OECD

Step 5

Brady — Tue, 09 Oct 2018 23:13:29 +0000

Step 5 — Report Annually on Supply Chain Due Diligence

Report publicly on the company’s due diligence efforts for responsible supply chains of minerals from conflict-affected and high risk areas. No confidential information such as supplier relationships, price information, or identities of whistle blowers should be published.
Reports should focus on company actions to address identified risks (i.e. management systems in place, steps taken to identify smelters and refiners in the supply chain, risk assessment methodology, assessment of smelter/refiner’s risks and due diligence steps in accordance to the OECD Guidance, steps taken to manage risk, efforts made to monitor and track performance for risk mitigation).

Brady — Tue, 09 Oct 2018 23:13:00 +0000

Step 4 — Independent 3rd Party Audit of Smelter/Refiner/ key point of transformation Due Diligence Practices

Support audit of smelter/refiner/key point of transformation by:

Providing financial support to promote independent 3rd party audits of refiners and smelters
Strengthen industry programmes by participating through membership or promoting smelters and refiners participation in audit programmes
Periodically assessing the quality of industry-led validation programmes or independent smelter/refiner audits, if they choose to participate in such a scheme

Brady — Tue, 09 Oct 2018 23:12:20 +0000

Step 3 — Design and Implement a strategy to respond to Identified Risks

Report identified supply chain risks (i.e. priority suppliers, identified smelters/refiners, assessment of smelter/refiners’ level of risk and corresponding due diligence actions, information gaps, information on chain of custody information, etc.) to senior management.
Identify and track which suppliers who are responding to information requests, and those who are not. Follow up with suppliers, and escalate uncooperative suppliers to senior management.
Disengage from suppliers associated with any smelters/refiners that may be contributing to conflict or the most serious human rights impacts as defined in Annex II of the OECD Guidance.
Manage risks of support of public or private security forces, bribery, money laundering and non payment of taxes through measurable risk mitigation aiming to promote progressive performance improvement within reasonable timescale.
Improve internal risk assessment systems over time by tracking implementation and risk mitigation measures.

Brady — Tue, 09 Oct 2018 23:11:52 +0000

Step 2 — Identify and Assess Risks in the Supply Chain

Identify the company’s suppliers and, in collaboration with them, identify smelters, refiners or other point of transformation in the supply chain where the mineral is processed to reach commercial market quality.
Engage with smelters and refiners and obtain initial information on country of origin, transit and transportation routes used between mine and smelters/refiners/point of transformation. There are a number of “red flag” triggers which oblige refiners and smelters in the supply chain to conduct due diligence in line with the OECD Guidance.
Assess if smelters and refiners have conducted all the necessary due diligence steps for red flag supply chains (e.g. by reviewing the information generated by the assessment teams, reviewing the results of the audit.

Brady — Thu, 16 Aug 2018 17:29:19 +0000

Step 1 — Strong Company Management Systems

Adopt a policy for responsible mineral supply chains.
Assemble an internal team to oversee supply chain due diligence. Obtain senior management support including the necessary authority and budget.
Establish a supply chain transparency system that allows the identification of refiners or other point of transformation in the supply chain where the mineral is processed to reach commercial market quality
Communicate company policy and expectations to suppliers. Describe actions the company will take to support its policies and goals in responsible sourcing. Companies may want to include these expectations in supplier contracts
Collect and be aware of grievances from stakeholders