Zimbabwe Stock Exchange and Victoria Stock Exchange listing requirements: What are the opportunities to help advance mining sector transparency and accountability?


4 June 2021

Zimbabwe is yet to adopt the Extractive Industries Transparency Initiative (EITI)[1] or resuscitate the Zimbabwe Mining Revenue Transparency Initiative (ZIMRTI)[2] to fully bridge the transparency void in the mining sector. Despite expressing interest to join EITI, nothing tangible has been done towards this expression. However, there are other windows being opened towards enhancing transparency and accountability in the mining sector before the broader mining transparency reforms are achieved.

One such key window is the sustainability reporting framework which is provided for by the Statutory Instrument 134 of 2019 on Securities and Exchange (Zimbabwe Stock Exchange listing requirements) Rules. The governance instrument makes it mandatory for all companies listed on the Zimbabwe Stock Exchange to disclose Environmental, Social and Governance (ESG) information as part of their sustainability reporting.  The transparency window is also being reinforced by the current process to develop listing requirements for junior mining companies on the  recently launched Victoria Falls Stock Exchange.

This situation calls for CSOs such as the Publish What You Pay (PWYP) Zimbabwe coalition working on advancing good governance in the extractive sector not to sit back and fold their hands.  CSOs should be alive to mining disclosure windows which are opening. To help the PWYP Zimbabwe to gain a fair understanding of the opportunities that exist to advance transparency in the mining sector through governance instruments such as the Statutory Instrument 134 of 2019, the Zimbabwe Environmental Law Association (ZELA) organized a breakfast meeting. The meeting was held at Holiday Inn, in Harare on Monday, 31 May 2021. The meeting brought together the Zimbabwe Stock Exchange (ZSE) and Publish What You Pay (PWYP) members.

Data Disclosure Opportunities Presented by the ZSE Listing Requirements

The Statutory Instrument 134 of 2019 sets a number of requirements that listed companies are supposed to comply with. These include requirements for appointment of the company’s board of directors (Corporate Governance), publication of financial statements (Financial Disclosure) and sustainability disclosure. Under the sustainability listing requirement, all companies listed on the Zimbabwe Stock Exchange (ZSE) are mandated to produce Sustainability Reports. What is central to the sustainability listing requirement is the provision of a balanced and objective view on the company’s performance by including both positive and negative impacts on environment and society, how it relates to its stakeholders and contribute to sustainable development. The listing requirements on sustainability looks at disclosure on various aspects including Environmental, Social and Governance (ESG) information in line with the Global Reporting Initiative (GRI).  The Zimbabwe Stock Exchange provided clarity on how mining companies are expected to comply with sustainability reporting.

“Mining companies are expected to rely on GRI standards or any standards of their choice for their sustainability reporting since there is no specific international reporting framework or standards that the country has adopted for the extractive sector”.

Sustainability reports provide scope for CSOs and communities that host mining activities to have a fair understanding of the leakages between mining and social economic development. Communities that host mining activities are keen to know the profile of mining companies’ in public investments infrastructure and services, the proportion of mining companies’ spending on local procurement, payments that mining companies make to government, the impact of mining activities on human rights such as access to water, mining companies’ compliance with environmental laws and regulations and the resources that mining companies channel to Corporate Social Responsibility (CSR). This is part of the information that mining companies are expected to disclose as part of the sustainability reporting requirements.     

What CSOs can do with the information on sustainability reporting

There is a lot that communities and CSOs can do with sustainability reports produced by mining companies. Through the  sustainability reporting framework, communities and CSOs can engage the companies directly on any gaps, participate and validate  stakeholder engagement activities, inform regulators( Zimbabwe Stock Exchange, Zimbabwe Anti-Corruption Commission) on any misinformation, provide feedback to the standards issuers (GRI), engage the Executive and Board of Directors  on matters of concerns from the sustainability reports, analysing corporate social responsibility budgets and local procurement projects  and verify the impacts of the projects and provide feedback to the companies.

Managing expectations

Sustainability reporting by ZSE listed companies is currently at its gestation period and as such there is need for PWYP members to manage their expectations. During the Breakfast meeting, the Zimbabwe Stock Exchange (ZSE) indicated that voluntary compliance levels are still very low. ZSE further highlighted that enforcing the sustainability requirements have not been done as yet for two reasons which are compliance comes with cost,companies that are currently listed on the ZSE are burdened with survival issues and inadequate capacity to implement the requirements.

Apart from compliance issues, there is also a concern that there are very few mining companies that are listed on the Zimbabwe Stock Exchange.  Currently there are only three companies that are listed on Zimbabwe Stock Exchange and these are; RIO ZIM, Hwange Colliery Company (HCC)  and Bindura Nickel. Only one company, SEEDCO is listed at the Victoria Falls Exchange. Currently, the communities hosting mining activities stand an opportunity to benefit from sustainability reports that are produced by mining companies which are listed outside Zimbabwe. For example, the Johannesburg and Australian Stock Exchange listed ZIMPLATS produces sustainability reports which are already publicly available for use. In light of this, one may argue that even if compliance to sustainability reporting increases, the Zimbabwe Stock Exchange listing requirements might not do much in terms of addressing the transparency void that exists as long as there are few mining companies which are listed. This situation perhaps points to the need for a policy intervention.  The recent move by the Victoria Falls Stock Exchange to develop listing requirements for junior mining companies is very progressive and might make a difference  on the mining transparency landscape if ultimately, the small scale mining companies are listed on the stock exchange.


As the country still waits for the adoption of broader mining legislative and policy framework on transparency, it is important for CSOs to take advantage of every opportunity to advance transparency and accountability. The SI 134 of 2019 is one of the governance instruments that CSOs should embrace and use to the maximum as it promotes sustainable management and use of mineral revenue. There is need for CSOs to complement transparency opportunities that the governance instrument offers with disclosure frameworks that are provided for by existing laws. Such disclosure frameworks include the Audit General’s Reports on State Owned Enterprises, local authorities, and government ministries.  It is also important to highlight that the PWYP should continue to call for adoption of transparency provisions in the Mines and Mineral Amendment Bill.  There is also need for the coalition to also provide its input into the ongoing process of developing Victoria Falls listing requirements for Small Scale mining companies.         

[1] https://eiti.org

[2] http://www.zela.org/from-zimbabwe-mining-revenue-transparency-initiative-to-the-extractive-industries-transparency-initiative/

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