As private companies assume a growing role in climate adaptation, their strategies may harm society and ecosystems unless grounded in responsible business conduct. This Element offers a new perspective on responsible business conduct in climate adaptation, presenting a theoretical framework that explains how regulatory and political factors external to firms influence their consideration of societal needs when adapting to climate change. Using a novel quantitative and qualitative dataset, the Element shows that the world's largest mining companies have primarily addressed climate risks through conventional corporate social responsibility strategies rather than procedural components of responsible business conduct, such as risk assessments, participation, and transparency. The results suggest this outcome is best explained by a combination of weak governance, lax voluntary standards, and civil society advocacy. This title is also available as Open Access on Cambridge Core.