC principles into their adaptation responses.

Civil society advocacy can influence RBC by pressuring companies to develop more transparent and inclusionary adaptation responses. We refer to civil society advocacy as a civil society-based form of regulation of companies (cf. Newell Reference Newell2008), in which different types of CSO actors rely on campaigns, partnerships, and public scrutiny to compel companies to address socio-environmental risks in their adaptation strategies. Civil society has played a key role in compelling companies to comply more meaningfully with human rights and environmental standards (Bartley Reference Bartley2018b; Thorlakson et al. Reference Thorlakson, Hainmueller and Lambin2018a). However, it has often proved challenging for civil society to gather solid evidence of corporate impacts in the area of adaptation (Gustafsson et al. Reference Gustafsson, Schilling-Vacaflor and Pahl-Wostl2024). Additionally, unlike the large-scale protests against fossil-fuel emissions, mobilization around climate adaptation remains relatively rare (de Moor Reference de Moor2022).

We do not claim that these are the only factors likely to influence RBC in adaptation. Existing corporate adaptation research has also highlighted the role of biophysical risk exposure (Averchenkova et al. Reference Averchenkova, Crick, Kocornik‐Mina and Leck2016; Mbanyele and Muchenje Reference Mbanyele and Muchenje2022) and firm characteristics (Klein et al. Reference 75Klein, Käyhkö, Räsänen and Groundstroem2022; Pinkse and Gasbarro Reference 78Pinkse and Gasbarro2019). In contrast, our theoretical framework is embedded in the private governance literature and privileges regulatory and political factors, which to date remain under-researched in the context of adaptation. Next, we lay out our research design to empirically examine our account.

Mapping Responsible Business Conduct in Adaptation through a Quantitative Dataset

To explore the first part of our theoretical framework, we descriptively map the extent to which companies have integrated the RBC principles into their adaptation responses. For this purpose, we compiled a dataset based on a qualitative coding of documents from the world’s thirty-seven largest mining companies according to their market capitalization in 2019 (PWC 2019; see Appendix A; Table A1). An inductive coding of all available documents from 2017 to 2019 resulted in a company-level dataset with the capacity to descriptively map companies’ perceptions of climate risks, adaptation responses, and RBC (see Appendix B; Tables B1, B2, and B3). The corporate documents we compiled for our research include annual reports, sustainability reports, reports to the Carbon Disclosure Project, Global Reporting Initiative reports, as well as policies and reports available on the companies’ websites. The time period covered begins in 2017, prior to which the observed companies disclosed little or no information on their adaptation responses, conditions that rendered them ill-suited for analysis.

To operationalize the RBC principles, we confronted the challenge that many companies do not explicitly label their responses to climate risks as “adaptation.” Rather, they tend to use several terms, like flood risk management, risk assessments, and resilience, somewhat interchangeably (see also Averchenkova et al. Reference Averchenkova, Crick, Kocornik‐Mina and Leck2016). This makes it difficult – but not impossible – to identify different types of activities that would here be classified as “adaptation” (Dupuis and Biesbroek Reference Dupuis and Biesbroek2013). Thus, we examined the documents in conjunction with the interviews described later to operationalize the four principles (see also Section 3). More specifically, we coded whether companies adhered to the four RBC principles, as we describe in detail in Section 3 and Appendix B; Table B3. We also used the documents to measure a range of other aspects, including whether companies framed climate-related risks as economic and/or societal, and how they responded to these risks organizationally. This is useful information to set the stage for the mapping of the RBC principles.

Relying on company self-reporting of corporate adaptation has the advantage that we can generate this quantitative dataset, but as with any measurement approach, it also has limitations. Companies’ reporting is often fragmented, biased, and vague and it should, therefore, be treated as a strategic communication tool employed by companies to present themselves as leaders in upholding voluntary sustainability standards. Therefore, the quantitative document analysis may overestimate RBC in adaptation and must be interpreted with caution.

To provide a more balanced analysis, we complement the quantitative data with eighty-seven semi-structured interviews with representatives of companies, business associations, civil society, and the public sector during the period 2020–2022. We transcribed and coded all interviews in Atlas.ti. We conducted forty-one of the eighty-seven interviews in relation to our dataset of the world’s largest mining companies (see Appendix C). The main aim of these interviews was to contextualize the quantitative coding of the RBC principles. In this way, this Element offers a context-sensitive and critical analysis of how corporate actors perceive climate risks, adapt their practices, and adhere to RBC principles when adapting to climate risks (Section 3).

Explaining Responsible Business Conduct in Adaptation through Case Studies

To explore the second part of our theoretical framework laying out the factors that may explain RBC in adaptation, we conducted qualitative case studies on three mining projects in Peru. The selected mines in Peru include Antamina, Cerro Corona, and Quellaveco. Figure 1 indicates that these three projects are situated in Peruvian provinces, which are highly vulnerable to climate risks. Generally, Peru is not among the most vulnerable mining-dependent countries, but climate vulnerability is unevenly distributed across its provinces.

The case studies enabled a more nuanced and context-sensitive analysis of how each of the three factors shaped companies’ integration of the RBC principles. These mining companies rank among the most socially and environmentally responsible in the sector (RMI 2022). Studying how they implement the principles at the operational level enables us to identify important barriers to fostering greater RBC in adaptation (Section 4). We conduct the analysis of the three cases on the basis of material collected during four weeks of fieldwork conducted in the three mining localities and in the capital, Lima, in November and December 2022. We conducted forty-six interviews with representatives of the three mining companies, state agencies at both the national and subnational levels, and civil society and grass-roots organizations who work on climate adaptation, mining, or both (see Appendix C). We use these interviews to operationalize the three theorized explanatory factors and offer a context-sensitive analysis of the three cases.

To analyze public governance in Peru, we analyzed national-level legal requirements to integrate RBC into key sectoral policies, including EIAs, water licenses, the design of tailing dams, and closure plans. We also relied on the interviews to investigate subnational and national authorities’ attempts to influence the companies through soft steering, such as partnerships, dialogues, and production of data on climate risks. Regarding the role of voluntary adaptation standards in shaping RBC in adaptation, we used both the quantitative dataset described earlier and interviews with company representatives to identify the most commonly used standards and then used documents describing the standards to analyze the extent to which these standards covered RBC principles. Subsequently, we interviewed representatives of the three companies to understand how they perceived the influence of these standards on their adaptation responses. Finally, we interviewed representatives from civil society and the three companies to investigate how civil society advocacy mattered RBC in adaptation. In summary, the case studies enabled us to systematically explore the theoretical framework in a context-sensitive manner.

Assessments of Climate Risks to Society

Assessing climate risks to society enables companies to identify and address potential harms linked to their operations, making it an important procedural principle for preventing harms before they occur. We understand assessments of climate risks to society as the obligation of companies to adequately evaluate the societal risks associated with their business activities in a context of climate change. Climate risk assessments involve a technical analysis of the likelihood, responses, and consequences tied to climatic impacts, and the options available to redress them (see also Adger et al. Reference Adger, Brown and Surminski2018). While many companies have procedures to assess their own risk exposure, including those ensuing from climate impacts, addressing socio-environmental risks requires shifting the focus toward the external risks posed by their own activities.

To gather sufficiently rigorous data, companies must conduct a complex technical analysis that will yield reliable data showing how climate impacts could exacerbate, or even create, new socio-environmental risks linked to their business activities. In the mining sector, companies must ensure that tailings dams withstand intense rains (Hopkins and Kemp Reference 74Hopkins and Kemp2021). In the agroindustry, companies also must assess the short- and long-term effects of their water use (cf. Rattis et al. Reference Rattis, Brando, Macedo and Spera2021). Meanwhile, in the apparel industry, the effects of extreme heat and floodings on workers’ health and safety must be carefully analyzed (Judd et al. Reference Judd, Bauer, Kuruvilla and Stephanie2023).

To carry out climate risk assessments, companies can integrate climate risks into existing forms of risk assessments. For example, in the case of major projects, companies in most countries are legally required to conduct EIAs and are thereby already assessing their potential impacts on the environment and, in some cases, on society (Lawrence and Kløcker Larsen Reference Lawrence and Kløcker Larsen2017). Moreover, HREDD frameworks give companies tools to ascertain the human rights and environmental risks associated with their business activities, though climate change, and environmental issues more broadly, have often been poorly integrated in such procedures (Bernaz Reference Bernaz2016; Macchi Reference Macchi2022). Hence, companies could integrate climate adaptation into existing methods of risk assessment rather than developing new ones.

Despite the potential to integrate climate adaptation into existing risk management procedures, barriers hinder companies from carrying out such assessments. One major challenge lies in the complexity and uncertainty of these assessments, which can reduce companies’ motivation to conduct them. Climate impacts can have immediate, short-term, and long-term consequences. In some cases, the impacts do not arise until after a company has ceased its operations. In addition, companies must contend with the uncertainty surrounding future climate projections, specifically in assessing long-term impacts and the effectiveness of adaptation interventions (Adger et al. Reference Adger, Brown and Surminski2018). Research shows that perceived uncertainty influences how much attention companies allocate to climate impacts and whether they adopt more rigorous adaptation responses (Pinkse and Gasbarro Reference 78Pinkse and Gasbarro2019).

In sum, assessing climate risks to society is a procedural principle that enables companies to address harms before they occur and can often be integrated into existing risk assessment procedures. But significant challenges remain due to the complexity of analyzing how business activities might interact with climate change. That these assessments also support other procedural principles such as participation and transparency makes them even more essential for RBC in adaptation.

Participation

Meaningful participation ensures that affected groups can influence how their perspectives and adaptation needs are integrated into corporate adaptation responses. Specifically, we refer to participation as the engagement of relevant stakeholders in the planning and implementation of adaptation interventions (Eriksen et al. Reference Eriksen, Schipper, Scoville-Simonds and Vincent2021; Shi et al. Reference Shi, Chu, Anguelovski and Aylett2016). According to the UNGPs (OHCHR 2011) and the OECD Guidelines (2023), companies shall consult stakeholders throughout the process of assessing and addressing environmental and human rights risks. Companies can consult affected stakeholders regarding climate risk assessments and the implementation of adaptation activities. This is especially important when corporate adaptation efforts impact the land and water that local communities rely on for their livelihoods (cf. OECD 2023: 20).

Depending on their purpose, quality, and outcomes, participatory processes may give vulnerable and marginalized groups greater voice and influence (Dellmuth and Gustafsson Reference Dellmuth and Gustafsson2023; Gustafsson and Schilling-Vacaflor Reference Gustafsson and Schilling-Vacaflor2022). To foster meaningful stakeholder consultations, the OECD Guidelines stipulate that companies shall set up participatory processes that are “timely, accessible, appropriate and safe for stakeholders” (OECD 2023: 20). They further underscore the importance of identifying and removing potential barriers to engagement with vulnerable and marginalized groups (OECD 2023: 19).

However, participatory processes have often not enabled the influential participation of marginalized groups. For example, adaptation interventions led by public actors have often suffered from shortcomings when it comes to setting up inclusionary participatory processes (Eriksen et al. Reference Eriksen, Schipper, Scoville-Simonds and Vincent2021). Similarly, company-led participatory processes in large-scale projects are often beset by shortcomings such as limited information, time, and influence on decision-making (Lawrence and Kløcker Larsen Reference Lawrence and Kløcker Larsen2017). Consequently, if companies formally involve affected groups in implementing adaptation interventions but fail to provide adequate and accessible information about climate risks, they undermine their ability to voice their concerns and influence corporate adaptation strategies.

Transparency

As the final procedural principle, access to information on climate risk assessments and corporate adaptation responses equips affected groups and public authorities with tools to critically evaluate how companies address climate-related risks arising from their operations. We conceive of transparency as companies’ duty to inform society more broadly about the societal risks associated with their business activities in the context of climate change and of the adaptive measures they have taken to address them (cf. OECD 2023). Access to such information is particularly important in cases where business activities may expose communities and ecosystems to severe risks. For instance, if a company builds a pipeline to transport toxic materials, it must inform local communities of any increased risks for dangerous accidents.

There has been a proliferation of voluntary initiatives and legislation mandating that companies report on their sustainability performance, particularly regarding climate change. Initiatives like the Carbon Disclosure Project and the Global Reporting Initiative have significantly enhanced companies’ reporting about their decarbonization strategies (cf. Pinkse and Gasbarro Reference 78Pinkse and Gasbarro2019). In contrast, few initiatives require companies to disclose information about their adaptation strategies.

Corporations tend to be very cautious in disclosing information about their adaptation interventions (Gustafsson et al. Reference Gustafsson, Rodriguez-Morales and Dellmuth2022). Unless required to do so, those operating in high-risk sectors, such as extractive industries or agroindustry, generally have few incentives to be transparent about the risks they face, as doing so could provoke conflicts that disrupt their operations. This situation is very different in the climate mitigation space, where companies are strongly motivated to showcase their contributions to the low-carbon transition (Jernnäs and Lövbrand Reference Jernnäs and Lövbrand2022).

Although climate risk assessments are technically complex and their results uncertain, companies must find a way to present the information they gather in a format that is relevant and easily accessible to affected groups (cf. Gardner et al. Reference Gardner, Benzie, Börner and Dawkins2019; OECD 2023). Without such information, local populations and public institutions will struggle to evaluate corporate adaptation responses. In turn, this may undermine local and public actors’ attempts to hold companies accountable and hinder the establishment of a democratic dialogue on the impacts of business activities within the context of climate change.

CSR Investments

CSR investments can enable companies to move beyond a “do no harm” approach and make positive contributions to adaptation in the countries where they operate. In our framework, CSR investments are understood as the provision of public adaptation goods by companies (cf. Tompkins and Eakin Reference Tompkins and Eakin2012). Companies can invest in early warning systems, cooling systems, water infrastructure, and capacity building to help affected stakeholders to cope with climate change. Such investments could expand access to public adaptation goods in countries where governments lack the resources to fund the implementation of adaptation plans. The problem is particularly urgent in developing countries, where the annual adaptation costs are expected to reach 140 to 300 billion USD in 2030 and 280 to 500 billion USD in 2050 (UNEP 2021: xiv). According to the UN Environment Programme (UNEP), private adaptation funding is essential to reducing this gap (UNEP 2021: xiv).

Against this background, companies could partner with nongovernmental organizations (NGOs) and state institutions to invest in essential public adaptation goods such as water infrastructure, climate-proofing infrastructure, and capacity building. By channeling CSR investments through institutionalized partnerships that benefit broad swaths of the populations, companies could contribute both through financial support and by expanding state capacity to implement adaptation plans.

At the same time, companies are often unwilling to make CSR investments unless there is a business case (Auld et al. Reference Auld, Bernstein and Cashore2008). CSR investments in the mining sector tend to be aimed at preventing or mitigating conflicts with local communities that could disrupt their economic activities (Franks et al. Reference 72Franks, Davis, Bebbington and Scurrah2014). To defuse opposition, companies sometimes make targeted investments that benefit smaller groups, but create dependency which often undermines long-term local development, civil society organizations, and institutional reforms (Amengual Reference Amengual2018; Bebbington Reference Bebbington, Ravi and Lipschutz2010; Gustafsson Reference Gustafsson2018). In such situations, the existence of CSR investment might reduce local communities’ demands for the procedurally oriented principles. Consequently, it is important to monitor how companies channel these investments, be it either through institutionalized partnerships or bilateral exchanges with small groups or individuals as tools for gaining political support.

Public Governance

We expect public governance to influence corporate behavior through both legal requirements and soft steering. Public governance refers to the system of organizations, institutions, and networks at domestic and global levels that develop and implement rules and norms for handling societal problems (Weiss and Wilkinson Reference Weiss and Wilkinson2019). We analyze how domestic institutions at both the national and subnational levels require or encourage RBC in adaptation through hard and soft regulatory activities. These forms of governance are important because they can strongly influence corporate behavior by shaping incentives and enforcing compliance.

Legal requirements are central to influence business behavior. For instance, governments can institute legal requirements that climate risks be considered within key sectoral regulatory instruments such as concessions, water licenses, and EIAs. These instruments can act as “market-restricting rules” that governments could employ to limit or prohibit business activities likely to undermine societal and ecosystemic adaptation (cf. Bartley Reference Bartley2018a). In developed countries, the prospect of governmental regulation has been an important driver of corporate climate action, particularly in the area of mitigation (Newell and Daley Reference Newell and Daley2024; Sakhel Reference Sakhel2017). However, legal requirements in the area of adaptation tend to be weaker (Klein et al. Reference Klein, Araos, Karimo and Heikkenen2018), especially in countries in the Global South (Pulver and Benney Reference Pulver and Benney2013; Purdon and Thornton Reference Purdon, Thornton, Keskitalo and Preston2019).

Still, most countries have EIA legislation in place, which can serve as an important instrument for governments to require companies to conduct impact assessments, disclose information, and enable stakeholder participation. Furthermore, EIAs could lead to stricter rules or the suspension of major projects where the negative impacts are deemed too high. While EIA legislation increasingly includes climate mitigation, legal requirements that climate adaptation be taken into account are rare, reflecting that adaptation is not yet institutionalized in sectoral policies (Mayembe et al. Reference Mayembe, Simpson, Rumble and Norton2023). However, some governments have also used EIAs as an instrument to restrict activities deemed to have a negative impact on climate adaptation. For example, in 2017, the Salvadoran government conducted a Strategic Environmental Impact Assessment to evaluate the impacts of mining under conditions of increased water scarcity and climate-related disaster. That assessment resulted in a national ban on metal mining (Odell et al. Reference Odell, Bebbington and Frey2018).

Governments can also use support and soft steering mechanisms, like funding, scientific information, endorsement, partnership, or multistakeholder initiatives to influence companies’ adaptation behavior (cf. Abbott and Snidal Reference Abbott and Snidal2009; Eberlein Reference Eberlein2019). For example, some countries have developed voluntary guidelines on how companies should assess physical climate risks in EIA processes (Strindevall et al. Reference 79Strindevall, Gustafsson and Dellmuth2022). Since knowledge and expertise are often important barriers to tackling climate impacts, clear guidelines can encourage companies to undertake risk assessments for society by making them less costly. Moreover, partnerships and multistakeholder initiatives can provide companies with institutionalized channels through which they can channel CSR investment in public adaptation goods, disclose information, and engage important stakeholders in dialogues on adaptation. However, soft steering processes are often ineffective in changing company behavior unless backed up by a viable threat of mandatory regulation (Börzel et al. Reference Börzel, Hönke and Thauer2012).

To effectively steer or regulate company behavior, public institutions must involve robust monitoring systems capable of assessing the impacts of climate change and evaluating the extent to which companies responsibly assess and redress manifest risks (cf. Lambin and Thorlakson Reference Lambin and Thorlakson2018). While many governments have adopted National Adaptation Plans (NAPs), the quality of the data that emerges is a significant limitation. NAPs are often too generic to capture risks in specific geographic and social contexts (Dolšak and Prakash Reference Dolšak and Prakash2018). Without robust data on climate risks, public authorities cannot provide companies with relevant data or evaluate the adequacy of corporate responses.

Adaptation is often not prioritized by political and economic actors. Where national or subnational economies heavily depend on particular economic activities, the adaptation agenda may become more responsive to corporate interests than to the rights and needs of marginalized groups. In Brazil, for instance, adaptation policies have enabled large-scale agricultural producers to cope with water stress through irrigation infrastructure, often at the expense of marginalized communities who face severe water insecurity as a result (Gustafsson et al. Reference Gustafsson, Schilling-Vacaflor and Pahl-Wostl2024; Milhorance et al. Reference Milhorance, Sabourin, Chechi and Mendes2022a). Overall, it is important to consider the underlying political priorities, power dynamics, and monitoring capacities that shape how legal requirements and soft steering influence company behavior.

Voluntary Adaptation Standards

We expect voluntary adaptation standards to matter for RBC in adaptation through the diffusion of norms about RBC. Voluntary adaptation standards refer to any type of multistakeholder initiative, certification scheme, or private standard that sets requirements designed to increase the sustainability of corporate adaptation responses (cf. Marx et al. Reference Marx, Depoorter, Fernandez de Cordoba and Verma2024). More generally, voluntary sustainability standards typically define specific foundational principles, which are then translated into measurable indicators for monitoring and compliance (Marx et al. Reference Marx, Depoorter, Fernandez de Cordoba and Verma2024: 3). However, standards differ in terms of their institutional design, and although they usually rely on enforcement mechanisms such as audits, they can also rely on market incentives and capacity building to generate compliance (Depoorter and Marx Reference Depoorter and Marx2024). When public governance is weak or lacking, companies are more likely to rely on voluntary standards (cf. Potoski and Prakash Reference Potoski and Prakash2013). This is likely to be the case in adaptation.

While there are no comprehensive voluntary adaptation standards, several standards have integrated climate adaptation to some extent, notably those developed by the Alliance for Water Stewardship, the Sustainable Agriculture Initiative, and the Responsible Business Initiative. In the mining sector, ICMM and the Global Tailings Review have developed industry-specific standards which include adaptation (Hopkins and Kemp Reference 74Hopkins and Kemp2021). Such standards can contribute to learning and thereby facilitate businesses uptake of RBC principles (cf. Depoorter and Marx Reference Depoorter and Marx2024).

The private governance literature yields mixed evidence about whether voluntary standards lead to meaningful improvements in the sustainability practices of firms (Marx et al. Reference Marx, Depoorter, Fernandez de Cordoba and Verma2024; Thorlakson et al. Reference Thorlakson, Hainmueller and Lambin2018a). A study by Thompson and colleagues (Reference Thompson, Davis, Mosley-Thompson and Porter2021) on the effects of certifications on the climate resilience of cocoa farmers in Ghana showed some positive impacts on farm management practices, but found significantly weaker effects on more complex adaptation measure. This is likely due to the continued lack of clarity regarding what constitutes adaptation, which makes it challenging for standard setters to develop and monitor appropriate measures. More generally, numerous studies have shown that voluntary standards are often insufficient for preventing or rectifying serious problems due to limited uptake, lack of stringency, poor-quality auditing, and a tendency toward symbolic compliance (Bartley Reference Bartley2018b; LeBaron et al. Reference LeBaron, Lister and Dauvergne2017).

Companies usually adopt voluntary standards for utilitarian reasons (de Bakker et al. Reference de Bakker, Rasche and Ponte2019). Retailers with high-profile consumer brands, who are more exposed to CSO scrutiny, have shown a greater tendency to adopt sustainability standards compared to business-to-business firms (Thorlakson et al. Reference Thorlakson, Hainmueller and Lambin2018a). Additionally, researchers have concluded that the use of public monitoring systems and legal enforcement mechanisms contribute to more meaningful compliance with voluntary standards (Lambin and Thorlakson Reference Lambin and Thorlakson2018). In sum, while voluntary standards can contribute to learning about RBC in adaptation, meaningful adoption and compliance by profit-maximizing firms tends to depend on incentives or external pressures, with civil society advocacy often playing an important role.

Civil Society Advocacy

Finally, we expect CSO advocacy to influence RBC not only by pressuring them to adopt voluntary adaptation standards but also to develop more inclusionary and transparent adaptation responses.

Here, civil society advocacy refers to a civil society-based form of corporate regulation (cf. Newell Reference Newell2008), in which NGOs, social movements, grassroots organizations, labor unions, and other civil society actors pressurize companies to change their behavior (cf. Dellmuth and Bloodgood Reference Dellmuth, Bloodgood, Dellmuth and Bloodgood2023). CSOs have often played a critical role in scrutinizing companies and incentivizing companies to disclose information, to reduce the negative impacts of their business activities, to invest in CSR, to adopt voluntary sustainability standards (Bartley Reference Bartley2018b; Franks et al. Reference 72Franks, Davis, Bebbington and Scurrah2014; Thorlakson et al. Reference Thorlakson, Hainmueller and Lambin2018a), and to comply with legal requirements (Kramarz et al. Reference Kramarz, Mason and Partzsch2023).

CSOs pursue a range of advocacy strategies, such as generating and disseminating alternative data about the impacts of business activities (Kramarz et al. Reference Kramarz, Mason and Partzsch2023), engaging in highly visible naming-and-shaming campaigns (Balsiger Reference Balsiger2014), and interacting closely with companies through multistakeholder initiatives (Gustafsson Reference Gustafsson2018). In particular, the deployment of visible campaigns could pressure companies to integrate RBC. Campaigns that show the consequences of failing to address climate risks can lead to consumer boycotts, investor demands for action, and other potential consequences that reputation-sensitive businesses usually seek to avoid (Balsiger Reference Balsiger2014). Concerns about reputational harm might lead companies to improve climate risk assessments, develop their adaptation responses in a more transparent and inclusionary way, and support societal adaptation through CSR investments.

However, civil society advocacy in the field of climate adaptation has been relatively weak, in part because adaptation is often framed as a technical and depoliticized problem. In sharp contrast to civil society campaigns against carbon-intensive industries (Boulianne et al. Reference Boulianne, Lalancette and Ilkiw2018), activists have rarely engaged in open protests to pressure governments and corporations to intensify their efforts to promote climate adaptation (de Moor Reference de Moor2022). Social movement scholars have stressed that CSO mobilization around systemic issues, where responsibility is diffuse and specific attribution challenging, is generally less likely to occur (Carpenter Reference Carpenter2007). This is certainly the case with corporate adaptation, where it can be difficult to provide robust evidence on a given corporation’s impact on community and ecosystem resilience. At the same time, local protests over climate-related impacts are common – especially in industries that require the intensive use of land and water – even if they are not explicitly framed in terms of climate change (Leme da Silva et al. Reference Leme da Silva, Eloy, Oliveira and Coelho Filho2023; Odell Reference Odell2021; Urkidi Reference Urkidi2010).

Overall, while CSO advocacy has the potential to pressure companies to integrate RBC principles into their adaptation responses, its role in shaping corporate behavior depends on the ability of civil society actors to mobilize collectively and articulate concrete, actionable demands regarding corporate responsibilities in the face of climate risks.

Antamina: A Reactive Approach to Local Climate Concerns

Antamina is operated by a Peruvian mining company owned by Glencore, BHP, Teck, and Mitsubishi. As we show in Section 3, these companies, most notably Teck, belong to the small group of industry actors that have begun to integrate the RBC principles into their adaptation responses. In Peru, mining experts recognize Antamina as a company that employs dialogues, partnerships, and social investments as a general approach to address community concerns. One expert on community rights in the mining sector told us that this approach was an important explanation for the absence of major protests and strong anti-mining mobilizations against the company over the years (Interview 57). While this general approach to local communities is to some extent reflected in its adaptation responses, the procedural principles remain weakly integrated.

Antamina extracts copper and zinc from its mine in the Ancash region, located at an altitude of 4,300 meters above sea level. The extracted minerals are then transported via pipeline to the shipping port in the coastal province of Huarmey, which has led to some concerns among communities affected by the pipeline. Ancash is the region with the largest area of tropical glaciers in the world. Due to climate change, 35 percent of the total glacier-covered area has been lost over the past forty years with severe consequences. For the human population, it has significantly reduced the availability of freshwater during the dry season with manifold repercussions (Gobierno Regional de Ancash 2017: 7). Mining activities have further exacerbated water insecurity for downstream populations (Bury et al. Reference Bury, Mark, Carey and McKenzie2013). Intense rains resulting in landslides pose another salient climate risk (Gobierno Regional de Ancash 2017: 7). The most noteworthy climate-related event occurred in 1970, when a devastating earthquake caused the death of about 80,000 people. The history of environmental disasters, melting glaciers, and the presence of NGOs working on adaptation projects have raised awareness of climate impacts and natural disasters throughout the local population. Demonstrating its responsible management of such climate-related risks was, therefore, essential for Antamina to gain social license to operate.

Our analysis of how the company has handled climate-related risks reveals that Antamina (2020) has not reported carrying out climate risk assessments for its own operations or assessing climate risks to society. Compared to other companies that combine global climate-driven scenarios with site-level data to analyze the likelihood and prospective consequences of climatic impacts, Antamina does not appear to be working with climate data suited for making predictions. This makes it hard for the company to proactively identify the risks for host communities linked to their operations. At the same time, the company does refer to climate impacts in its assessments of water and disaster risks. Instead of anticipating future conditions, it concentrates on climate-related impacts that have already begun to affect local communities within its area of operation (Antamina 2020), illustrating its reactive approach to such risks.

Antamina has, to some extent, integrated the procedural principles by being transparent and participatory in specific adaptation responses. Community members have been concerned about the risks of accidents related to mining infrastructure. In 2019, there were indications that the tailings dam could collapse, and the entire community had to be temporarily evacuated. The dam, which contains highly toxic topic mining waste, is located just above the community, and its collapse would have had catastrophic effects. That incident was followed by dialogues between the company and the community. These dialogues led to an agreement that Antamina would both improve dam stability to be able to withstand more extreme weather events and develop a Community Early Warning System to alert members of the local population of an emergency. Another example of a CSR investment is the climate-proofing of the pipeline that transports minerals to the coast along a route that passes through an area highly exposed to climate-related disasters (Cenepred 2023). In 2019, intense rains damaged the pipeline, which led to community protests about risks of contamination of land and water (CooperAcción 2021). In response, the company developed a partnership with public institutions working on disaster risks and conducted a risk assessment. These actors reached an agreement that the company would climate-proof the pipeline to reduce communities’ exposure to the risk of dangerous accidents (Interviews 62, 73, 74).

In both cases, Antamina provided local communities with information and engaged them in the planning and implementation of adaptation measures. Antamina informed the community about the improvements it made to the tailings dam, involved community members in the development of an Early Warning System, and organized a public consultation about plans to climate-proof the pipeline (Interview 73). The company has also set up participatory water monitoring to enable communities to regularly assess the operation’s impact on water quantity and quality. These examples suggest that Antamina has, to some extent, integrated the procedural principles by being transparent and participatory in certain adaptation responses. However, such steps were only taken after repeated community demands on the company to disclose data and engage in dialogue.

Importantly, community members lacked trust in the information the company provided. When it reassured them that the upgrade of the tailings dam was sufficient, the community engaged an external technical advisor who maintained that the company had underestimated the risks to such an extent that the entire community should be relocated (Interview 76). Similarly, one community leader told us that they were suspicious of the accuracy of company results, as the company water assessments always showed that the level of contamination never exceeded the legal limit (Interview 63). Most importantly, these examples reveal that Antamina has not proactively consulted local communities about climate risk assessments or adaptation measures. Instead, it has disclosed information only under pressure – and even then, limited disclosures to the most visible climate impacts, particularly those too evident to ignore or deny.

Finally, Antamina has made CSR investments aimed at compensating local communities and strengthening their resilience in response to climate impacts that have become a growing source of local concern. For example, the company has installed water reservoirs for communities near the mine, and in areas where the pipeline passes, Antamina has partnered with the Ministry of Agriculture and local governments to implement a project aimed at improving water governance and irrigation infrastructure and raising awareness of climate change.

Overall, Antamina has invested in public adaptation goods through CSR initiatives, but its integration of key procedural principles has been limited and often reactive – typically occurring in response to the threat of community protests.

Cerro Corona: Corporate Adaptation in Contested Terrain

Gold Fields, in contrast to Antamina, adopted a more proactive and comprehensive strategy to integrate our four RBC principles into its adaptation strategy for the Cerro Corona project. The company emphasizes community resilience as a cornerstone of its adaptation policy (Gold Fields 2021a: 11). Interviewees both within and without the company have remarked that the CEO and the sustainability manager for the Cerro Corona project displayed a high level of commitment to implementing the policy (Interviews 6, 40, 36, 37, 59, 60, 78). That commitment notwithstanding, the company largely abandoned an important component of its work on community adaptation due to unfavorable sociopolitical conditions and staff changes in the associated CSR unit.

The Cerro Corona gold and copper project is located in the impoverished mining region of Cajamarca, where rural protests over mining impacts on scarce water resources have led to the indefinite postponement of the development of two large-scale mines. There have, to date, been few protests against the Cerro Corona project. According to the regional climate change plan, climate vulnerability is classified as “high” or “very high” in 85 percent of the region’s territory, with droughts, floods, and frosts identified as the most significant risks (Gobierno Regional de Cajamarca 2016: 35). Heavy rains resulting in landslides are also a key risk that must be accounted for in any assessment undertaken (Gobierno Regional de Cajamarca 2016: 43). The Cerro Verde project is located in Hualgayoc, the district with the highest number of environmental liabilities in Peru. It is the site of a staggering 1,036 unremediated environmental liabilities, which enable toxic substances to pollute the surrounding water and land during periods of intense rainfall. This situation led MINAM to declare the district an area of environmental emergency in 2016 (MINAM 2016). More broadly, water stress is becoming an acute problem in both rural and urban areas. In the urban area of Hualgayoc, the population relies entirely on Gold Fields’ provision of freshwater in tanks, and within rural communities the key demand is that Gold Fields invest in water reservoirs (Interview 54).

Gold Fields has committed to supporting community resilience by integrating all RBC principles. Since 2016, Gold Fields has conducted two assessments of climate risks comprising both their own operations and those of surrounding communities, which led them to adopt several adaptation measures (Gold Fields 2022: 77). To carry out the site-based risk assessments, the company piloted the MiCA tool developed by ICMM, which enables companies to analyze climate risks, including community vulnerability; and it also engaged external consultants to conduct community climate risk assessments (Interview 40). Gold Fields reported having addressed the identified risks by reducing its water consumption and improving tailings management in the Cerro Corona project (Gold Fields 2021b: 83). Compared to other companies in our sample, the company has a more advanced understanding of community resilience, particularly in its approach to tailings management.

Cerro Corona focused most intensively on integrating the RBC principles between 2014 and 2017, when it implemented the “Adapting Together” program in partnership with NGOs and the local government. The project involved building institutional capacity, developing an adaptation plan, and formulating adaptation projects eligible for funding via the tax revenues transferred to mining-producing subnational governments. It also constructed 250 water reservoirs to support agricultural activities, a potable water system for the city of Hualgayoc, and developed training programs to increase the awareness of climate risks within local communities (Goldfields 2019: 112; Lutheran World Relief 2017). This shows how the company used CSR investments to support adaptation infrastructure, awareness-raising, and capacity building of subnational governments. Importantly, this initiative was implemented as an institutionalized partnership, rather than being targeted at smaller groups critical of the mine.

The initiative also included components that may support the integration of the procedural principles, such as transparency and participation. Gold Fields distinguishes itself among the three companies studied by making technical information accessible and engaging in dialogues about climate change. For instance, it used local radio, theater, and brochures to disseminate information about climate impacts and adaptation to local communities. A company representative explained that the goal was to find “a neutral platform with a collaborative space where we can share our technical data on [climate] risks so that the farmers understand that there is something bigger […] something that we are also battling” (Interview 36). A former sustainability manager at Cerro Corona described it as an attempt to create a win-win situation where the mine is “viewed as an opportunity to adapt to climate change rather than a risk” (Interview 78). However, this framing of shared risks was met with suspicion by local politicians and communities (ibid). One community leader who participated in the training saw it as an attempt to shift blame for the impacts caused by mining to climate change (Interview 53), suggesting that such CSR initiatives did not have the intended impacts of increasing community support for the mining project. Local communities, though aware of longer dry periods and more intense rains than in the past, voiced far greater concern over the deeply unsustainable effects of mining in their regions, which they perceived as the main cause of the climate-related problems they now faced.

The deep-rooted distrust against the company was an important barrier to integrating the procedural principles. Gold Fields claims to be regularly disclosing information about the mine’s impacts on water quantity and quality and involving local communities and authorities in participatory monitoring (Gold Fields 2019: 106). But community members are skeptical about the information the company releases on water impacts (Interviews 54, 56). A representative from the regional government admitted having never seen a test result indicating that the company was tied to any polluted water detected, raising suspicions that the results had been manipulated (Interview 70). Moreover, the company failed to invite community members or representatives of public authorities to participate in climate risk assessments (Interviews 36, 40). Yet, in line with the newly adopted Global Industry Standard on Tailings Management, Gold Fields has publicly committed to involving local communities in climate risk assessments of its tailings dams (Gold Fields 2021c: 15). However, whether this has actually been done has yet to be determined.

Overall, the Cerro Corona case illustrates an attempt to integrate the four principles. At the same time, this case also reveals the challenges associated with disclosing information and engaging in dialogues about climate adaptation in contexts where past and present mining activities are deeply implicated in societal climate vulnerability. In such situations, companies are likely to be unwilling to disclose information about the risks associated with mining activities in a context of climate, as it might lead to community protests.

Quellaveco – Adapting Core Business Activities

Quellaveco, operated by Anglo American, had recently committed to integrating the RBC principles into its adaptation strategies during the time we conducted our fieldwork in 2022. Although Anglo American describes this work as evolving, it claimed it was committed to integrating climate adaptation in its social management systems (Anglo American 2022: 20). Its approach differed from Cerro Corona’s in that the adaptation measures were more closely linked to the company’s core operations, partly because they were already integrated into the project’s initial design. The company made relatively significant CSR investments in adaptation, but generally fell short in the integration of procedural principles.

The Quellaveco copper project is located in the Moquegua region and currently constitutes the largest mining investment in Peru (MINEM 2022: 12). Consistent with its scale, mining plays a crucial role in the regional economy and, as of 2018 (the most recent year for which data is available), 87 percent of that region’s revenues originated from mining (Arellano-Yanguas Reference Arellano-Yanguas2018: 5). Although the population generally recognizes the importance of mining as a driver of regional development, concerns about water stress continue to be a pressing issue. Moquegua is located in the Atacama Desert, where water scarcity is extremely high (see Figure 6). Despite these challenging conditions, extending the agricultural frontier into the arid desert remains a regional priority. Following a lengthy negotiation process, during which the company made significant concessions to reduce the project’s impact on the region’s water resources and made CSR investments to facilitate the Pasto Grande irrigation project, the Quellaveco project finally began operating in 2023 (Gustafsson and Scurrah Reference Gustafsson and Scurrah2023).

Discussing the first procedural principle, Anglo American began assessing climate risks for both their own operations and for its host communities in 2010. The results of this assessment showed that 70 percent of Anglo American’s mines were located in water-scarce areas, with the highest risks to their projects in the Atacama Desert in Chile and Peru (Anglo American 2018: 49). Consequently, the company’s adaptation strategy has focused on reducing its water footprint (Anglo American 2022: 9). A company representative in the environmental unit explained that Anglo American made a generic climate adaptation study as part of the EIA it conducted based on data from public institutions, but planned to undertake a new climate risk assessment in 2023 based on their own local data. To this point the company has not involved local communities in its climate risk assessments (Interview 85).

To address concerns from local communities and the regional government about the potentially negative impacts of the Quellaveco mine, Anglo American made significant concessions by modifying the project’s engineering design. In the initial EIA presented in 2000, the company proposed using groundwater for its operations. But the results of an independent report by an international water specialist commissioned by the regional governor showed that the project would produce a severe water shortage. In 2008 Anglo American presented a new project design that would rely on water from the Titire River – a waterway naturally contaminated by boron and arsenic and therefore not suitable for consumption – rather than groundwater.

Between 2011 and 2012, the company participated in a sixteen-month-long dialogue table with members of the regional government and civil society representatives. The process resulted in twenty-six agreements and the establishment of a committee dedicated to monitoring company compliance (Jaskoski Reference Jaskoski2014). An important concession that emerged from these talks was Anglo American’s commitment to build an eight-kilometer-long tunnel to direct the Asana River around the mine. The dialogue table was led by the regional government and was carried out in a relatively participatory way, resulting in a final agreement that reflected a broad regional consensus.

In addition to substantial changes in the project’s engineering design, Anglo American also committed to making significant CSR investments in water infrastructure which, according to company representatives, will positively affect the water balance in the area (Interview 85). To accomplish this, the company has constructed the large Vizcachas large dam to store rainwater (Anglo American 2018: 48). The dam was critical for the acceptance of the project since the water could be used for an irrigation project to enable the extension of Moquegua’s agricultural frontier. However, there are also concerns about the long-term sustainability of the dam with rainfall steadily decreasing and becoming increasingly irregular (Interview 57). In 2021, there was not enough rainwater to fill the dam, which led to water shortage (Interviews 79, 83).

Another significant CSR investment was made in the development of a technical solution that would enable the contaminated water from the Titire river to be treated and clean water returned for use by farmers in the downstream Tambo Valley. Anglo American claims that its approach, once implemented, will improve the water quality for the Tambo region. However, farmers who would be affected fear that the cumulative volume of river water would be reduced and consequently have protested against the project and appealed the decision of the National Water Authority to grant the company a water license (CooperAcción 2022). A former leader of a rural organization in the Tambo Valley claims that the decision to issue the water license was based on 2009 data that is no longer reliable and does not consider the impacts of climate change on hydrological stress (Interview 75). CSOs rarely express such an open critique of the lack of regulatory controls on companies’ adaptation strategies, which also eases the pressure on public authorities to adopt stricter controls on business activities to reduce climate-related risks.

It is noteworthy that Anglo American has negotiated in a relatively participatory and inclusive way, made important concessions, and dedicated significant CSR investments to water infrastructure. Yet it is equally notable that it has not been transparent about the climate-related risks linked to their operations. The company has not disclosed the results of its climate risk assessments to relevant public authorities or local communities, leaving them without the information necessary to evaluate the risks associated with mining activities in a context of climate change. Even though water stress is a key climate risk and the project has been designed to reduce its impacts on water resources, climate adaptation was not discussed explicitly with local stakeholders. Two civil society representatives we interviewed were concerned about the lack of a public debate on the long-term sustainability of the company’s adaptation strategies. They warned that the climate-related risks associated with the project had been significantly underestimated. They were also worried that water stress would severely affect local populations in the future (Interviews 47, 81). This suggests that the lack of transparency regarding the short- and long-term effects on water stress is an important shortcoming in Anglo American’s approach.

Overall, while Anglo American has made significant CSR investments in adaptation and has taken some steps to assess climate risks to society and engage in participatory process, it has not been transparent about the risks associated with mining in a context of climate change.

Table 1 presents an overview of the integration of the principles in the three cases. The findings are consistent with our analysis in Section 3. The assessment of climate risks to society is a relatively new practice in each of the three cases. Compared to the other companies, Cerro Corona followed a more systematic approach in seeking to include community vulnerability in its climate risk assessments. By contrast, Antamina had a more reactive approach, while Quellaveco offered only a generic analysis of community vulnerability, which inevitably limits its utility as a tool for proactively identifying climate-related risks. CSR investments in public adaptation goods appear to be the most systematically integrated principles in all three cases. Finally, although each company has participatory procedures for involving local communities in addressing some climate-related risks, specifically those relating to water, they have disclosed only selective information about climate risks and adaptation interventions. Without access to such information, it is difficult, if not impossible, for local communities or governmental agencies to hold companies accountable for how they handle the risks linked to mining activities in a context of climate change.

Taken together, the findings suggest that there are both differences and similarities in RBC in adaptation between the three companies. All have primarily addressed climate risks through conventional CSR strategies rather than through procedural components of RBC, such as risk assessments, stakeholder participation, and transparency.

Table 1Companies’ adherence to the principles of responsible business conduct.

Table 1Long description

Assessment of climate risks to society: Antamina and Quellaveco adhered partially, while Cerro Corona adhered to a large extent. CSR investments: Antamina showed significant adherence, and both Cerro Corona and Quellaveco adhered to a large extent. Participation: All three companies adhered only partially to this principle. Transparency: Antamina and Cerro Corona adhered to a little extent, and Quellaveco did not adhere at all.

Public Governance

Climate governance in Peru is in its early stages. Although the country has taken a progressive stance in international climate negotiations, progress in the domestic policy arena has been limited. In 2014, Peru hosted the twentieth session of the Conference of the Parties (COP20) and played a central role in the multilateral negotiations that led to the Paris Agreement in 2015 (Castro Pereira Reference Castro Pereira2023).

In 2018, Peru passed the Climate Change Framework Law (Framework Law No. 30754) – its first framework law on climate change – which established a relatively ambitious structure for public policies on climate adaptation and mitigation. For its work on climate mitigation, Peru has received substantial international funding for forest conservation in the Amazon, and climate mitigating has been a key priority for MINAM (Interviews 16, 48, 69). However, there is an urgent need to accelerate adaptation efforts given the country’s climate vulnerability and the severe water stress (Figures 5 and 6). In 2021, the National Adaptation plan was adopted (RM 096-2021). MINAM’s efforts to implement the adaptation plan have, however, been undermined by a lack of resources, a paucity of data on climate impacts, the weak institutional capacities of regional governments, and the counter-lobbying in which economic and political elites have engaged (Interviews 50, 58). Against this backdrop, the Peruvian government has sought to steer corporate adaptation efforts via multistakeholder initiatives and dialogues rather than regulatory controls.

The Ministry of Energy and Mining (MINEM), which is responsible for regulating large-scale mining, has so far done little to incorporate climate adaptation into sectoral governance instruments, leaving it up to companies to voluntarily integrate the RBC principles in their adaptation responses. For example, in EIAs the anticipated impacts of a mining project are evaluated, and companies are bound to disclose the results of risk assessments and organize public consultations. However, the Peruvian EIA regulation only requires companies to present a climate change study, while – in contrast to other types of risks – there are no requirements to establish a management plan to redress the climate risks identified (Law no. 27446). The National Environmental Certification Service for Sustainable Investments has developed voluntary guidelines for integrating climate adaptation measures into EIAs. However, according to two interviewees working at the state agency that monitors the mining sector, without enforceable legal obligations, the uptake of guidelines like these has been limited (Interviews 70, 71). Similarly, there are no legal requirements that climate impacts be considered, be transparent, and enable stakeholder participation in the design of tailings dams and closure plans (Interview 69, 72). The National Water Authority does not take future climate impacts on water resources into account when approving water concessions for mining companies, which implies that the state has no information about intersecting impacts between climate change and mining activities (Interview 32). Consequently, there is no instance of the Peruvian government limiting or prohibiting mining activities that could have adverse impacts on society or the environment.

Indeed, representatives of the companies we studied all agreed that neither existing nor the threat of future state regulations have influenced their adaptation strategies; under the circumstances, they were not perceived as providing any meaningful incentives for them to integrate RBC in adaptation. Both Antamina and Gold Fields have occasionally disclosed climate risk assessments to local communities, but none of the companies have institutionalized such procedures, as previously discussed. Further diminishing its utility, the information that is disclosed tends to be fragmented and selective. As a representative at Antamina argued: “As it’s not a legal requirement, not even in the EIA, it’s just a question of voluntary social responsibility” (Interview 80, see also 85). A representative of Gold Fields both underscored the need for state regulations to ensure that companies address climate risks in a transparent and inclusionary way, but recognized that the majority of mining companies were strongly opposed to such regulations (Interview 78). Our findings suggest that the absence of strict legal requirements has been, and continues to be, a critical impediment to fostering RBC in adaptation.

Instead, MINAM and regional governments have sought to incentivize companies to engage in climate adaptation through dialogues and partnerships. While such processes could potentially foster greater transparency and participation, national and subnational officials emphasize that these initiatives are mainly used as a means of persuading large companies, specifically in the mining sector, to commit financial resources toward the implementation of adaptation plans, particularly by investing in water storage infrastructure (Interviews 59, 64, 69). According to an interviewee responsible for climate adaptation in Cajamarca, subnational government officials were inspired by Gold Fields’ adaptation project and considered inviting mining companies to help implement their own climate adaptation plans. However, others stressed the risks of business capture of the adaptation agenda, which could delay or even derail discussions on the ways mining activities might undermine societal resilience (Interviews 48, 49).

To promote greater private sector involvement, national authorities have relied on soft steering and established multistakeholder initiatives and partnerships. In 2021 MINAM formed a steering group aimed at engaging the private sector in implementing the Nationally Determined Contributions, which are plans laying out national strategies for climate action under the Paris Agreement. In the steering group, twenty business associations participate regularly (MINAM n.d.). The Ministry of Agriculture, through the Sierra Azul climate adaptation fund, has promoted public–private partnerships, notably by granting tax deductions for contributions to water storage infrastructure for small farmers. Antamina is among the mines that benefitted from partnerships of this type (Antamina 2017). With water infrastructure being a key demand of local populations, representatives from Anglo American and Gold Fields have also shown interest in participating in a climate-related partnership (Interviews 78, 85). Public institutions have used this as a means to incentivize companies to make CSR investments in public adaptation goods. Earmarking funds to this end aligns with companies’ need to legitimize their presence by showcasing their positive impacts on local development.

Another important soft steering mechanism is the provision of scientific data on climate risks. Public institutions have used existing public databases on disaster risks to support companies to assess climate risks to society and thereby reduce the risks of dangerous accidents. The National Center for Estimation, Prevention and Reduction of Disaster Risks, which delivers high-quality scientific data on regional climate disaster risks, partnered with Antamina to develop a Community Early Warning System and supported the company in climate-proofing the pipeline it uses to transport minerals. The Environmental Assessment and Enforcement Agency of Peru has started to collect data on extreme weather events to alert companies about emergencies that could lead to the collapse of tailings dams (Interview 70). These examples show how public institutions have sought to steer companies to integrate the RBC principles by providing scientific information about climate risks.

However, in the absence of any legal requirements, the use of such data is likely to be limited. Moreover, while there is high-quality data on climate disasters, the National Water Authority has no information on the effects of climate change on water stress. This lack of data is a significant limitation, as this is the most pressing climate impact in many mining localities in Peru.

Although the three companies interact closely with regional and local governments, company representatives did not perceive climate adaptation as a salient topic in any of the subnational regions (Interviews 78, 80, 85), which is likely because the three regions are still in the process of developing their adaptation plans. In the case of Cerro Corona, company representatives highlighted a lack of support from the local government as the main reason they stopped working on climate adaptation governance (Interviews 60, 78). None of the subnational governments have used formal adaptation planning institutions as a way to steer companies’ adaptation strategies. Moquegua stands out among the regional governments in having negotiated an agreement in which Anglo American committed to making major investments in water infrastructure and changes in the engineering design of the project. By conditioning the acceptance of the project on these changes, the regional government contributed to improve the company’s adaptation strategy (Gustafsson and Scurrah Reference Gustafsson and Scurrah2023).

Overall, public governance imposes no legal restrictions on companies in the area of adaptation. Instead, it primarily incentivizes the use of CSR investments through partnerships and, to a lesser extent, through the provision of scientific data about climate-induced disasters. However, there are also important differences among the cases. In the case of Quellaveco, the regional government played a significant role in shaping how the company addressed climate-induced water stress. This influence can be attributed to the regional government’s capacity to generate and deploy scientific data to evaluate the project’s impact under conditions of climate-induced water stress, which gave it greater leverage in negotiating CSR investments in water infrastructure with the company. In the other two cases, subnational governments had less influence on corporate adaptation strategies. They mainly entered into partnerships with the companies to incentivize them to make CSR investments in water infrastructure. Taken together, and in line with our expectations, we found significant barriers related to the absence of regulatory controls and the limited capacity of national authorities and subnational governments to use soft steering to influence corporate adaptation behavior, except for making CSR investments.

Voluntary Adaptation Standards

As per our theoretical expectation, without legally binding rules, emergent voluntary adaptation standards can contribute to the incorporation of the RBC principles in companies’ risk management systems through monitoring of compliance and capacity-building incentives. While the quality of compliance monitoring varies widely, at the very least standards can contribute to the spread of norms and best practice about responsible business behavior in adaptation (Marx et al. Reference Marx, Depoorter, Fernandez de Cordoba and Verma2024). In the context of adaptation, standards have primarily appeared in response to investors’ concerns about the effects of climate impacts on operational resilience and the sustainability of business practices, suggesting that market incentives have generated a demand for such standards. For instance, the Equator Principles, supported by national and international financial institutions, require companies to consider climate risks in EIAs for all major projects (Equator Principles 2020). With climate impacts identified as one of the most serious threats to business resilience, investors are increasingly in search of reliable data on how companies handle climate adaptation. A variety of private voluntary standards have emerged to support companies in meeting investor requirements. For instance, in 2015, the Financial Stability Board established the TCFD, which was widely used by companies until it was disbanded in 2023. It was replaced by the International Financial Reporting Standards, which will further develop climate-related disclosure. In the mining sector, ICMM has played an important role in developing industry-specific standards for adapting to climate-induced change and provided a valuable platform for exchanging experiences in the larger arena of climate adaptation.

Representatives of both Gold Fields and Anglo American emphasized the critical capacity-building role of ICMM’s standard and underlying investor pressure in the development of their adaptation strategies (Interviews 78, 85). A representative of ICMM recognized Gold Fields as a company that had been particularly active in developing and implementing ICMM frameworks on climate adaptation and community resilience (Interview 6). Likewise, an interviewee speaking on behalf of Antamina recognized that ICMM frameworks had been an important reference point for their work on adaptation (Interview 80).

Whereas private voluntary standards have clearly influenced the adaptation strategies of the three companies, standards differ in the extent to which they integrate RBC principles. For instance, reporting in line with the TCFD is aimed at increasing transparency vis-á-vis investors, yet the information disclosed is too generic to provide the affected parties and governmental agencies much, if any, relevant information about site-specific climate risk assessments and adaptation strategies. One contributing factor is likely to be the absence of a clear definition of “adaptation,” which has given companies significant discretion in presenting their findings on risk exposure and adaptation measures. In turn, differences in the level of detail incorporated into their adaptation reports are readily discernible. For example, Gold Fields provides a detailed account of identified risks, adaptation interventions, and the progress achieved (Gold Fields 2022). In contrast, Anglo American presents only general country-level risks on a purpose-specific map, without offering any information on prioritized risks or adaptation interventions (Anglo American 2022). The same applies to the owners of Antamina (Glencore 2021; Teck 2022). This suggests that TCFD has not contributed to provide local communities and governmental agencies with relevant and accessible information about climate risks and adaptation measures. Hence, existing voluntary adaptation standards have done little to improve transparency.

Compared to the TCFD, ICMM provides more detailed specifications on RBC principles in its standard. However, its requirements remain too lax, lacking the concrete indicators and monitoring mechanisms to significantly improve corporate adaptation. For example, according to ICMM’s principles, companies should “engage with host communities on our shared climate change risks and opportunities and help host communities to understand how they can adapt to the physical impact of climate change” (ICMM 2021: 5). By 2016, ICMM had launched a Climate Assessment Data Tool that companies could use to assess the climate risk exposure of their own operations and for that of surrounding communities (ICMM 2019). This could potentially be used as a means both to disclose information and to involve local communities in assessing climate risks and planning for adaptation. However, use of this tool is entirely voluntary, with no specific requirements or indicators guiding companies on how to engage host communities in participatory adaptation processes. As a result, while Gold Fields piloted the tool, it did not involve affected communities in its climate risk assessments. Ultimately, the lack of specific indicators and strong enforcement mechanisms limits the effectiveness of these standards in shaping corporate behavior.

By contrast, water stewardship and tailings dam standards are included among key performance indicators, with company compliance monitored by independent auditors. These areas have relatively detailed requirements, including on how to engage communities in planning processes (ICMM 2020: 27). In our three cases, company representatives emphasized that they had made some changes to comply with the new tailing dam standards, suggesting that the enforcement mechanism has generated some level of compliance (Interviews 78, 80, 85).

In contrast, compliance with water stewardship and other adaptation-related aspects of the ICMM standard appears to be subject to interpretation and internal prioritization. Gold Fields representatives emphasize that their decision to focus on climate adaptation and community resilience was made early and taken seriously by key decision-makers (Interviews 36, 37, 78). Similarly, representatives of Anglo American affirm that climate adaptation is a priority, while acknowledging that their primary focus has been on addressing the urgent issue of water stress (Interview 85).

In the end, ICMM appears to prioritize capacity-building in adaptation while allowing companies significant flexibility in interpreting and constructing compliance with the standard. It seems to be intended to influence company behavior by learning and support, rather than imposing burdens and controls on companies. As a former ICMM employee remarked, “there is always a tension between minimizing the costs for the companies and improving sustainability within ICMM […] and they are always more inclined to listen to the demands of the investors” (Interview 87, see also interview 78). The absence of clear and measurable indicators of adaptation has made meaningful compliance dependent upon the efforts of internal champions to convince other firm actors to comply. Norm entrepreneurs of this kind were especially active players in the Cerro Corona case until 2020, when a community relationship team less committed to community resilience took over (Interview 78).

Compared to the OECD guidelines that stipulate that companies have an obligation to avoid negative socio-environmental impacts when adapting to climate change (OECD 2023: 37), ICMM’s adaptation standard is more lax. ICMM portrays climate impacts as a shared risk and presents the business case for voluntarily supporting community adaptation. This framing allows for the decoupling of climate impacts from business activities, positioning companies as affected groups rather than as being responsible for exacerbating such risks. Generally, ICMM favors a voluntary CSR approach to climate adaptation rather than one centering on an obligation to do no harm.

To conclude, in the absence of domestic legislation, private voluntary adaptation standards began to emerge after 2015. These standards have played a key role in spreading norms and promoting learning about RBC in adaptation, particularly in the case of Gold Fields. However, adaptation is only partially included among audited performance indicators, and weak enforcement mechanisms grant companies significant discretion in interpreting ICMM’s standards. As a result, meaningful compliance often depends on the commitment of key decision-makers within these companies. In all, our findings in all three cases support our expectation that companies will rely on voluntary standards to incorporate the RBC principles, but our analysis suggests that their influence is weak as the majority of existing standards are not accompanied by strong enforcement mechanisms.

Civil Society Advocacy

Although voluntary adaptation standards have spread awareness about the RBC principles, there has been a noticeable absence of civil society demands for companies to align their actions with these principles. Instead, CSO advocacy has mainly centered on companies’ negative impacts on water resources, leading companies to offer CSR investments in water infrastructure as compensation for negative impacts. In contrast, CSOs have rarely pressured companies either to enable stakeholder participation or to become more transparent about their adaptation-related actions. In the three cases we examined, the relative strength and capacity of CSOs to effectively negotiate with companies differed.

Although the region where Cerro Corona is situated has strong movements that have blocked several large-scale mines, the project has not been the movement’s focus. In addition to being localized and somewhat fragmented, CSO attempts to negotiate with the company have tended to prioritize CSR investments. Local communities are divided between those that have benefited from CSR investments and the labor opportunities they provide and those that have not. Their principal demand has been to construct new water reservoirs or improve existing ones (Interviews 54, 55). Recognizing that water scarcity is a very sensitive issue, representatives of Gold Fields have focused on reservoir-building (Goldfields 2019: 112; Interview 78). Communities have also raised concerns about water pollution. For instance, the river pollution that ensued after the leakage of the tailings dam in 2018 prompted communities to ally with the municipal government and rural organizations in the region to file a legal complaint against the company, which had not been settled as of late 2024 (Interview 56). In this and other cases, communities perceived climate impacts as inseparable from the existing water-related impacts of mining activities rather than as a qualitatively new phenomenon.

Likewise, there has been no large-scale mobilization against the Antamina project. Sporadic community protests have focused on specific mining-related impacts that have been exacerbated by climate change. It was only after communities raised concerns about the tailings dam that the company developed an emergency plan. Protests related to risks associated with the pipeline led the company to take appropriate climate-proofing measures and invest in several adaptation projects. Company representatives we spoke to recognized that concerns about community protests were critical to Antamina’s decision to remediate these climate impacts (Interviews 61, 62, 80). Here as well, localized protests played a significant role in the company’s decision to disclose pertinent information, involve communities in adaptation planning, and invest in CSR initiatives meant to improve water infrastructure.

In the case of Quellaveco, CSOs were able to form a broad-based coalition with local elites, business groups, NGOs, rural organizations, and the regional government that demanded the company to find a solution to reduce its impacts on scarce water resources. In response, the company changed the project’s design and invested in the water harvesting infrastructure needed to extend the agricultural frontier in the Atacama desert (Anglo American n.d.).

Our findings suggest that civil society advocacy has often foregrounded the impact of mining activities on water resources and lead to strong demands for CSR investments in water infrastructure. Climate change and adaptation have largely been absent from CSO demands, which helps explain why there has been so little progress toward institutionalizing the other procedurally oriented principles. Although CSOs recognize the impacts of climate change on water stress, they emphasize that mining companies are principally responsible for the current water scarcity (Interviews 56, 63, 67). In each case, local communities have concentrated their efforts on providing scientific evidence showing the impact of mining activities on water quantity and quality, challenging companies to become more transparent about their negative impacts on water. In the presence of competing expert knowledge, it has proven difficult to demonstrate causality for negative impacts, as, for instance, illustrated in the case of the pollution for which Gold Fields was responsible (Interviews 53, 63, 79).

In contrast, CSOs have rarely demanded that companies become more transparent and inclusionary in their responses to climate impacts. Mobilizing around issues where it is difficult to attribute responsibility to specific actors is generally more challenging (cf. Carpenter Reference Carpenter2007). Whereas public institutions are responsible for helping communities cope with the physical impacts of climate change, companies must ensure that their business activities do not further exacerbate them and heighten society’s exposure to danger. In practice, it can be hard to distinguish between the intersecting impacts of climate change and business activities. CSOs thus have little incentive to frame their demands in terms of climate change, as it would not only make it more technically challenging to compile evidence of mining impacts, but it would also dilute corporate responsibility for their presence.

Whereas company representatives in both the Antamina and Cerro Corona cases sought to portray climate risks as shared, organizations of civil society rejected this framing. Local communities in the Cerro Corona interpreted Gold Field’s educational programs about climate adaptation as an attempt to avoid responsibility by blaming the global phenomenon of climate change without recognizing their responsibility for the double exposure of local communities to such intersecting impacts (Interview 54). Advocacy has instead focused on compelling companies to assume responsibility for their impacts on water resources.

That said, some civil society representatives have been critical of the insufficient attention given to climate adaptation. Gold Fields, for example, has submitted an EIA for extending its operations, but rural organizations have argued against approving this and other new mining projects affecting water resources in the face of climate change (Interviews 53, 57, 63). Similar concerns have been raised in the Antamina case (Interview 67). Had CSOs challenged the ways in which mining companies handle climate impacts, companies may have felt increased pressure to handle climate risks in a more transparent and inclusionary way. However, as such demands were rare, the companies in our three cases have largely abstained from engaging in public debates about climate adaptation.

Overall, civil society advocacy has concentrated on convincing companies to disclose information and compensate local communities for the negative impacts on water resources through CSR investments in water infrastructure. These demands have rarely been framed in terms of climate change. While this might be due to lack of awareness of the intersecting impacts of mining activities and climate change, the climate adaptation framing also makes it harder to ascribe responsibility to companies, a factor that provides at least a partial explanation for CSOs’ avoidance of this frame. In the three cases examined, advocacy has worked to induce companies both to make CSR investments in water infrastructure and to involve local communities in participatory monitoring processes around water resources. Thus, civil society advocacy has played a crucial role in pressuring companies to integrate RBC principles. However, this pressure has been selective, as important components such as climate risk assessments and transparency were largely absent from their demands.