Three years ago, if you were a procurement officer for a mining camp, your RFQ asked two questions: "Price per square meter?" and "Delivery lead time?" Today, a growing number of international mining companies are adding questions that cannot be ignored:
These are not talking points from an environmental NGO. They are substantive clauses that more than half of the world's top 20 mining companies have already incorporated into their supplier onboarding process. From BHP and Rio Tinto in Australia to Vale in Brazil and Glencore in Switzerland, ESG compliance is no longer a paragraph buried in a corporate social responsibility report — it is becoming a non-negotiable procurement gate.
The ESG pressure on mining companies comes from three directions.
First: the capital markets. The London Stock Exchange, the Australian Securities Exchange, and the Toronto Stock Exchange — the world's major mining capital markets are tightening ESG disclosure requirements year by year. The LSE's updated Climate Disclosure Guidance in 2025 requires listed companies to report Scope 1, Scope 2, and Scope 3 carbon emissions. For mining companies, camp energy consumption and construction material emissions fall under Scope 3 — the hardest category to quantify and reduce.
Second: sovereign wealth funds and pensions. Norway's Government Pension Fund Global (the world's largest sovereign fund, managing USD 1.7 trillion) updated its responsible investment policy in 2022, imposing specific disclosure requirements on Indigenous community impact and worker accommodation standards for its mining holdings. The Canada Pension Plan Investments (CPP Investments) stated in its 2025 annual report that camp facility compliance is treated as a "community relations risk" indicator in mining investment evaluations.
Third: host-country mining permit reviews. Chile, Peru, the DRC, Indonesia — the mining authorities in these resource-rich countries are tightening social impact assessments for camp facilities when approving new mines or expansions. Peru's Ministry of Energy and Mines released a 2025 regulation requiring all new mine camp proposals to include a "community coexistence plan," covering: camp water supply must not compete with surrounding communities, camp infrastructure must be accessible to the community, and camp waste management plans require local government approval.
Trend 1: From "cheapest" to "carbon-calculable."
Unit price used to be the only metric. Now, more RFQs ask suppliers for one additional data point: the embodied carbon per square meter of the modules.
Embodied carbon refers to the total CO2 equivalent emitted throughout the lifecycle of building materials — extraction, transport, processing, and installation. For a 500-person mining camp, the choice of wall core material (EPS vs rock wool vs PIR) determines approximately 35% to 45% of the structural embodied carbon.
Rock wool sandwich panels have an embodied carbon of approximately 12 to 18 kg CO2e per square meter. EPS panels: 8 to 12 kg. While rock wool is higher, it is non-combustible and has a longer service life (15 years vs 8 to 10 years for EPS). On a full lifecycle basis, rock wool's annualized carbon impact is actually lower. PIR falls between the two at 10 to 15 kg CO2e per square meter.
What really separates procurement options, however, is the steel structure design. 9States has begun applying high-strength steel (Q355+ grade) in select projects. Compared to conventional Q235 steel, high-strength steel reduces material usage by 15% to 20% while maintaining structural integrity. For a camp with 200 tons of steel framing, that translates to 60 to 80 tons of CO2 reduction.
Trend 2: From "single-use" to "relocatable and recyclable."
Traditional brick-and-mortar camps or welded container camps become almost entirely construction waste after decommissioning. In ESG evaluation systems, this is "linear economy" — extract, build, use, demolish, discard.
Modular buildings are inherently circular. A steel-framed flat-pack camp can serve one mine site for 5 to 10 years, then be fully dismantled and reassembled at a new site. In 9States' project experience, unit reusability exceeds 90%. The main items replaced are sealing gaskets, some insulation material, and surface coatings.
This feature is becoming a compliance advantage. In 2025, the environmental impact assessment (EIA) for a copper mine expansion in Chile explicitly required that the new camp not use brick-and-concrete construction — on the grounds that "temporary facilities must use relocatable solutions to minimize long-term environmental legacy." The mine operator chose modular container units not because of price but because it was the only option that passed the EIA requirement.
Trend 3: From "imported" to "locally embedded."
The "S" in ESG — social responsibility — is becoming a decisive factor in camp procurement.
In the past, mining camp supply was a "enclave" model: the Chinese supplier shipped container units, assembled them with Chinese workers on site, and had almost no interaction with the local community during camp operation.
Today, multiple countries are mandating local content requirements. The DRC and Zambia updated their mining code implementing regulations in late 2024, requiring that a minimum percentage of mine infrastructure procurement (materials and labor) must be sourced locally. South Africa's Mining Charter has long included similar provisions.
On a 9States gold mine camp project in Ghana, the container units were shipped from China, but all concrete foundations, MEP installation, and interior finishing labor were recruited locally — 12 local workers plus 2 Chinese technical supervisors completed the entire installation. The client later cited this as a "local employment contribution" in its annual ESG report.
ESG-driven design changes are moving from "nice to have" to "must have":
Materials:
Operations:
Social engagement:
For mining company procurement teams, ESG compliance does not mean choosing the most expensive option. What matters is whether the supplier can produce a complete compliance documentation package: material carbon footprint calculations, circular economy plans, and local sourcing commitments.
Based on 9States' experience, the unit price difference between an ESG-compliant supplier proposal and a plain quote-only proposal is typically 8% to 12%. But the former gives the client verifiable data points for their ESG reports — data that, in the rating systems of major stock exchanges, directly affects the cost of capital for listed companies.
For 9States, embedding ESG compliance capability into our product offering is not because we claim to be "greener" than anyone else. It is because this is what our clients are asking for. We are simply following the market.
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