CRM Mining in Central Asia Region: Recommendations from Civil Society

1. Transparency and Accountability 
Both Issues of transparency and accountability in subsoil use have always been and remain crucial for local communities. According to the Constitutions of almost all Central Asian countries, the subsoil of these states belongs to the people. People have the right to know the benefits they receive from the use of the country's natural resources and to participate in decision-making, which can be realized through public consultations and local budget planning. Companies entering new projects typically either disclose no information at all about their ownership structure, production chains, taxes paid, production volumes and costs in a specific project, or limit themselves to very general information, using the phrases “major producer,” “company with a long history,” or “responsible and careful subsoil user.”
In this regard, companies, participating in Global Gateway, may have a distinct advantage over their direct competitors in Central Asia, in terms of transparency and accountability—their accessible and understandable social and environmental policies, stated approaches to protecting workers' rights, etc. Given the challenging competition for mineral resources in the Central Asian region, a responsible approach to fulfilling social and environmental obligations, a transparent and fair system for hiring local labour, and respect for labour rights foster a positive attitude toward the company's activities among local communities and increase trust, fostering a positive atmosphere and reducing social tension.
Global Gateway could play a more systemic role in improving transparency and accountability by embedding clear and enforceable requirements into project financing and implementation, including mandatory disclosure of beneficial ownership, contract transparency, and project-level reporting on revenues, payments, and environmental impacts. In addition, support for public participation mechanisms—such as meaningful consultations with local communities and the disclosure of accessible project information—could strengthen the social license to operate and align projects with the expectations of citizens as the ultimate owners of subsoil resources.
From a practical perspective, this requires strengthening compliance and governance mechanisms; Global Gateway can reinforce these efforts by making high standards of transparency, ESG compliance, and community engagement binding conditions for financing, while also supporting civil society oversight and building the capacity of local institutions to monitor and enforce these requirements effectively.

2. Corruption
Corruption in the extractive sector is one of the most serious problems in Central Asia. All countries in the region rank near the bottom of the Corruption Perceptions Index, and there are no clear signs of improvement. This is facilitated by relatively weak and flexible legislation, which allows for the implementation of corruption schemes, and a lack of information about extractive projects, which hinders the external assessment of corruption risks. Overall, corruption turns natural resources into a source of costs for the region, resulting in deteriorating infrastructure, poor environmental conditions, and loss of public trust. 
A critical requirement for combating corruption is a clear and transparent understanding of a company's ownership structure. If a mining project exhibits signs of corruption risks—hidden ultimate beneficiaries, a complex and opaque chain of ownership, data discrepancies where ownership registers and company annual reports show differences in beneficiaries—such a project raises questions among local communities and undermines trust not only in the project itself but also in the entire operations of the company or group of companies in the country. Companies that have accessible and understandable anti-corruption policies, proactive measures to prevent corruption, and visible monitoring of corruption risks contribute to increased trust in the company's operations, thereby creating a competitive advantage. 
In this context, Global Gateway could play an important role in addressing governance challenges in the extractive sector. At the practical level, this implies a set of concrete measures aimed at strengthening compliance and risk management. Participating companies should implement robust compliance systems, including regular independent audits, and continuous corruption risk assessments across the entire value chain. The introduction of internal whistleblowing mechanisms, protection of reporting individuals, and clear procedures for investigating allegations can further reduce corruption risks. Global Gateway can support these efforts by making enhanced compliance systems, ESG due diligence, and transparency benchmarks a precondition for financing, while also investing in local institutional capacity and civil society oversight to ensure that these standards are effectively implemented in practice.

3. Grievance Mechanism
A “grievance and response mechanism” is one of the most pressing needs for local communities living in mining areas. It must be acknowledged that such a mechanism does not yet exist institutionally. Existing complaint mechanisms to government agencies regulating subsoil use are typically ineffective due to the formality of responses to complaints, while judicial mechanisms are time-consuming and require resources that local communities typically lack. At the same time, the implementation of any mining project inevitably entails grievances from local residents regarding deteriorating air quality, water pollution or shortages, increased energy consumption by the mining project to the detriment of local residents, soil contamination, the seizure of agricultural land for mining, unfair employment practices for local residents, and so on. 
In this context, Global Gateway could contribute to the institutionalization of effective grievance and response mechanisms as part of project design and financing conditions. By requiring participating 
companies to establish accessible, transparent, and culturally appropriate grievance mechanisms aligned with international standards, such frameworks can help ensure that community concerns are addressed in a timely and meaningful manner. Moreover, support for capacity-building of local authorities and civil society organizations can strengthen independent monitoring and facilitate dialogue between companies and affected communities, thereby reducing social tensions and conflict risks. 
From a practical standpoint, participating companies should implement formal grievance mechanisms that are easily accessible to local communities, including multiple reporting channels (online, in-person, anonymous), clear timelines for response, and public disclosure of how complaints are addressed. These mechanisms should be integrated into broader compliance systems, including environmental and social risk management, and subject to regular independent audits. Global Gateway can reinforce these approaches by making the existence and effectiveness of grievance mechanisms a precondition for financing. 

Conclusions
This The rapid expansion of CRM development in Central Asia presents both significant opportunities and substantial governance risks. This challenges related to transparency, corruption, and the absence of effective grievance mechanisms are not isolated issues but interconnected systemic weaknesses that directly affect the quality of life of local communities and the sustainability of mining projects. In this context, the values underpinning Global Gateway—transparency, accountability, high environmental and social standards, and inclusive partnerships—have the potential to serve as a transformative framework for the extractive sector in the region.
If applied consistently and as binding conditions rather than declarative principles, these values can help shift the current model of CRM extraction toward one that is more transparent, socially responsible, and development-oriented. In particular, embedding strict requirements on beneficial ownership disclosure, anti-corruption compliance, and community engagement, alongside enforceable grievance mechanisms, can reduce risks, increase public trust, and strengthen the social license to operate. At the same time, support for institutional capacity-building and civil society oversight is essential to ensure that these standards are implemented effectively in practice.
Ultimately, the role of Global Gateway in Central Asia’s CRM sector will depend on its ability to balance strategic interests in securing raw materials with a genuine commitment to its stated values. Where this balance is achieved, Global Gateway can contribute not only to more reliable supply chains, but also to improved governance, reduced social tensions, and more equitable distribution of the benefits derived from natural resources.