Ecuador Chamber of Mining of Ecuador Mina Mirador – “in progress” Not identified in consulted public sources Not identified as country-level adoption in consulted public sources Brazil IBRAM Mineração Serra Grande (Nickel Mark) – “in progress” IRMA public entries for Brazil (scheme presence evidenced) Brazil adopts TSM through IBRAM (agreement with Mining Association of Canada) Source: Author’s compilation based on public site lists (The Copper Mark / Nickel Mark), IRMA audit publications, TSM adoption announcements and external verification publications, and association institutional pages. 3. PROBLEM STATEMENT: THE “IMPLEMENTATION GAP” IN LAC In LAC, global responsible mining standards exist and largely converge in content, yet verifiable implementation is often uneven and concentrated among operations facing stronger external pressures (financing, market access, traceability requirements or corporate commitments). In practice, this produces “islands” of adoption: a group of early movers advances with assurance and transparency, while a significant share of mid-sized operators, contractors and local supply chains remains below verifiable thresholds. This gap matters because “credible” performance depends not only on corporate intent, but also on enabling conditions such as regulatory capacity, institutional integrity, security and effective State presence in mining territories. Across LAC, these conditions are more heterogeneous than in many OECD jurisdictions, which raises the threshold for comparable evidence and consistent assurance. Illegal economies and illicit flows can further erode traceability and governance. OECD analysis, for instance, documents how high-risk gold originating in the region may be laundered within LAC before reaching destination markets, exploiting vulnerabilities in certain trade circuits (OECD, 2022). The implementation gap typically manifests in four structural challenges: (i) limited coverage (adoption concentrated among early movers); (ii) incomplete comparability (heterogeneous evidence thresholds and audit quality); (iii) insufficient incentives and consequences (performance is not consistently rewarded, and persistent non-conformance is not consistently sanctioned); and (iv) fragmentation (multiple initiatives complicate interpretation and prioritization for investors, buyers, authorities and communities). 194
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