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Red flags and conflict-affected and high-risk areas

High-risk areas

Conflict-affected and other high-risk areas are char­ac­terised by insti­tu­tional weak­ness, polit­ical insta­bility, inse­cu­rity, armed conflict, wide­spread violence, or other risks of harm to people.

What are red flags?

When compa­nies recog­nise the following red flags, they should apply the due-diligence stan­dards and processes recom­mended in the Guidance:

Mineral, origin, and transit red flags
  • The minerals orig­i­nated in or have been trans­ported through a conflict-affected or high-risk area.
  • The declared country of origin for the minerals is one where the known mineral reserves or stocks, prob­able resources, or expected produc­tion levels are limited (i.e. the declared volumes of minerals from the country are dispro­por­tionate to its known reserves or expected produc­tion levels).
  • The minerals are declared to orig­i­nate in a country through which minerals from conflict-affected and high-risk areas are known or reason­ably suspected to be trans­ported.
  • The minerals are declared to orig­i­nate from recy­clable, scrap, or mixed sources and have been refined in a country through which minerals from conflict-affected and high-risk areas are known or reason­ably likely to be trans­ported.

Suppliers red flags
  • Suppliers or other known upstream compa­nies operate in one of the red-flag loca­tions of mineral origin and transit, or suppliers hold share­holder or other inter­ests in suppliers of minerals from one of the red-flag loca­tions of origin and transit.
  • Suppliers or other known upstream compa­nies are known to have sourced minerals from a red-flag loca­tion of origin and transit in the last 12 months.

Red-flag circum­stances
Based on anom­alies or unusual circum­stances iden­ti­fied in the infor­ma­tion collected in Step 1, it is reason­able to suspect that the minerals may contribute to conflict or serious abuses, bribery, or other serious finan­cial crimes asso­ci­ated with mineral extrac­tion, trans­port, or trade.

High-risk areas

Conflict-affected and other high-risk areas are char­ac­terised by insti­tu­tional weak­ness, polit­ical insta­bility, inse­cu­rity, armed conflict, wide­spread violence, or other risks of harm to people.