When a mine changes hands, the supplier evidence stays behind.

What’s changing

A steady flow of mines is moving to owners who did not build them. Large miners are selling assets to sharpen their portfolios, often to private or newly formed buyers. Others are bought out of administration or receivership and prepared for restart.

The routes differ: a carve-out from a major, a purchase after administration, a purchase out of receivership. Each new owner faces the same practical question on the first day: what do we actually know about the businesses we now pay?

The contracts move. The evidence does not.

When a mine is sold, most site contracts can be assigned or novated to the buyer. What sits behind those contracts is another matter. The seller’s supplier code, its registration checks and its screening records belong to the seller.

Large miners usually make this explicit. Their supplier codes are often published, and suppliers, including agents, contractors and consultants, agree to them when they register. That is a commitment made to the seller, under the seller’s policies. A new owner inherits the contract, not the commitment.

After an administration or receivership the picture is usually harder. Records may be incomplete, and some suppliers will have been unpaid creditors shortly before they are asked to supply again. Where a transitional services agreement keeps the seller’s systems running for a while, the gap is postponed rather than closed. It comes back when the agreement ends.

Who will ask, and when

A new owner rarely gets to work through this at its own pace. The questions tend to arrive together.

• Lenders want to know who the business pays, and whether any of those counterparties create sanctions or reputational exposure for the bank.
• Joint venture partners and customers carry their own human rights due diligence commitments, and those reach into the supply chain they share with you.
• Contractors mobilising for a restart have to clear onboarding quickly, or the restart slows down.
• Reporting law follows the new owner. In Australia, an entity with consolidated revenue of A$100m or more must publish a modern slavery statement within six months of each financial year end. In Canada, an entity that produces goods, or imports them into Canada, and meets two of three size tests (C$20m in assets, C$40m in revenue, 250 employees) must report on forced and child labour risk by 31 May each year.

Five things to check before day one

1. Which supplier contracts rely on the previous owner’s policies, codes or approvals, and what replaces them.
2. Who owns and controls your largest suppliers by spend, traced to the people at the end of the chain.
3. Whether any supplier or owner appears on a sanctions or restricted-party list in the places where you, your lenders or your partners operate.
4. Which supply categories carry the most labour risk, and what your first statement or report will need to show about them.
5. What your lenders and partners will ask to see, in what form, and by when.

None of this needs a view on geology, operations or safety. It is evidence about counterparties, and most of it can be built before completion.

A sensible first step

Start where the exposure is concentrated: the largest suppliers by spend, and every contractor being mobilised for a restart. Evidence those first and work outwards from there. It is a matter of weeks, not months, and it means your first contracts are signed on your own checks rather than someone else’s.

Counterparty Rescreen · up to 250 suppliers and contractors · 7 working days · £7,500 fixed, plus VAT. Every name screened against current UK, EU, UN and US lists, with ownership traced to 50 per cent on every match, delivered as a graded register you can hand to your lender. Wider transition work is scoped to the deal.

Working through a transition? Start a rescreen → or speak to us first.