Track 3: Environmental Stewardship

231 One tension requires direct acknowledgement: several major institutional investors and development finance institutions — including the European Investment Bank, which has largely exited upstream gas financing, and several IFC-aligned commercial lenders — have adopted exclusion policies for new gas infrastructure. For mining companies seeking to access these capital pools, a gas-inclusive strategy requires careful framing and robust documentation. In practice, this means presenting the hybrid strategy as a phased, time-bound pathway with defined exit triggers; demonstrating that gas infrastructure does not foreclose lower-emission alternatives; and committing to full methane MRV from wellhead to end-use. The IFC Performance Standards and the Climate Bonds Initiative taxonomy provide relevant reference frameworks for structuring this documentation. Proactive engagement with financiers well before project-level financing decisions is essential — presenting the strategy as a phased pathway with defined milestones rather than an open-ended gas commitment significantly improves the odds of accessing transition-aligned capital. Peru’s sustainable finance frameworks remain at an early stage of development. As taxonomies and reporting standards evolve, the ability to demonstrate a credible, MRV-backed decarbonization strategy will become an increasingly important determinant of financing costs and capital access for mining companies. 5.4 Risks and Mitigations: A Complete Register Table 12 — Risk Register for a Gas-Enabled Mining Energy Transition Risk Nature Required Mitigation Transition misalignment Assets risk becoming stranded. Preserve optionality in a strategy that balances competitiveness, sustainability and security. Methane leakage Fugitive methane can erase the climate benefit of switching from coal or diesel if leakage exceeds ~3.2%. Implement full-value-chain MRV from wellhead to burner tip; report publicly. Supply chain vulnerability Pipeline dependence creates outage exposure. Invest in gas pipelines, storage capacity and LNG alternatives. ESG threshold misalignment Institutional investors with gas exclusion policies may restrict capital access for gas-inclusive strategies. Demonstrate credible Scope 1/2 trajectories with MRV backing; align with GHG Protocol and TCFD.

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