Extractive Commodity Trading Report 2023

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The trading of extractive commodities (oil and gas, metals and minerals) is of huge importance, not only in maintaining global flows of these resources but also in providing many resource-rich countries with critical revenues for their economic development. Recent events have underscored the interconnections between the commodity trading sector and sustainable development. This is seen for example in the commodity market disruption caused by the Covid-19 pandemic and the sanctions imposed by some countries since the start of the war in Ukraine, and in recent high-profile cases of bribery and corruption within the sector.

Governments, financiers, customers and consumers are showing increased awareness of the need for the commodity trading industry to demonstrate more systematic action and transparency on economic, environmental, social and governance issues if internationally agreed aims on human rights, sustainable development and accountable financial flows are to be achieved – including the UN Sustainable Development Goals.

The Extractive Commodity Trading Report (ECTR) 2023 is an evidence-based assessment of due diligence and public disclosure among a sample of companies in the extractive commodity trading sector. Coming two years after the first edition of the assessment, the Report continues to track, and encourage improvement in, companies’ policies and practices related to responsible sourcing and public data sharing.

The 25 geographically dispersed companies included in the assessment have significant activities in the trade of oil, gas, metals or minerals sourced from third parties, and include traditional trading companies, international oil companies, and integrated companies (involved in both production and trading).

Companies assessed in the report

BP trading & shipping, CCI, Chevron Supply and Trading,, CITIC Metal, ConocoPhillips, Eni Trade & Biofuels, ExxonMobil, Gerald Group, Glencore, Gunvor, LITASCO, Mercuria, Minmetals International, Mitsubishi Corporation, Mitsui, MRI Trading, Noble Resources, Phibro, RGL Group, Shell International Trading and Shipping, TotalEnergies Trading & Shipping, Trafigura, UNIPEC, Vitol, and Wogen



The assessment focuses on issues related to the trading activities of each company, providing an overview of the basic measures that the companies are taking to: (1) manage their supply chain risks related to human rights abuses, illicit financial flows and environmental damage; and (2) publicly share data on their corporate governance, trading activities and other public interest issues.

The assessment results offer companies a ‘gap analysis’ of their current performance, indicating where improvement is most needed. More broadly, the assessment supports industry-wide learning by providing a framework that can be used by all companies in the extractive commodity trading sector and by other stakeholders (e.g., banks, investors, industry associations, etc.) to develop their own approaches on these key issues.

Companies and other stakeholders can use the results, recommendations and learning resources in this report to improve their due diligence and public reporting. For example, the interactive library or over 1,500 documents (sourced largely from the assessed companies) includes useful models of tools such as supplier expectations, risk assessment questionnaires and public reporting frameworks.

The full assessment framework of indicators and metrics is included in the report (See Annex 3).


Key findings & Recommendations

[1] Most due diligence systems fall far short of robust risk management

Most companies’ due diligence systems are very limited, covering little more than the initial step of setting expectations for their suppliers. Few systems extend to the critical stages of assessing supplier compliance, engaging with suppliers, and taking action to address any non-compliance. This is the case for due diligence systems on all three risk areas studied: human rights abuses, illicit financial flows, and environmental damage, with evidence particularly weak on assessment and mitigation of environmental risks. Without these elements the due diligence systems will never contribute to the prevention of these significant supply chain issues.

→ Recommendation: Companies can learn from the few examples of comprehensive due diligence systems demonstrated by some of their peers.

[2] Little effort to improve effectiveness of due diligence systems

Very few companies can show they are checking how well their due diligence measures are working. For example, about two-thirds of the companies show no evidence of tracking and reporting their performance on managing human rights risks in their supply chain. A similar proportion of companies show no evidence of tracking and reporting their performance on preventing illicit financial flows. Given the harmful practices that continue to come to light, particularly on illicit financial flows, the onus is on companies to demonstrate they are reviewing their performance on responsible sourcing and seeking ways to strengthen it.

→ Recommendation: Companies can enhance their continuous improvement efforts by increasing their focus on the last two critical steps of the ‘plan-do-check-act’ management cycle.

[3] Some companies are debunking the myth that public disclosure harms competitiveness

Very few companies are publicly disclosing information of strong public interest such as their annual turnover, the taxes they pay, or their purchases from governments or state-owned enterprises. One of the reasons cited by companies for non-disclosure is that financial data of this kind is highly confidential, and public disclosure could harm their competitiveness. Yet on each of these issues a few companies (private as well as publicly listed) show strong and voluntary disclosure. These good practices demonstrate that transparency on these issues can be considered compatible with competitiveness.

→ Recommendation: Companies can follow the examples of their more transparent peers to share public interest data without compromising their competitiveness.

[4] Anti-bribery and corruption systems rarely supported by practical measures

While most companies have anti-bribery and corruption (ABC) systems, including a compliance function and whistleblowing mechanism, there is less evidence of companies ensuring that their employees routinely fulfil their ABC responsibilities. Few companies show detailed evidence of conducting regular training on ABC for their workforce. And there is no evidence that ABC performance is included in any ESG executive compensation criteria. These kinds of practical measures are critical as ABC risks are by no means hypothetical. Several assessed companies have been subject to recent investigations or legal action relating to bribery and corruption.

→ Recommendation: Companies can improve their prevention of bribery and corruption by strengthening awareness and accountability at all levels of their workforce.

[5] Weak progress overall, some individual improvements

There is no sign of a marked shift towards responsible and transparent practices. The overall average performance has increased only minimally, from 33% to 34% in the last two years. Nonetheless, the majority of companies show progress on at least one issue. Improvements include, for example, new policy commitments, new management standards, and more public sharing of public interest data. Currently a few companies show significantly stronger results among those assessed, and it is encouraging to see that some companies are starting to catch up with their better-performing peers.

→ Recommendation: Companies can use the results of this assessment to improve their due diligence practices and strengthen their public disclosure.


Document Library

The searchable document library includes approximately 1,500 source documents (sourced from the public domain or submitted by companies), which have been reviewed during the assessment of the 25 companies. It is possible to search for a specific text in the titles, using the relevant field. The library can momentarily only be accessed through the Responsible Mining Foundation website.

Access the Document Library


The findings, conclusions and interpretations within the Extractive Commodity Trading Report 2023 do not necessarily represent the views of funders, trustees, and employees of WRF or RMF, and others who participated in consultations and as advisors to the report.

This report is intended to be for information purposes only and is not intended as promotional material in any respect. The report is not intended to provide accounting, legal, tax or investment advice or recommendations, neither is it intended as an offer or solicitation for the purchase or sale of any financial instrument.

The assessment reported on in the Extractive Commodity Trading Report 2023 seeks evidence of companies’ policies and practices on economic, environmental, social and governance (EESG) issues, but does not seek to measure the actual outcomes achieved on EESG issues. Results are based only on evidence sourced from the public domain or provided by companies as open data. Whilst this information is believed to be reliable, no guarantee can be given that it is accurate or complete, nor does it preclude the possibility that policies and practices may exist, but which the report has not been able to consider for purposes of assessment. In this respect, the results of the low-scoring companies do not necessarily reflect a lack of relevant policies and practices; as they may be due to a lack of public reporting by the companies, limitations in accessing information, and/or any difficulties in accessing the company portal during the company review period.

It should be noted that, prior to publication, all companies assessed were invited to check the factual accuracy of the contextual data presented and to review company information to be included in the document library.

Country borders or names on maps do not reflect an official position of WRF or RMF or anyone involved in their governance, employees or in service providers. Maps used are for illustrative purposes and do not imply the expression of any opinion on the part of WRF or RMF concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Where needed, approaches used by the UN to present borders were followed.

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Users are free to share and adapt the material but must give appropriate credit, provide a link to the license and indicate if changes were made. The licensed material may not be used for commercial purposes, or in a discriminating, degrading or distorting way. When cited, attribute to: WRF and RMF, 2023. Extractive Commodity Trading Report 2023. Images, and video content depicted on WRF or RMF websites are excluded from this license, except where noted.