Adopt a policy for responsible supply chains of minerals consistent with the OECD Due Diligence Guidance and support the implementation of the Extractive Industry Transparency Initiative
Assemble an internal team to oversee supply chain due diligence. Ensure that the necessary budget resources are assigned and that a senior manager is ultimately accountable.
Establish an internal system of transparency, information collection, and records of supply chain due diligence processes, findings and resulting decisions.
Assign a unique internal reference number to each mineral input and output and affix it to each output in such a way that any tampering will be evident.
Compile information related to mine of origin production, transport, trade and export, including, if relevant, the identities of any suppliers of minerals. Disclose this information to immediate downstream purchasers or to any mandated institutional mechanism.
If sourcing minerals from any third parties, communicate the company policy, actions and expectations related to responsible sourcing to any suppliers. Companies should incorporate these expectations into supplier contracts and consider other ways to support the capabilities of suppliers to fulfil responsible sourcing expectations.
Collect stakeholder grievances through individual or collaborative grievance mechanisms.
Miners — Step 2
Identify, assess, and prioritise risks
Determine whether your company mines, transports, or purchases minerals in or from a conflict-affected or high-risk area or is associated to any other red flags (see red flags).
Map the factual circumstances of red-flagged operations by reviewing research reports and consulting with local and central governments and civil society organisations.
For red-flagged operations set up on-the-ground assessment teams and ask these questions to generate and maintain information on the circumstances of extraction, trade, handling, refining, and export.
If an on-the-ground assessment was already carried out (e.g. by a supplier, an industry scheme, or other third party), review the assessment to ensure they are credible, up-to-date, and cover risks specific to your supply chain.
Assess risks in the supply chain by determining whether the circumstances in the supply chain meet the companies supply chain policy and standards in Annex II of the Guidance (see risks listed above for a summary).
Miners — Step 3
Report identified supply chain findings to senior management.
Devise and implement a mitigation plan. Immediately suspend or discontinue engagement with specific upstream suppliers if there is a reasonable risk that they are sourcing from or otherwise affiliated with any party committing serious human rights abuses or providing direct or indirect support to non-state armed groups.
Sourcing from upstream suppliers is possible even if there is a reasonable risk of direct or indirect support to public or private security forces (e.g. criminal networks within the police, army units, or private mine security), corruption, money laundering, non-payment of dues, or an inaccurate or fraudulent chain of custody. However, in such cases, the company should immediately devise and implement a risk-management plan with suppliers, local governments and impacted stakeholders to address these risks and seek to demonstrate significant and measurable improvement every six months. Risk-management measures can include formalising security arrangements, reporting abusive units to competent authorities, and/or improving and monitoring transparency systems.
Monitor risk management plan and commitments, including by engaging with impacted communities and stakeholders to support monitoring.
Monitor your supply chains and undertake additional risk assessment for any change of circumstances.
Miners — Step 4
Audit control point
Allow access to company sites and relevant documentation. Facilitate on-site visits and contacts with suppliers selected by the audit team.
Miners — Step 5
Communicate and report on due diligence
Report publicly on the company’s due-diligence efforts for responsible supply chains of minerals from conflict-affected and high-risk areas. Disclose information on payments made to governments in line with the Extractive Industry Transparency Initiative.
Reports should focus on the key findings of the risk assessment and actions taken by the company to address identified risks (e.g. management systems established; risk-assessment methodology implemented; steps taken to manage risks; and efforts made to monitor and track performance for risk mitigation).
Provide a description of any audits in which the company has participated.
Disclose information with due regards taken of business confidentiality and other competitive concerns (i.e. price information and supplier relationships do not need to be disclosed).