Stakeholder Engagement in Mining: Best Practices for Uganda

Introduction: The Foundation of Responsible Mining

Mining, by its very nature, transforms landscapes, displaces livelihoods, and alters communities. No mineral deposit exists in isolation — every project is situated within a web of social, economic, environmental, and political relationships. The communities that live on or near mineral-bearing land, the local and national governments that regulate resource extraction, the environmental organisations that monitor ecological impacts, and the investors who finance operations all have legitimate interests in how a mining project is planned, executed, and eventually closed.

Stakeholder engagement is the structured process through which mining companies identify, communicate with, and respond to the concerns of all parties affected by or interested in their operations. Done well, it builds trust, reduces conflict, secures the social licence to operate, and creates shared value that extends far beyond the mine gate. Done poorly — or not at all — it leads to community opposition, regulatory delays, costly legal disputes, reputational damage, and, in the worst cases, the complete shutdown of otherwise viable projects.

In Uganda, where the mining sector is poised for significant growth following recent discoveries and increased government investment in geological surveys, stakeholder engagement is not merely a corporate social responsibility exercise. It is a regulatory requirement, a business imperative, and a moral obligation. This guide examines why stakeholder engagement matters, what the legal framework requires, and how mining companies operating in Uganda can implement best practices that deliver genuine results.

Why Stakeholder Engagement Matters

Securing the Social Licence to Operate

The social licence to operate is the informal, ongoing acceptance of a mining project by the local community and broader society. Unlike a government-issued mining licence, the social licence cannot be purchased or legislated — it must be earned through consistent, transparent, and respectful engagement. Communities that feel heard, respected, and fairly treated are far more likely to support a mining project. Those that feel excluded, misled, or exploited will resist, and that resistance can take many forms: from peaceful protests and petition campaigns to blockades of access roads and, in extreme cases, violence.

The reality is that a mining licence from the government grants the legal right to explore or mine, but it does not guarantee community acceptance. Projects that secure their legal permits but neglect their social licence frequently encounter delays, cost overruns, and reputational damage that far outweigh the investment required for meaningful engagement.

Regulatory Compliance

Uganda's legal framework explicitly requires stakeholder engagement as part of the mining permitting process. The Mining and Minerals Act, 2003, and its associated regulations require applicants for exploration and mining licences to demonstrate that they have consulted with affected communities and local authorities. The National Environment Act, 2019, mandates that Environmental Impact Assessments (EIAs) for mining projects include a public consultation component, giving affected persons the opportunity to review the assessment findings and submit their concerns.

Failure to comply with these consultation requirements can result in licence applications being rejected, permits being revoked, or operations being suspended. The legal obligation is clear, but the most successful companies go well beyond the minimum requirements, recognising that compliance-driven engagement alone is insufficient to build genuine trust and cooperation.

Reducing Conflict and Project Risk

Stakeholder conflicts are among the most significant risks facing mining companies worldwide, and Uganda is no exception. Disputes over land rights, compensation, environmental damage, employment expectations, and benefit sharing have disrupted mining projects across the country. In many cases, these conflicts could have been prevented or resolved early through proactive engagement.

By identifying and addressing stakeholder concerns before they escalate, mining companies can avoid costly disruptions, litigation, and reputational harm. Early engagement also allows companies to incorporate local knowledge and priorities into project design, often resulting in better outcomes for both the company and the community.

Creating Shared Value

Beyond risk mitigation, effective stakeholder engagement creates opportunities to generate genuine shared value. Mining projects can stimulate local economic development through employment, procurement of local goods and services, skills training, infrastructure development, and community investment programmes. These benefits are most effectively delivered when they are designed in partnership with stakeholders, rather than imposed from outside.

Communities that experience tangible, equitable benefits from mining are more likely to become long-term allies of the project, providing a stable operating environment and a positive reference for future investments. For investors and companies evaluating mining opportunities in Uganda, a strong track record of stakeholder engagement is a powerful indicator of project viability.

Uganda's Legal Framework for Community Participation

The Mining and Minerals Act, 2003

The Mining and Minerals Act establishes the legal framework for mining in Uganda and includes several provisions related to stakeholder engagement and community rights:

Consultation before licence grant: The Commissioner for Geological Survey and Mines is required to consider the views of local communities and District Local Governments before granting exploration or mining licences. Applicants must demonstrate that they have informed and consulted affected parties.
Surface rights and compensation: The Act provides for compensation to surface rights holders whose land is affected by mining activities. Negotiations over compensation amounts and terms are a critical element of stakeholder engagement.
Community development agreements: While not explicitly mandated in the current Act, the government has signalled through policy statements and proposed amendments that community development agreements — formal commitments by mining companies to invest in local development — will become a statutory requirement for large-scale mining operations.

The National Environment Act, 2019

The National Environment Act requires that EIAs for projects likely to have significant environmental impact — which includes virtually all mining operations — incorporate public participation. This includes:

Public notification of the proposed project and the EIA process.
Availability of EIA documentation for public review.
Public hearings or meetings at which affected persons can present their views.
A requirement for the developer to respond to public concerns in the final EIA report.

These provisions ensure that communities have a formal opportunity to influence project design and conditions of approval. However, the quality and genuineness of public participation vary widely in practice, and mining companies committed to best practice will go beyond the procedural minimum.

The Land Act and Land Rights

Land tenure in Uganda is complex, with four distinct systems recognised under the Constitution: customary, freehold, mailo, and leasehold. Mining often takes place on customary land, where rights may not be formally documented but are nonetheless legally recognised. Stakeholder engagement must include a thorough and culturally sensitive process for identifying and consulting all persons with legitimate land interests, including women and vulnerable groups who may hold customary use rights even if they are not the registered landholders.

Best Practices for Stakeholder Engagement

1. Start Early and Engage Continuously

The most common mistake in stakeholder engagement is starting too late. Engagement should begin at the earliest stages of a project — ideally during the exploration phase, before any ground disturbance occurs. Early engagement allows the company to:

Introduce itself and its intentions transparently.
Build relationships with community leaders, local government officials, and other key stakeholders.
Understand community concerns, expectations, and priorities.
Identify potential issues and address them proactively.

Engagement must then continue throughout the project lifecycle: during advanced exploration, feasibility studies, construction, operations, and closure. It is not a one-off event but an ongoing relationship.

2. Identify All Stakeholders Comprehensively

A robust stakeholder identification process goes beyond the obvious actors (community leaders and local government) to include:

Women, youth, and elderly community members.
Pastoralists or seasonal land users who may not be permanently resident.
Downstream water users and neighbours.
Religious and cultural leaders.
Local civil society organisations and NGOs.
National regulatory bodies (DGSM, NEMA, DWRM).
Academic and research institutions.
Media.

Stakeholder mapping tools such as interest-influence matrices help categorise stakeholders and tailor engagement approaches accordingly.

3. Communicate Transparently and Accessibly

All communication with stakeholders should be:

Honest: Do not make promises that cannot be kept. Be upfront about both the potential benefits and the potential risks of the project.
Timely: Share information before decisions are made, not after. Stakeholders should have genuine opportunities to influence outcomes.
Accessible: Use local languages. Avoid technical jargon. Use visual aids, maps, and diagrams. Hold meetings at convenient times and locations. Consider literacy levels and ensure that information is available in both written and oral formats.
Two-way: Engagement is not a lecture — it is a dialogue. Create meaningful opportunities for stakeholders to ask questions, express concerns, and propose alternatives.

4. Conduct Free, Prior, and Informed Consent (FPIC)

For projects that affect indigenous peoples or communities with deep customary ties to the land, the principle of Free, Prior, and Informed Consent (FPIC) applies. FPIC requires that affected communities are:

Freely able to give or withhold their consent without coercion, intimidation, or manipulation.
Prior to the commencement of activities — not presented with a fait accompli.
Informed through the provision of complete, accurate, and understandable information about the project, its impacts, and the alternatives.

Even where FPIC is not strictly required under national law, adopting its principles is considered international best practice and significantly strengthens the social licence.

5. Establish Robust Grievance Mechanisms

No matter how well a company engages, grievances will arise. A credible grievance mechanism provides stakeholders with a clear, accessible, and responsive channel for raising concerns, complaints, or disputes. Effective grievance mechanisms:

Are known and accessible to all stakeholders, including women and marginalised groups.
Accept complaints in any form — verbal, written, anonymous.
Acknowledge receipt promptly and provide a timeline for resolution.
Investigate complaints impartially and transparently.
Provide remedies that are fair and proportionate.
Track and report on grievances to identify systemic issues.

The absence of a functioning grievance mechanism forces stakeholders to seek redress through other channels — the media, the courts, politicians, or direct action — all of which are more costly and adversarial for both parties.

6. Invest in Community Development

Stakeholder engagement should not be confused with corporate philanthropy, but genuine investment in community development is a critical component of building trust and shared value. Effective community development initiatives:

Are identified through participatory needs assessments, not imposed by the company.
Align with local and national development priorities.
Build local capacity and create sustainable outcomes, rather than creating dependency.
Are transparently budgeted and reported.

Common community development contributions by mining companies in Uganda include investments in education (schools, bursaries), health (health centres, clean water supply), infrastructure (roads, bridges, electricity), and livelihoods (skills training, agricultural support, small business development).

7. Engage Local Government as a Partner

District Local Governments in Uganda play a critical role as intermediaries between mining companies and communities. They issue local government approvals, monitor environmental compliance, and are responsible for delivering public services to mining-affected communities. Engaging District leadership — the District Chairperson, Chief Administrative Officer, and relevant technical officers — early and consistently is essential.

Local government engagement should include:

Formal introductions and project briefings.
Regular progress updates and joint monitoring visits.
Coordination on community development priorities to avoid duplication of efforts.
Collaboration on issues such as road maintenance, health services, and environmental monitoring.

ALOM's Approach to Stakeholder Engagement

At ALOM Mining & Geohydro Services, stakeholder engagement is not an afterthought — it is embedded in the way we work. Our experience across multiple districts in Uganda has demonstrated that mining projects succeed when communities are treated as partners, not obstacles.

In Kitgum District, our work with the Orom East Subcounty community and the District Local Government exemplifies our approach. Before commencing any technical activities, our team engaged directly with community leaders, local council officials, and affected landholders to explain the project scope, address concerns, and incorporate local input into our work plans. This early and transparent engagement built trust that facilitated smooth operations and positive community relations throughout the project.

Our mining services are designed to integrate stakeholder engagement into every phase of the project lifecycle, from initial exploration through to mine development and closure. We work closely with our clients to develop engagement strategies that comply with Uganda's regulatory requirements, align with international best practice, and deliver genuine benefits to host communities.

Common Challenges and How to Overcome Them

Unrealistic Expectations

Communities may expect immediate and substantial benefits from mining — jobs, infrastructure, wealth — that are not realistic, particularly during the exploration phase, which generates few direct benefits and may not lead to a mine at all. Managing expectations through honest, clear communication from the outset is essential. Explain the exploration process, the timelines involved, and the uncertainties that exist. Our guide to the mineral exploration process is a useful resource for understanding the stages that precede mining.

Land and Compensation Disputes

Disputes over land ownership, compensation amounts, and resettlement terms are among the most contentious issues in mining stakeholder relations. These disputes are best addressed through:

Early and thorough land tenure assessments.
Transparent and well-documented valuation and compensation processes.
Use of independent valuers and legal advisors.
Involvement of local government and community leaders as witnesses and mediators.
Provision of legal assistance to affected persons.

Political Interference

In some cases, local or national politicians may seek to exploit mining projects for political gain, making unrealistic promises to communities or attempting to influence licence allocation. Mining companies should maintain political neutrality, engage with all elected and appointed officials on a professional basis, and ensure that their engagement processes are transparent and well-documented to withstand scrutiny.

Cultural Sensitivities

Uganda is home to more than 50 ethnic groups, each with distinct cultural practices, land use systems, and governance structures. Mining projects must be culturally sensitive — for example, some communities may have sacred sites that must not be disturbed, customary governance structures that must be respected, or gender norms that require tailored engagement approaches to ensure women's voices are heard.

Conclusion

Stakeholder engagement is not a box to be ticked on the way to obtaining a mining licence. It is a fundamental discipline that determines whether a mining project will earn the trust of the communities it affects, comply with Uganda's legal requirements, avoid costly conflicts, and create genuine shared value. The best mining companies recognise that their most important asset is not the ore in the ground — it is the relationship they build with the people who live above it.

For mining companies, investors, and project developers operating in Uganda, investing in professional, sustained, and genuine stakeholder engagement is not an optional cost — it is a strategic investment that pays dividends throughout the life of the project. Whether you are in the early stages of exploration or planning a major mining development, ALOM Mining & Geohydro Services is here to support your stakeholder engagement efforts with local knowledge, proven experience, and a commitment to responsible mining practice.