From Carbon to Capital: The Impact of Global Climate Regulation on South Africa’s Policy and Market Dynamics in the Gold Mining Sector

Chapter 3. Methodology

This chapter outlines the research methodology employed to investigate the influence of international environmental regulation on policy development and corporate emissions performance in South Africa. The study is guided by two interrelated research questions:

• RQ1: How do international environmental regulations influence environmental policy and regulatory development in South Africa?

• RQ2: To what extent do international regulatory frameworks influence carbon emission reductions within the operations of South African gold mining companies?

The distinction between these questions lies in their level of analysis. RQ1 adopts a macro - level perspective, examining how global regulatory instruments, such as the European Union’s CBAM, shape national policy responses and regulatory alignment. In cont rast, RQ2 adopts a micro -level perspective, empirically assessing the impact of these frameworks on firm-level emissions performance using carbon intensity trends across JSE-listed gold mining companies. Despite this distinction, the questions are inherently interconnected, as domestic policy serves as a conduit through which international regulation influences corporate behaviour. Understanding the policy landscape (RQ1) is therefore essential for interpreting changes in emissions intensity at the firm level (RQ2). The research adopts a critical realist philosophical stance, recognising the existence of objective phenomena, such as emissions levels and policy instruments, while acknowledging that their interpretation is shaped by institutional and socio-political contexts (Bhaskar 2013; Sayer 2000). Epistemologically, the study is grounded in a post -positivist approach, which accepts that knowledge is fallible but can be systematically developed through empirical investigation (Guba and Lincoln 1994, pp.105–117). A deductive research approach was employed, drawing on Institutional Theory and Legitimacy Theory to formulate the proposition that firms respond to regulatory pressures in order to preserve legitimacy an d market access. This proposition was tested through the analysis of firm-level emissions data (Bryman 2012; Creswell 2014).

To operationalise this approach, a quantitative longitudinal research design was adopted. The study analysed changes in carbon emissions intensity, measured as Scope 1 and Scope 2 emissions (in tonnes of CO ₂-equivalent) divided by total revenue (in ZAR ‘000), over the period 2018 to 2024. Revenue-normalised intensity is widely regarded as a robust metric, as it accounts for firm size and economic output, thereby enabling more meaningful comparisons of environmental efficiency across firms (Delmas et al. 201 5; Busch et al. 2020; Zhou et al. 2017; Matsumura et al. 2014). This design facilitates the identification of longitudinal trends and potential responses to regulatory developments, including the anticipated implementation of CBAM. 

The unit of analysis is the firm. The sample comprises five gold mining companies listed on the Johannesburg Stock Exchange (JSE): Harmony Gold Mining Company, Gold Fields Limited, DRDGOLD Limited, Pan African Resources Plc, and Sibanye -Stillwater Limited. Although Sibanye-Stillwater operates across multiple commodities, it was included due to its significant gold operations. Refer to Table 2 in the appendices for further details on the selected firms. The sample was selected based on emissions intensity, o perational scale, consistent disclosure of emissions and revenue data, and exposure to both domestic and international regulatory environments (Sullivan and Mackenzie 2017).

Data were obtained from publicly available sources, including integrated annual reports, sustainability reports, and JSE filings. Only firms with complete Scope 1 and Scope 2 emissions and revenue disclosures for all years were included to ensure data cons istency and integrity. The use of secondary data is appropriate for analysing firm -level ESG performance over time and aligns with established research practice (Saunders et al. 2019). A purposive sampling approach was employed to select information -rich cases relevant to the research objectives. While this limits generalisability, it enhances internal validity by controlling for variation in industry characteristics, regulatory exposure , and emissions profiles (Bryman 2012).

Data analysis was conducted using Microsoft Excel. Carbon intensity was calculated annually for each firm, and sector-level averages were derived by aggregating emissions and revenue across the sample. Line graphs were used to visualise changes in carbon intensity over time, enabling cross -firm comparison and identification of significant trends (Zhou et al. 2017; Saunders et al. 2019). Excel was deemed appropriate given the relatively small sample size and the descriptive, trend -based focus of the analysis . Regression analysis was not undertaken, as the study aims to identify patterns rather than establish causal relationships. While the analysis identifies strong temporal alignment between regulatory developments and emissions trends, the study does not establish causality but rather interprets directional relationships consistent with institutional and signalling dynamics. To ensure validity and reliability, a consistent methodology for calculating carbon intensity was applied across all firms and time per iods. The focus on a single sector enhances internal validity by reducing heterogeneity. While external validity is limited, the sector -specific design improves contextual relevance. Reliability was strengthened through the use of standardised, independently verified corporate reports prepared in accordance with international frameworks such as GRI and Integrated Reporting () (Junior et al. 2013). All methodological procedures were documented to ensure transparency and replicability.

Although the study relies exclusively on publicly available data, ethical considerations remain important. No human participants were involved, and therefore ethical clearance was not required. The research adheres to principles of academic integrity, incl uding accurate citation, transparency in data handling, and avoidance of selective reporting (Broom 2006; Resnik 2007). Firms with incomplete or inconsistent data were excluded to minimise bias, and a neutral analytical stance was maintained throughout, gi ven the sensitivity of ESG - related disclosures in financial and regulatory contexts (Bell and Bryman 2007).

Several limitations must be acknowledged. The analysis is restricted to Scope 1 and Scope 2 emissions, as Scope 3 data were excluded due to inconsistent disclosure. This is a notable limitation, as Scope 3 emissions are material in the mining sector, particularly in downstream processes such as refining and transport. The reliance on secondary data introduces potential reporting inconsistencies (Simnett et al. 2009). The small, purposively selected sample limits the generalisability of findings beyond the South African gold mining sector. Given the limited sample size and sector -specific focus, regression analysis was not appropriate; instead, a descriptive longitudinal approach was adopted to identify directional trends aligned with regulatory developments. In addition, revenue -based carbon intensity measures may be influenced by external economic factors, including commodity price cycles and macroeconomic shocks such as COVID-19. Finally, the absence of qualitative data limits insight into firm-level strategic and institutional responses to regulatory pressures.

Chapter 4. Results and Discussion

This chapter presents the empirical findings of the study, structured around the two research questions. It analyses trends in environmental policy development and corporate emissions performance within South Africa’s gold mining sector, linking observed o utcomes to international regulatory drivers and relevant theoretical frameworks. The analysis adopts both a macro-level perspective, examining the influence of international environmental regulation on domestic policy development, and a micro -level perspec tive, assessing firm -level emissions performance through carbon intensity trends. By integrating these perspectives, the chapter provides a comprehensive evaluation of how global regulatory pressures translate into measurable corporate outcomes within a ca rbon-intensive sector. Beyond environmental performance, the findings are interpreted in relation to broader financial and strategic implications. In particular, the analysis considers how regulatory alignment influences firm -level positioning in capital m arkets, including investor perceptions, competitiveness, and access to capital. This approach enables the study to extend beyond descriptive analysis and provide a theoretically grounded interpretation of the relationship between environmental regulation, corporate behaviour, and financial outcomes.

Research Question 1: How do international environmental regulations influence environmental policy and regulatory development in South Africa?

International environmental regulation has emerged as a central driver of South Africa’s domestic policy and regulatory evolution over the past two decades. As a carbon -intensive economy integrated into global trade systems, South Africa is increasingly sh aped by transnational frameworks such as the Paris Agreement, the European Union’s Carbon Border Adjustment Mechanism (CBAM), and global ESG disclosure standards. These frameworks exert a combination of coercive, normative, and mimetic pressures (DiMaggio and Powell 1983), compelling alignment between domestic environmental governance and global climate policy norms. Importantly, these pressures extend beyond regulatory compliance to influence how domestic firms are positioned within global capital markets. Climate policy alignment is increasingly associated with reduced investment risk and improved access to capital, reinforcing the link between environmental regulation and financial outcomes (Dhaliwal et al. 2011; Ameli et al. 2021). This dynamic reflects the combine d explanatory power of institutional theory (Scott 2014) and signalling theory (Spence 1973; Connelly et al. 2011), where regulatory alignment functions both as a compliance mechanism and as a signal of credibility to external stakeholders.

South Africa’s structural dependence on coal-based electricity, which accounts for over 80% of national power generation (Swilling et al. 2015), intensifies its exposure to international climate regulation. Within this context, the gold mining sector contr ibutes significantly to national greenhouse gas emissions, particularly through Scope 1 and Scope 2 emissions (Azapagic 2004; Hanto et al. 2021). This creates a dual dynamic: heightened vulnerability to carbon-related trade measures, such as CBAM, and increased incentives to align with global climate frameworks to maintain competitiveness and attract investment (Vorster et al. 2011; Zhang and Sovacool 2024; Death 2024). The Carbon Tax Act (No. 15 of 2019) provides a clear illustration of how international regulatory pressures translate into domestic policy. Its design reflects alignment with global carbon pricing principles and multilateral policy guidance (IMF 2023; Baker 2022). Three primary channels of international influence are evident. First, South Africa’s commitments under the Paris Agreement created a diplomatic and reputational imperative to introduce a carbon pricing mechanism (Averchenkova et al. 2019). Second, the anticipated implementation of CBAM provided an economic rationale to internalise ca rbon costs pre-emptively and protect export competitiveness. Third, engagement with international financial institutions, including the IMF and World Bank, influenced the phased design of the policy through technical guidance and transitional allowances (G ustafsson 2021). The phased implementation of the Carbon Tax reflects the need to balance environmental objectives with economic constraints. Phase 1 (2019 –2022) introduced substantial allowances for emissions -intensive sectors, while Phase 2 (2023 –2030) progressively tightens compliance thresholds. This trajectory is consistent with coercive institutional pressures, as domestic policy evolves in response to global regulatory expectations (DiMaggio and Powell 1983; Digitemie and Ekemezie 2024). The Johannes burg Stock Exchange’s Sustainability and Climate Disclosure Guidance further illustrates the influence of international regulation through market -based governance mechanisms (JSE 2022). By aligning domestic reporting practices with global frameworks such as TCFD and IFRS S1 and S2, these guidelines promote policy convergence and enhance transparency (Laine et al. 2021). They also strengthen the signalling function of ESG disclosures, enabling firms to communicate climate risk management capabilities and reduce information asymmetry (Connelly et al. 2011; Dhaliwal et al. 2011). 

CBAM represents a structural shift in climate governance by embedding carbon considerations directly into international trade systems (European Commission 2023). Although raw gold exports are not currently included in its initial scope, indirect exposure through processing and supply chain emissions presents a material risk to South Africa’s mining sector. This has already influenced national planning frameworks, including the Just Energy Transition Investment Plan, which identifies carbon-related trade risks as a strategic priority (Cosbey et al. 2021). The influence of international regulation can be effectively conceptualised through the Multi -Level Governance framework (Hooghe and Marks 2003; Meadowcroft 2002). At the global level, transnational frameworks establish regulatory expectations. At the nati onal level, policies such as the Carbon Tax Act translate these expectations into enforceable measures. At the sectoral level, institutions such as the JSE adapt global standards to local contexts. At the co rporate level, firms respond through ESG disclosure, operational adjustments, and investment decisions. Across these layers, coercive, normative, and mimetic pressures interact to shape policy and behaviour. The combined effect of these pressures is reflected in measurable corporate outcomes. Carbon intensity in the gold mining sector declined from 0.0876 tCO ₂e/ZAR revenue in 2018 to 0.0464 in 2024, representing approximately a 47% reduction. This suggests that international regulatory pressures, mediated t hrough domestic policy and market mechanisms, have contributed to tangible emissions reductions. Firms have also increased alignment with global disclosure frameworks and expanded investments in renewable energy, energy efficiency, and process optimisation (Qu, Zhang, et al. 2023).

Despite these advances, challenges remain. Policy fragmentation and overlapping regulatory frameworks create compliance complexity and reporting fatigue (Laine et al. 2021). Equity concerns also arise, as mechanisms such as CBAM may disproportionately impa ct developing economies (Rumble and Gilder 2024). In addition, implementation gaps persist, particularly in relation to Scope 3 emissions (Downie and Stubbs 2012), and the risk of symbolic compliance remains significant in high-visibility sectors (Clarkson et al. 2008; Haque and Ntim 2020). Overall, the findings demonstrate that international environmental regulation has been a decisive driver of South Africa’s environmental policy evolution. Global frameworks have shaped domestic policy instruments, corporate disclosure practices, and emissions trajectories, embedding South Africa’s environmental governance within a broader transnational regulatory system. This supports the explanatory value of institutional theory and multi-level governance in understanding how global regulat ory pressures translate into national policy and firm-level outcomes.

Research Question 2: To what extent does international regulatory frameworks influence carbon emission reductions within the operations of South African gold mining companies?

This research question evaluates the extent to which international regulatory frameworks have driven measurable carbon emission reductions in South Africa’s gold mining sector between 2018 and 2024. While Research Question 1 examined the influence of globa l climate governance on domestic policy formation, this section focuses on firm -level outcomes, linking carbon intensity trends to a timeline of key international and domestic regulatory interventions. The analysis integrates Institutional Theory to explai n coercive, normative, and mimetic pressures (DiMaggio and Powell 1983; Scott 2014), Signalling Theory to assess the role of ESG disclosures (Spence 1973; Connelly et al. 2011), and Legitimacy Theory to interpret environmental action as a mechanism for sus taining a social licence to operate (Suchman 1995; Deegan 2002). Between 2018 and 2024, the South African gold mining sector operated within a progressively tightening regulatory environment shaped by international climate governance and domestic policy translation. Over this period, aggregate carbon intensity declined from 0.0876 tCO₂e/ZAR revenue to 0.0464, representing an approximate 47% reduction (Table 1; Figure 1). This trajectory can be divided into two distinct phases aligned with regulatory developments.

Table 1 Source: Author’s calculations based on company reports and ESG GPS™ Data

Figure 1 Source: Author’s calculations based on company reports and ESG GPS™ Data

Phase One: Rapid Decline (2019-2021)

The most significant reduction occurred between 2019 and 2021, coinciding with the implementation of the Carbon Tax Act (2019) and the announcement of the EU’s CBAM (2021). These measures functioned as coercive pressures (DiMaggio and Powell 1983), introducing both direct cost implications and anticipated trade compliance risks. Firms responded through operational efficiency improvements, process optimisation, and limited fuel-switching, reducing Scope 1 and Scope 2 emissions. From a financial perspective, this phase reflects the initial pricing of transition risk, where regulatory signals increased the cost of carbon-intensive operations and influenced capital allocation decisions.

Phase Two: Moderate Decline/Plateau (2022–2024)

From 2022 onwards, the rate of emissions reduction moderated. This period coincides with the introduction of the JSE’s Sustainability and Climate Disclosure Guidance, which shifted the emphasis from direct regulatory pressure to normative and mimetic drive rs (Laine et al. 2021). During this phase, emissions reductions were increasingly driven by investor expectations, reputational considerations, and disclosure alignment rather than direct cost pressures. This aligns with Signalling Theory, where firms use ESG disclosures to communicate credibility and long -term strategic positioning (Spence 1973; Connelly et al. 2011). Further improvements required more capital-intensive interventions, including on-site renewable energy investments, advanced ventilation systems, and processing upgrades. Firm-level variation highlights differentiated responses:

• Gold Fields emerged as a leader, combining early TCFD -aligned disclosure with significant renewable energy investment.

• Harmony Gold and Sibanye -Stillwater demonstrated steady, incremental improvements through operational efficiency.

• DRDGOLD showed accelerated improvement post -2021, likely reflecting CBAM anticipation and increased investor scrutiny. 

Common strategies across firms included solar PV deployment, energy efficiency retrofits, and process optimisation, all contributing to reduced electricity intensity per unit of output.

Theoretical Interpretation of Emissions Trends

The observed emissions trajectory reflects the combined influence of institutional, signalling, and legitimacy dynamics. Coercive pressures were most pronounced during the 2019 –2021 period. The Carbon Tax Act imposed direct financial costs, while CBAM introduced credible future trade risks, jointly driving early emissions reductions. From 2022 onwards, normative pressures gained prominence as global investors increasingly required alignment with disclosure frameworks such as TCFD and ISSB. These expectation s were institutionalised through the JSE’s disclosure guidance, embedding global norms into domestic practice. Mimetic pressures further reinforced convergence, as firms adopted strategies demonstrated by industry leaders to maintain competitiveness and legitimacy.

Signalling Theory explains the increasing importance of ESG disclosures as firms sought to reduce information asymmetry and demonstrate climate readiness (Spence 1973; Connelly et al. 2011). High -quality disclosures, particularly those supported by verifia ble emissions data, enhanced credibility and reduced perceptions of greenwashing (Hawn and Ioannou 2016). Legitimacy Theory provides additional context, highlighting how emissions reductions and renewable energy investments function as legitimacy -enhancing strategies in a highly scrutinised sector (Suchman 1995; Deegan 2002). Firms operate under both domestic and international scrutiny, where failure to act risks reputational damage, reduced investment, and exclusion from export markets (Aguilera et al. 2018). Taken together, these dynamics explain the observed pattern of emissions reduction. Coercive pressures initiated rapid declines, while normative expectations and signalling mechanisms sustained, but did not accelerate, further reductions. It is reasonable to infer that a substantial share of the reductions between 2019 and 2021 was driven by international regulatory pressures, mediated through domestic policy instruments. However, the slower rate of decline after 2022 highlights the limitations of disclosure-based governance in the absence of strong coercive mechanisms (Laine et al. 2021).

Contextual Constraints and External Factors

Several contextual factors influenced emissions trends. Commodity price fluctuations affected production volumes and emissions intensity. COVID -19 temporarily reduced operations, contributing to short -term emissions declines unrelated to regulatory drivers . More fundamentally, South Africa’s reliance on coal-based electricity (Swilling et al. 2015) continues to constrain decarbonisation efforts, limiting firms’ ability to achieve further reductions despite regulatory pressure. Data limitations, particularly in Scope 3 emissions (Downie and Stubbs 2012), and the risk of symbolic compliance (Clarkson et al. 2008; Haque and Ntim 2020) further complicate interpretation.

Capital Market Implications

The emissions trajectory has important implications for capital markets. Firms demonstrating sustained reductions in carbon intensity and alignment with ESG disclosure frameworks are likely to experience improved investor confidence and reduced perceived r isk. Empirical evidence suggests that such firms benefit from lower costs of capital and more favourable valuation outcomes (Dhaliwal et al. 2011; Fatemi et al. 2018; Khan et al. 2016). Conversely, firms with higher carbon intensity or slower adaptation face in creased transition risk, which may manifest in higher financing costs, reduced investment attractiveness, and potential exclusion from climate-sensitive portfolios (Ameli et al. 2021). In this context, carbon intensity functions not only as an environmenta l metric but also as a financial signal influencing firm valuation and competitiveness.

Synthesis

Overall, coercive international regulatory frameworks were the primary drivers of emissions reductions during the 2019–2021 period. However, the transition from regulatory compliance to market -driven pressures reflects a broader structural shift in which e nvironmental performance is increasingly integrated into financial decision -making and capital allocation. While disclosure -based frameworks have strengthened transparency and legitimacy, sustained decarbonisation will depend on structural energy reform an d the ability of firms to align operational strategies with both regulatory expectations and capital market demands. The findings of this study extend beyond the South African context and offer broader implications for emerging market economies characterised by carbon -intensive growth models and structural energy constraints. South Africa’s experience illustrates how international climate regulation can act as a catalytic force in shaping both domestic policy frameworks and firm-level behavioural change, even in environments with limited institutional capacity and infrastructure challenges. As global mechanisms such as carbon pricing, disclosure standards, and trade -related instruments like the CBAM become increasingly embedded within financial and trade sys tems, emerging markets are likely to face similar convergence pressures. In this context, South Africa serves not merely as a case study, but as a representative template for carbon -constrained economies navigating the transition to low-carbon development pathways. The study highlights that while regulatory alignment can drive measurable improvements in emissions performance, the pace and extent of decarbonisation remain contingent on underlying structural factors, particularly energy system dependence and access to capital. For policymakers and market participants across emerging economies, the findings underscore the importance of integrating climate policy with financial market development and energy transition strategies to ensure both environmental sustainability and economic competitiveness in a rapidly evolving global regulatory landscape.

Chapter 5. Conclusion

This study examined how international environmental regulation shapes both environmental policy development and corporate emissions performance in South Africa, with a specific focus on the gold mining sector. Drawing on Institutional Theory, Signalling Theory, and MultiLevel Governance, the analysis provides both empirical and conceptual insights into how global climate governance frameworks translate into domestic policy responses and firm-level behavioural change. The findings confirm that international environmental regulation has been a key driver of South Africa’s environmental policy trajectory, with instruments such as the Paris Agreement, the EU’s CBAM, and global ESG disclosure standards shaping domestic responses, including the Carbon Tax Act (20 19) and the Johannesburg Stock Exchange’s Sustainability and Climate Disclosure Guidance (2022). This reflects an increasing alignment of national policy frameworks with transnational regulatory systems. At the firm level, the study identifies a significan t reduction in carbon emission intensity within the South African gold mining sector, with an approximate 47% decline observed between 2018 and 2024. The most substantial reductions occurred during the 2019–2021 period, coinciding with the introduction of carbon pricing mechanisms and the anticipation of trade-related regulatory pressures. This suggests that early -stage decarbonisation is strongly influenced by coercive regulatory drivers. In contrast, the post -2022 period reflects a more gradual trajectory , shaped by disclosure-based frameworks and market expectations, consistent with signalling and legitimacy dynamics. Importantly, the findings extend beyond environmental performance to demonstrate that carbon intensity and ESG disclosure increasingly function as material financial signals within capital markets. Firms that demonstrate credible decarbonisation strategies and transparent ESG disclosures are associated with improved investor confidence, reduced information asymmetry, and more favourable capit al allocation outcomes. Conversely, firms that are slower to adapt face elevated transition risks, including increased costs of capital and reduced competitiveness in both financial and trade environments.

The study contributes to the literature by bridging environmental policy analysis with financial market implications in an emerging market context. It highlights how global climate governance frameworks interact with local structural constraints particularly South Africa’s dependence on coal -based energy systems to shape both environmental outcomes and economic performance. These structural realities limit the pace of decarbonisation and underscore the tension between global climate expectations and domesti c development priorities. From a policy perspective, the findings suggest that effective climate governance in emerging markets requires a coordinated approach that integrates regulatory instruments, market-based mechanisms, and energy system transformation. Carbon pricing, disclos ure frameworks, and trade -related policies must be designed to support both environmental objectives and economic resilience, particularly in carbon-intensive sectors central to national growth. In conclusion, the findings reinforce the central premise of this study: the transition to a low-carbon economy is not only an environmental imperative but a fundamental financial and strategic transformation. Climate regulation is increasingly shaping how firms operate, compete, and access capital. The South African gold mining sector illustrates how environmental policy, corporate strategy, and capital market dynamics intersect, demonstrating that decarbonisation has become a critical determinant of risk, value, competitiveness, and long-term capital access in the global economy.

References

1. Aguilera, R.V., Judge, W.Q. and Terjesen, S.A. (2018). Corporate Governance Deviance. Academy of Management Review, 43(1), pp.87–109.

2. Ameli, N. et al. (2021). Higher cost of finance exacerbates a climate investment trap in developing economies. Nature Communications, 12(1). [online]. Available from: https://www.nature.com/articles/s41467-021-24305-3.

3. Averchenkova, A., Gannon, K. and Curran, P. (2019). Policy brief Governance of climate change policy: A case study of South Africa Headline issues. [online]. Available from: https://www.lse.ac.uk/granthaminstitute/wpcontent/uploads/2019/06/GRI_Governance-of-climate-change-policy_SAcasestudy_policy-brief_8pp.pdf.

4. Azapagic, A. (2004). Developing a framework for sustainable development indicators for the mining and minerals industry. Journal of Cleaner Production , 12(6), pp.639–662.

5. Baker, L. (2022). The Political Economy of South Africa’s Carbon Tax.

6. Baker, L. and Phillips, J. (2018). Tensions in the transition: The politics of electricity distribution in South Africa. Environment and Planning C: Politics and Space, 37(1), pp.177–196.

7. Bell, E. and Bryman, A. (2007). The Ethics of Management Research: an Exploratory Content Analysis. British Journal of Management, 18(1), pp.63–77.

8. Bhaskar, R. (2013). A Realist Theory of Science. London: Routledge.

9. Biermann, F. et al. (2009). The Fragmentation of Global Governance Architectures: A Framework for Analysis. Global Environmental Politics, 9(4), pp.14–40.

10. Bitektine, A. and Haack, P. (2015). The ‘Macro’ and the ‘Micro’ of Legitimacy: Toward a Multilevel Theory of the Legitimacy Process. Academy of Management Review, 40(1), pp.49–75.

11. Black, S. et al. (2022). A Framework for Comparing Climate Mitigation Effort Across Countries. Washington DC: International Monetary Fund.

12. Bodansky, D., Brunnée, J. and Rajamani, L. (2017). International Climate Change Law. Oxford University Press.

13. Börzel, T.A. and Risse, T. (2010). Governance without a state: Can it work? Regulation & Governance, 4(2), pp.113–134.

14. Broom, A. (2006). Ethical Issues in Social Research. Complementary Therapies in

Medicine, 14(2), pp.151–156. [online]. Available from: https://www.sciencedirect.com/science/article/pii/S0965229905001445.

15. Bryman, A. (2012). Social research methods . 4th ed. Oxford: Oxford University Press.

16. Bulkeley, H. and Betsill, M. (2005). Rethinking Sustainable Cities: Multilevel Governance and the ‘Urban’ Politics of Climate Change. Environmental Politics, 14(1), pp.42–63. [online]. Available from: https://www.tandfonline.com/doi/abs/10.1080/0964401042000310178.

17. Busch, T., Johnson, M. and Pioch, T. (2020). Corporate carbon performance data: Quo vadis? Journal of Industrial Ecology, 26(1), pp.350–363.

18. Campbell, R. (2025). Mining still major contributor to South African economy. Mining Weekly. [online]. Available from: https://www.miningweekly.com/article/mining-still-major-contributor-tosouthafrican-economy-2025-02-03.

19. Clarkson, P.M. et al. (2008). Revisiting the relation between environmental performance and environmental disclosure: An empirical analysis. Accounting, Organizations and Society, 33(4-5), pp.303–327.

20. Clora, F., Yu, W. and Corong, E. (2023). Alternative carbon border adjustment mechanisms in the European Union and international responses: Aggregate and within-coalition results. Energy Policy, 174, p.113454.

21. Cole, M.J. (2023). ESG risks to global platinum supply: A case study of Mogalakwena Mine, South Africa. Resources Policy, 85, p.104054. [online]. Available from: https://www.sciencedirect.com/science/article/pii/S0301420723007651.

22. Connelly, B.L. et al. (2011). Signaling Theory: a Review and Assessment. Journal of Management, 37(1), pp.39–67.

23. Corvino, I. (2025). Environmental Sustainability: Ideas about the Future, Expectations and Justice. In Extending the Idea of Environment: New Perspectives and Tools for a new Knowledge. Vernon Press.

24. Cosbey, A., Mehling, M. and Marcu, A. (2021). CBAM for the EU: A Policy Proposal. papers.ssrn.com. [online]. Available from: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3838167.

25. Creswell, J. (2014). Research design: Qualitative, quantitative, and Mixed Methods Approaches. 4th ed. London: Sage Publications Ltd.

26. Creswell, J.W. and Creswell, J.D. (2022). Research design: Qualitative, quantitative & mixed methods approaches. 6th ed. Los Angeles: Sage.

27. Dhaliwal, D.S., Li, O.Z., Tsang, A. and Yang, Y.G. (2011). Voluntary nonfinancial disclosure and the cost of equity capital: The initiation of corporate social responsibility reporting. The Accounting Review, 86(1), pp.59–100.

28. Death, C. (2024). Narrating transitions to low carbon futures: the role of long -term strategies (LTS) in fossil fuel producing emerging economies. New political economy, 29(4), pp.1–18.

29. Deegan, C. (2002). The legitimising effect of social and environmental disclosures – a theoretical foundation. Accounting, Auditing & Accountability Journal , 15(3), pp.282–311.

30. Delmas, M.A., Nairn-Birch, N. and Lim, J. (2015). Dynamics of Environmental and Financial Performance. Organization & Environment, 28(4), pp.374–393.

31. Dhaliwal, D.S. et al. (2011). Voluntary Nonfinancial Disclosure and the Cost of Equity capital: the Initiation of Corporate Social Responsibility Reporting. The Accounting Review, 86(1), pp.59–100.

32. Digitemie, W.N. and Ekemezie, I.O. (2024). Assessing the role of carbon pricing in global climate change mitigation strategies. Magna Scientia Advanced Research and Reviews, 10(2), pp.022–031. [online]. Available from: https://magnascientiapub.com/journals/msarr/content/assessing-rolecarbonpricing-global-climate-change-mitigation-strategies.

33. DiMaggio, P.J. and Powell, W.W. (1983). The Iron Cage Revisited: Institutional Isomorphism and Collective Rationality in Organizational Fields. American Sociological Review, 48(2), pp.147–160.

34. Downie, J. and Stubbs, W. (2012). Corporate Carbon Strategies and Greenhouse Gas Emission Assessments: The Implications of Scope 3 Emission Factor Selection. Business Strategy and the Environment, 21(6), pp.412–422.

35. DRD Gold. (2023). Reports and results - DRDGOLD. Drdgold.com. [online]. Available from: https://www.drdgold.com/investors/reports-and-results#ars2024.

36. Dryzek, J.S. et al. (2003). Green States and Social Movements. OUP Oxford.

37. Erdogdu, E. (2025). The Carbon Border Adjustment Mechanism: Opportunities and Challenges for Non-EU Countries. WIREs Energy and Environment, 14(1).

38. European Commission. (2023). Carbon Border Adjustment Mechanism (CBAM). trade.ec.europa.eu. [online]. Available from: https://trade.ec.europa.eu/access - tomarkets/en/news/carbon-border-adjustment-mechanism-cbam.

39. European Commission. (2021). Carbon Border Adjustment Mechanism: Questions and Answers. European Commission . [online]. Available from: https://ec.europa.eu/commission/presscorner/detail/en/qanda_21_3661.

40. Evans, D. et al. (2023). Environmental, social and corporate governance (ESG) on the financial performance of listed mining firms in South Africa. International Journal of Business and Economic Sciences Applied Research (IJBESAR), 16(2), pp.42–52. [online]. Available from: https://www.econstor.eu/handle/10419/289526 [Accessed May 17, 2024].

41. Fatemi, A., Fooladi, I. and Tehranian, H. (2018). Valuation effects of corporate social responsibility. Journal of Banking & Finance, 87, pp.53–63.

42. Flues, F. and Dender, K. van. (2020). Carbon pricing design: Effectiveness, efficiency and feasibility: An investment perspective. www.oecd-ilibrary.org. [online]. Available from: https://www.oecd - ilibrary.org/docserver/91ad6a1een.pdf?expires=1634480700&id=id&accname=gu est&checksum=C45C0B77513 34B25362CBE7AFDAFF8A6.

43. Galiffa, C. and Bercero, I.G. (2022). How WTO -Consistent Tools can Ensure the Decarbonization of Emission -Intensive Industrial Sectors. AJIL Unbound , 116, pp.196–201.

44. Gibbs, D. and Jonas, A.E.G. (2000). Governance and regulation in local environmental policy: the utility of a regime approach. Geoforum, 31(3), pp.299 – 313.

45. Gold Fields. (2024). Integrated annual reports | INVESTORS AND MEDIA | Gold Fields. www.goldfields.com. [online]. Available from: https://www.goldfields.com/integrated-annual-reports.php.

46. Guba, E.G. and Lincoln, Y.S. (1994). Handbook of Qualitative Research. Thousand Oaks: Sage Publications.

47. Gustafsson, M. (2021). ISER Working Paper Series Working Paper Number 1/2021 Carbon taxes and the attainment of emissions reductions targets in South Africa A critical stocktaking of recent analyses and policies . [online]. Available from: https://www.ru.ac.za/media/rhodesuniversity/content/iser/documents/Carbon_tax _in_South_Africa_-_ISER_WP_-_August_2021-Gustafsson_%283%29.pdf [Accessed July 23, 2025].

48. Hanto, J. et al. (2021). Effects of decarbonization on the energy system and related employment effects in South Africa. Environmental Science & Policy, 124, pp.73–

84. [online]. Available from: https://www.sciencedirect.com/science/article/pii/S1462901121001532#bib0380.

49. Haque, F. and Ntim, C.G. (2020). Executive Compensation, Sustainable Compensation Policy, Carbon Performance and Market Value. British Journal of Management, 31(3), pp.525–546.

50. Harmony Gold Mining. (2025). Investor Relations. Harmony.co.za. [online]. Available from: https://www.harmony.co.za/investors/ [Accessed August 24, 2025].

51. Hawn, O. and Ioannou, I. (2016). Mind the gap: The interplay between external and internal actions in the case of corporate social responsibility. Strategic Management Journal, 37(13), pp.2569–2588.

52. Hooghe, L. and Marks, G. (2003). Unraveling the Central State, but How? Types of Multi -level Governance. American Political Science Review , 97(02), pp.233 – 243.

53. IMF. (2023). South Africa. International Monetary Fund.

54. Ishtiaq, M. (2019). Creswell, J. W. (2014). research design: Qualitative, quantitative and mixed methods approaches (4th ed.). thousand oaks, CA: Sage. English Language Teaching, 12(5), p.40. [online]. Available from: https://www.researchgate.net/publication/332246566_Book_Review_Creswell_J_ W_2014_Research_Design_Qualitative_Quantitative_and_Mixed_Methods_Appr oaches_4th_ed_Thousand_Oaks_CA_Sage.

55. Jänicke, M. (2005). Trend-setters in environmental policy: the character and role of pioneer countries. European Environment, 15(2), pp.129–142.

56. Jordan, A. et al. (2018). Governing Climate Change. A. Jordan et al., eds. Cambridge University Press. [online]. Available from:

https://www.cambridge.org/core/books/governingclimatechange/033486F6DA7F2CD1F8F3D6011B17909B.

57. Jordan, A., Wurzel, R.K.W. and Zito, A.R. (2013). Still the century of ‘new’ environmental policy instruments? Exploring patterns of innovation and continuity. Environmental Politics, 22(1), pp.155–173.

58. JSE. (2021). JSE LIMITED SUSTAINABILITY DISCLOSURE GUIDANCE DRAFT FOR EXTERNAL COMMENT Leading the way for a better tomorrow JSE Sustainability Disclosure Guidance. [online]. Available from: https://cisp.cachefly.net/assets/articles/attachments/86997_jse_sustainability_dis closure_guidance_1.pdf?utm_source=chatgpt.com [Accessed July 23, 2025].

59. JSE. (2022). Sustainability and Climate Disclosure Guidance. [online]. Available from: https://group.jse.co.za/sustainability/climate - disclosureguidance?utm_source=chatgpt.com [Accessed July 22, 2025].

60. Junior, R.M., Best, P.J. and Cotter, J. (2013). Sustainability Reporting and Assurance: A Historical Analysis on a World -Wide Phenomenon. Journal of Business Ethics, 120(1), pp.1–11.

61. Kabundu, E., Mbanga, S. and Makasa, P. (2022). The 2019 carbon tax in South Africa: effects on relative cost of building materials, welfare, emissions, and energy consumption for households. Acta Structilia, 29(2), pp.150–189. [online]. Available from: http://www.scielo.org.za/scielo.php?script=sci_arttext&pid=S24150487202200020 0006 [Accessed June 13, 2023].

62. Krüger, P. (2015). Corporate goodness and shareholder wealth. Journal of Financial Economics, 115(2), pp.304–329.

63. Khan, M., Serafeim, G. and Yoon, A. (2016). Corporate sustainability: First evidence on materiality. The Accounting Review, 91(6), pp.1697–1724.

64. Laine, M., Tregidga, H. and Unerman, J. (2021). Sustainability Accounting and Accountability. Third Edition. | New York : Routledge, 2021. | Revised edition of Sustainability accounting and accountability, 2014.: Routledge.

65. Lanis, R. and Richardson, G. (2012). Corporate social responsibility and tax aggressiveness: a test of legitimacy theory. Accounting, Auditing & Accountability Journal, 26(1), pp.75–100.

66. Magacho, G. et al. (2023). Macroeconomic exposure of developing economies to low-carbon transition. World Development, 167, p.106231. [online]. Available from: https://www.sciencedirect.com/science/article/pii/S0305750X23000499.

67. Masondo, Z.N. and Nwosimiri, O. (2023). Environmental Pollution and Climate Change: An Ethical Evaluation of the Carbon Tax Policy in South Africa. Journal of Humanities, 31(1), pp.113–133. [online]. Available from: https://www.ajol.info/index.php/jh/article/view/251341.

68. Matsumura, E.M., Vera -Munoz, S.C. and Prakash, R. (2014). Voluntary Disclosures and the Firm -Value Effects of Carbon Emissions. SSRN Electronic Journal, 89(2).

69. Meadowcroft, J. (2002). Politics and scale: some implications for environmental governance. Landscape and Urban Planning, 61(2-4), pp.169–179.

70. Mehling, M. (2024). Harvard Project on Climate Agreements.

71. Mehling, M.A., Metcalf, G.E. and Stavins, R.N. (2018). Linking Heterogenous Climate Policies (Consistent with the Paris Agreement). Environmental Law, 48(4), pp.647–698.

72. Moncks, T. et al. (2023). An Untapped Goldmine: Opportunities for South African Mining. BCG Global. [online]. Available from: https://www.bcg.com/publications/2023/an-untapped-goldmine-opportunitiesforsouth-african-mining.

73. Muzanya, S. (2022). ESG and corporate financial performance: evidence from JSE listed firms. Uct.ac.za. [online]. Available from: https://open.uct.ac.za/items/ecaf0711-ab85-472c-a705-2de28a5ef471 [Accessed October 12, 2024].

74. National Treasury. (2022). 2022 Budget Review: Chapter 4 – Carbon Tax. www.treasury.gov.za. [online]. Available from: https://www.treasury.gov.za/documents/national%20budget/2022/review/Chapter %204.pdf.

75. Pan African Resources. (2024). Financial Reports. PAN AFRICAN RESOURCES. [online]. Available from: https://www.panafricanresources.com/investors/financialreports/.

76. Prag, A. (2017). Trade and Climate Change. In B. Shepherd, ed. Win-Win : How International Trade Can Help Meet the Sustainable Development Goals . China: Asian Development Bank Institute. [online]. Available from: https://worlddidac.org/wp-content/uploads/2017/09/adbi-win-win-howinternationaltrade-can-help-meet-sdgs.pdf#page=271.

77. Qu, H. et al. (2023). South Africa Carbon Pricing and Climate Mitigation Policy . International Monetary Fund.

78. Qu, K. et al. (2023). Examining the Impact of China’s New Environmental Protection Law on Enterprise Productivity and Sustainable Development. Journal of the Knowledge Economy, 15.

79. Resnik, D. (2007). What Is Ethics in Research & Why Is It Important. ResearchGate. [online]. Available from: https://www.researchgate.net/publication/242492652_What_is_Ethics_in_Resear ch_Why_Is_It_Important.

80. Richards, K. and Giovanni, E. (2022). Case Study: South Africa Carbon Tax . [online]. Available from: https://gnarlytreesustainability.com/wpcontent/uploads/2022/07/Case-4_-SouthAfrica_revised.pdf.

81. Ross, S.A. (1977). The Determination of Financial Structure: The IncentiveSignalling Approach. The Bell Journal of Economics, 8(1), pp.23–40.

82. Rumble, O. and Gilder, A. (2024). The Impact of the CBAM on African Economies and the Role of the AfCFTA. South African Institute of International Affairs. [online]. Available from: https://www.jstor.org/stable/resrep67544.

83. Saunders, M., Lewis, P. and Thornhill, A. (2019). Research Methods for Business Students. 9th ed. Pearson.

84. Sayer, A. (2000). Realism and Social Science. London: Sage.

85. Scott, W.R. (2014). Institutions and Organizations : Ideas, Interests and Identities. 4th ed. Thousand Oaks, California: Sage Publications, Inc.

86. Sepetis, A. (2020). A Holistic Sustainable Finance Model for the Sustainable Capital Market. Journal of Financial Risk Management, 09(02), pp.99–125.

87. Sesele, M. (2024). The Impact of South Africa’s Carbon Tax Policy on Carbon Leakages on its Top Five African Trading Partners. International Journal of Research and Innovation in Social Science, VIII(II), pp.1960–1971.

88. Sibanye Stillwater. (2025). Annual Reports 2024 Archive. Sibanyestillwater.com. [online]. Available from: https://www.sibanyestillwater.com/newsinvestors/reports/annual/2024/ [Accessed August 24, 2025].

89. Simnett, R., Vanstraelen, A. and Chua, W.F. (2009). Assurance on Sustainability Reports: An International Comparison. The Accounting Review , 84(3), pp.937 – 967.

90. Spence, M. (1973). Job Market Signaling. The Quarterly Journal of Economics, 87(3), pp.355–374. [online]. Available from: https://www.jstor.org/stable/1882010?seq=1.

91. Suchman, M.C. (1995). Managing Legitimacy: Strategic and Institutional Approaches. The Academy of Management Review, 20(3), pp.571–610.

92. Sullivan, R. and Mackenzie, C. (2017). Responsible Investment. Google Books. [online]. Available from: https://books.google.co.uk/books?hl=en&lr=&id=Zqo0DwAAQBAJ&oi=fnd&pg=P T8&dq=responsible+investment+and+materiality+in+esg+sullivan&ots=jCJaWds2 K&sig=mB0LWDh1HyVm4WJ1xvVS9Kvc18#v=onepage&q=responsible%20investment%20and%20materiality%20in%2 0esg%20sullivan&f=false [Accessed August 5, 2025].

93. Swilling, M., Musango, J. and Wakeford, J. (2015). Developmental States and Sustainability Transitions: Prospects of a Just Transition in South Africa. Journal of Environmental Policy & Planning, 18(5), pp.650–672.

94. Trading Economics. (2024). South Africa Gold Production YoY. Tradingeconomics.com. [online]. Available from: https://tradingeconomics.com/south-africa/gold-production.

95. Vorster, S., Winkler, H. and Jooste, M. (2011). Mitigating climate change through carbon pricing: An emerging policy debate in South Africa. Climate and Development, 3(3), pp.242–258.

96. Xhindole, C., Tarquinio, L. and Sierra -García, L. (2025). Climate change and task force on climaterelated financial disclosures (TCFD) reports. A comparison between italy and spain. Journal of Accounting & Organizational Change , 21(7), pp.1–28.

97. Zhang, W. and Sovacool, B.K. (2024). The Geopolitics of Net -Zero Transitions: Exploring the Political Economy of Carbon Border Adjustment Mechanism Implementation in the Global South.

98. Zhou, S., Simnett, R. and Green, W. (2017). Does Integrated Reporting Matter to the Capital Market? Abacus, 53(1), pp.94–132.

Annexure 1 Profile of the Gold Minning Companies

Profile on each of the gold mining firms selected within this research, please note imbedded links to refer to the ESG GPS and company’s annual report page. 

Sibanye-Stillwater Limited

Sibanye-Stillwater is a multinational mining and metals processing group headquartered in Johannesburg, South Africa. Originally established in 2013 through the unbundling of Gold Fields’ Beatrix and Kloof operations, the company has since evolved into one of the world’s largest producers of platinum group metals (PGMs) and a significant gold producer. Its South African operations include deep-level gold mining as well as extensive PGM assets, while its international footprint spans the United States and Europe, including the Stillwater PGM mine in Montana. Beyond precious metals, Sibanye -Stillwater has diversified into battery metals, acquiring stakes in lithium and nickel projects to align with global decarbonisation trends. The company has positioned itse lf at the forefront of ESG initiatives, with growing investment in renewable energy, water stewardship, and mine rehabilitation. Given its size and emissions profile, Sibanye-Stillwater plays a pivotal role in South Africa’s Just Energy Transition and is particularly exposed to international regulatory pressures such as CBAM.

Harmony Gold Mining Company Limited

Harmony Gold is South Africa’s largest gold producer by volume and a leading emerging market miner with a diverse portfolio of assets. Established in 1950, the company is headquartered in Randfontein and operates nine underground mines, one open-pit operation, and several surface retreatment facilities in South Africa, as well as the Hidden Valley mine in Papua New Guinea. Harmony has long been associated with deep-level mining, particularly in the Witwatersrand Basin, which contributes significantly to its output but also presents high energy intensity and operational complexity. The company employs tens of thousands of workers, making it one of the largest employers in the mining sector. Harmony’s strategy increasingly emphasises sustainability, renewable energy integration, and improving the efficiency of legacy operations. With its heavy reliance on Eskom’s coal -based electricity, Harmony faces substantial challenges in managing its carbon footprint, making it a key case study in understanding how interna tional and domestic regulation drives decarbonisation efforts.

Gold Fields Limited

Gold Fields, founded in 1887, is one of the world’s oldest and most prominent gold mining companies. Headquartered in Johannesburg, the company has evolved into a globally diversified producer with operations in South Africa, Ghana, Australia, and Peru, al ong with projects in Canada and Chile. In South Africa, Gold Fields operates the South Deep mine, one of the world’s largest known gold deposits. Unlike some peers, Gold Fields has placed strong emphasis on ESG leadership, adopting TCFD -aligned reporting e arly and investing extensively in renewable energy infrastructure, including one of South Africa’s largest solar PV plants at South Deep. This proactive approach has positioned the company as an ESG frontrunner, enhancing its credibility with global invest ors and reducing exposure to international regulatory risks. With its relatively lower emissions intensity and emphasis on operational transparency, Gold Fields serves as a benchmark in the sector for how credible signalling and substantive sustainability initiatives can reinforce competitiveness.

DRDGOLD Limited 

DRDGOLD, headquartered in Johannesburg, is a specialist in surface gold tailings retreatment and one of South Africa’s oldest mining companies, with origins dating back to 1895. Unlike traditional deeplevel gold miners, DRDGOLD focuses on reprocessing mine dumps and tailings to extract residual gold, a business model that carries lower safety risks but remains highly energy-intensive due to its reliance on large -scale milling, pumping, and water management systems. The company operates primarily in the Witw atersrand Basin, with flagship operations including the Ergo and Far West Gold Recoveries projects. DRDGOLD is majority-owned by Sibanye-Stillwater, which has integrated it into its broader strategy of diversification and sustainability. DRDGOLD has distin guished itself through investments in renewable energy projects and its focus on environmental rehabilitation, as tailings retreatment inherently contributes to land restoration. Its operations offer an important lens into how niche mining models respond to ESG pressures, disclosure requirements, and regulatory frameworks like CBAM.

Pan African Resources Plc 

Pan African Resources is a mid -tier, African -focused gold producer headquartered in Johannesburg and listed on both the London Stock Exchange’s AIM market and the Johannesburg Stock Exchange. The company’s portfolio includes a mix of underground and surface operations in South Africa, with key assets such as Barberton Mines (among the country’s oldest gold mines) and Evander Gold Mines. It also operates surface retreatment plants, including the Barberton Tailings Retreatment Plant and the Elikhulu Tailings Retreatment Plant, which are central to its production profile. Pan African has p ursued a strategy of combining traditional gold mining with lower-cost, lower-risk surface operations to stabilise cash flows. More recently, the company has prioritised renewable energy, commissioning large-scale solar plants to reduce reliance on Eskom a nd to lower carbon emissions. Its hybrid operational model and emphasis on sustainability position it as an agile player in responding to international climate regulations while continuing to deliver shareholder value.

Annexure 2 Table 1: Data collected for firms within this research

Annexure 3 Table 2: Timeline of Environmental Regulation and Environmental Policy (2018-2024)