Other upstream companies — Step 1

Establish strong management systems

• Adopt a policy for respon­sible supply chains of minerals consis­tent with the OECD Due Diligence Guidance.
• 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.
• Compile infor­ma­tion related to mine of origin, produc­tion, trans­port, trade, export and the iden­ti­ties of any suppliers of minerals. Disclose this infor­ma­tion to imme­diate down­stream purchasers or to any mandated insti­tu­tional mechanism.
• For red-flagged supply chains iden­ti­fied in Step 2, seek to progres­sively collect and main­tain the following infor­ma­tion on the chain of custody or traceability: 
  • the iden­tity of all suppliers and rele­vant service providers handling the mineral in the upstream supply chain from the mine of origin until the refiner; the owner­ship (including bene­fi­cial owner­ship); the corpo­rate struc­ture including the names of corpo­rate offi­cers and direc­tors; the busi­ness, govern­ment, polit­ical or mili­tary affil­i­a­tions of those compa­nies and offi­cers within conflict-affected and high-risk areas
  • all taxes, fees or royal­ties paid to govern­ment related to the extrac­tion, trade, trans­port and export of mineral
  • all payments or compen­sa­tion made to govern­ment agen­cies and offi­cials related to the extrac­tion, trade, trans­port and export of mineral
  • all payments made to public or private secu­rity forces or other armed groups at all points in the supply chain from extrac­tion onwards, unless prohib­ited under applic­able law
• Assign a unique internal refer­ence number to each input and output and affix it to each output in such a way that any tampering will be evident.
• Communicate company policy, actions and expec­ta­tions related to respon­sible sourcing to suppliers. Companies should incor­po­rate these expec­ta­tions into supplier contracts or other written agree­ments with suppliers, and consider ways to build their capacity to imple­ment due diligence.
• Collect stake­holder griev­ances through indi­vidual or collab­o­ra­tive griev­ance mechanisms.

Other upstream companies — 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 with any other red flags.
• Map the factual circum­stances of red-flagged supply chains by reviewing research reports and consulting with local and central govern­ments and civil society organisations.
• For red-flagged supply chains 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).

Other upstream companies — Step 3

Manage risks

• Report iden­ti­fied supply chain find­ings to senior management.
• For red-flagged supply chains, strengthen chain of custody and trace­ability systems.
• 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 imple­ment a risk-management plan with upstream suppliers and other stake­holders to elim­i­nate these risks. 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.

Other upstream companies — 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.

Other upstream companies — 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.
• Reports should focus on the actions taken by the company to address iden­ti­fied risks (e.g. manage­ment systems estab­lished; steps taken to iden­tify control points in the supply chain; risk assess­ment method­ology imple­mented; assess­ments conducted to iden­tify control points’ risks and corre­sponding due dili­gence measures in accor­dance with the OECD Guidance; 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).

Key point of transformation — Step 1

Establish strong management systems

• Adopt a policy for respon­sible supply chains of minerals consis­tent with the OECD Due Diligence Guidance.
• 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.
• Compile infor­ma­tion related to mine of origin, produc­tion, trans­port, trade, export and the iden­ti­ties of any suppliers of minerals. Disclose this infor­ma­tion to imme­diate down­stream purchasers or to any mandated insti­tu­tional mechanism.
• For red-flagged supply chains iden­ti­fied in Step 2, seek to progres­sively collect and main­tain the following infor­ma­tion on the chain of custody or traceability: 
  • the iden­tity of all suppliers and rele­vant service providers handling the mineral in the upstream supply chain from the mine of origin until the refiner; the owner­ship (including bene­fi­cial owner­ship); the corpo­rate struc­ture including the names of corpo­rate offi­cers and direc­tors; the busi­ness, govern­ment, polit­ical or mili­tary affil­i­a­tions of those compa­nies and offi­cers within conflict-affected and high-risk areas
  • all taxes, fees or royal­ties paid to govern­ment related to the extrac­tion, trade, trans­port and export of mineral
  • all payments or compen­sa­tion made to govern­ment agen­cies and offi­cials related to the extrac­tion, trade, trans­port and export of mineral
  • all payments made to public or private secu­rity forces or other armed groups at all points in the supply chain from extrac­tion onwards, unless prohib­ited under applic­able law
• Assign a unique internal refer­ence number to each input and output and affix it to each output in such a way that any tampering will be evident. Compile infor­ma­tion related to produc­tion, trans­port, trade and export including the iden­ti­ties of any suppliers of minerals. Disclose this infor­ma­tion to imme­diate down­stream purchasers or to any mandated insti­tu­tional mechanism.
• Communicate company policy, actions and expec­ta­tions related to respon­sible sourcing to suppliers. Companies may want to 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.
• Report any incon­sis­tency between initial inspec­tion of a ship­ment and infor­ma­tion provided by the supplier. Make a busi­ness record of this verification.

Key point of transformation — 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 with any other red flags
• Map the factual circum­stances of red-flagged supply chains by reviewing research reports and consulting with local and central govern­ments and civil society organisations.
• For red-flagged supply chains 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).

Key point of transformation — Step 3

Manage risks

• 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 imple­ment a risk-management plan with upstream suppliers and other stake­holders to elim­i­nate these risks. 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.

Key point of transformation — Step 4

Audit control point

• Plan and imple­ment an inde­pen­dent third-party audit to provide assur­ance that your company has imple­mented due-diligence prac­tices for respon­sible supply chains from conflict-affected and high-risk areas. Audits should also include visits to suppliers (i.e. the traders or exporters that supply minerals to smelters, refiners, or other points of trans­for­ma­tion). Audit activ­i­ties can be conducted through any insti­tu­tion­alised mech­a­nism or industry programme.
• Allow access to company sites and rele­vant docu­men­ta­tion. Facilitate on-site visits and contacts with suppliers selected by the audit team.

Key point of transformation — 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.
• Reports should focus on the 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).

Traders and market makers — Step 1

Establish strong management systems

• Adopt a policy for respon­sible supply chains of minerals consis­tent with the OECD Due Diligence Guidance.
• 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.
• Communicate company policy, actions and expec­ta­tions related to respon­sible sourcing to suppliers. Companies may want to incor­po­rate these expec­ta­tions into supplier contracts and consider other ways to support the capa­bil­i­ties of suppliers to fulfil respon­sible sourcing expectations.
• Establish an internal system of trans­parency, infor­ma­tion collec­tion, and records of supply chain due dili­gence processes, find­ings and resulting deci­sions. In partic­ular, main­tain records on the iden­tity of smelters and refiners, or any other suppliers at points of trans­for­ma­tion where the mineral is processed to reach commer­cial market quality, once this infor­ma­tion is collected in Step 2.
• Collect and address stake­holder grievances.

Traders and market makers — Step 2

Identify, assess, and prioritise risks

• Identify your company’s suppliers and collab­o­rate with them to iden­tify the key points of trans­for­ma­tion in the supply chain where the mineral is processed to reach commer­cial market quality (e.g. smelters or refiners for metals).
• Engage with the key points of trans­for­ma­tion (e.g. smelters or refiners for metals). Obtain prelim­i­nary infor­ma­tion on the country of origin and the transit and trans­porta­tion routes used between the mine and refiners, or other point of trans­for­ma­tion to iden­tify any rele­vant red flags. 
• Assess whether smelters and refiners have conducted all neces­sary due dili­gence steps for any red-flagged supply chains that have been, or should have been, iden­ti­fied (e.g. by reviewing infor­ma­tion from the assess­ment teams and the results of any audits under Step 4 below).
• The above may be best achieved through an industry scheme or other collab­o­ra­tive initia­tive. If relying on such schemes or initia­tives, review those find­ings to ensure they are cred­ible, up-to-date, and cover risks specific to your supply chain.

Traders and market makers — Step 3

Manage risks

• Inform senior manage­ment of recog­nised supply chain risks (e.g. iden­tify priority suppliers; iden­tify smelters and refiners and assess their respec­tive risk levels and corre­sponding due dili­gence actions; docu­ment any infor­ma­tion gaps; and clarify the chain of custody).
• Identify and track which suppliers respond to infor­ma­tion requests and which do not. Follow up with suppliers and esca­late unco­op­er­a­tive suppliers to senior management.
• Strengthen efforts and systems to iden­tify and main­tain infor­ma­tion on key points of transformation.
• Disengage from suppliers asso­ci­ated with smelters and refiners that may be contributing to conflict or to the most serious human rights impacts as defined in Annex II of the OECD Guidance.
• Manage all other risks by devising a risk manage­ment plan with suppliers to promote progres­sive improve­ment within reason­able timescales. Specifically, risk manage­ment plans with smelters & refiners or other points of trans­for­ma­tion should include clearly defined targets, indi­ca­tors and time­frames to demon­strate signif­i­cant measur­able improve­ment every six months.
• Implementing risk manage­ment plans with smelters & refiners or compa­nies at other points of trans­for­ma­tion may be best achieved through an industry scheme or other collab­o­ra­tive initia­tive. If relying on such schemes or initia­tives, review those efforts to ensure they are cred­ible and on track.
• Improve internal risk assess­ment systems over time by tracking internal imple­men­ta­tion as well as commit­ments with suppliers.

Traders and market makers — Step 4

Audit control point

Support an audit of the smelter, refiner, and/or other key points of trans­for­ma­tion by:

• providing finan­cial resources for inde­pen­dent third-party audits of refiners and smelters
• becoming members of industry programmes or promoting smelter and refiner partic­i­pa­tion in audit programmes
• peri­od­i­cally assessing the quality of industry-led vali­da­tion programmes or inde­pen­dent audits of the smelters or refiners that choose to partic­i­pate in such schemes.

Traders and market makers — Step 5

Communicate and report on due diligence

• Report publicly on your compa­ny’s due dili­gence efforts for respon­sible supply chains of minerals from conflict-affected and high-risk areas.
• Reports should focus on the actions taken by the company to address iden­ti­fied risks (e.g. manage­ment systems estab­lished; steps taken to iden­tify smelters and refiners in the supply chain; risk assess­ment method­ology imple­mented; assess­ments conducted to iden­tify smelter and refiner risks and corre­sponding due dili­gence measures in accor­dance with the OECD Guidance; steps taken to manage risks; and efforts made to monitor and track perfor­mance for risk mitigation).
• Disclose infor­ma­tion with due regards taken of busi­ness confi­den­tiality and other compet­i­tive concerns (i.e. price infor­ma­tion and supplier relationships).

Manufacturers — Step 1

Establish strong management systems

• Adopt a policy for respon­sible supply chains of minerals.
• 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.
• Communicate company policy, actions and expec­ta­tions related to respon­sible sourcing to suppliers. Companies should incor­po­rate these expec­ta­tions into supplier contracts and consider other ways to support the capa­bil­i­ties of suppliers to fulfill respon­sible sourcing expectations.
• Establish an internal system of trans­parency, infor­ma­tion collec­tion, and records of supply chain due dili­gence processes, find­ings and resulting deci­sions. In partic­ular, main­tain records on the iden­tity of smelters & refiners, or any other suppliers at points of trans­for­ma­tion where the mineral is processed to reach commer­cial market quality, once this infor­ma­tion is collected in Step 2.

Manufacturers — Step 2

Identify, assess, and prioritise risks

• Identify your company’s suppliers and collab­o­rate with them to iden­tify the key points of trans­for­ma­tion in the supply chain where the mineral is processed to reach commer­cial market quality (e.g. smelters or refiners for metals).
• Engage with the key points of trans­for­ma­tion (e.g. smelters or refiners for metals). Obtain prelim­i­nary infor­ma­tion on the country of origin and the transit and trans­porta­tion routes used between the mine and refiners, or other point of trans­for­ma­tion to iden­tify any rele­vant red flags. 
• Assess whether smelters and refiners have conducted all neces­sary due dili­gence steps for any red-flagged supply chains that have been, or should have been, iden­ti­fied (e.g. by reviewing the above may be best achieved through an industry scheme or other collab­o­ra­tive initiative.
• If, due to the complexity of your supply chains, you are having diffi­culty iden­ti­fying the refiners or other points of trans­for­ma­tion in your supply chain, while your efforts are ongoing you may iden­tify through such industry schemes or collab­o­ra­tive initia­tives the refiners or other points of trans­for­ma­tion that meet the require­ments of this Guidance in order to source from.
• If relying on find­ings from an industry schemes or collab­o­ra­tive initia­tives, review those find­ings to ensure they are cred­ible, up-to-date, and cover risks specific to your supply chain.

Manufacturers — Step 3

Manage risks

• Inform senior manage­ment of the risks iden­ti­fied (e.g. iden­tify priority suppliers; iden­tify smelters and refiners and assess their rela­tive risk levels and corre­sponding due dili­gence actions; docu­ment any infor­ma­tion gaps; and clarify the chain of custody).
• Identify and track which suppliers respond to infor­ma­tion requests and which do not. Follow up with suppliers and esca­late unco­op­er­a­tive suppliers to senior management.
• Disengage from suppliers asso­ci­ated with smelters or refiners that may be contributing to conflict or to the most serious human rights impacts (as defined in Annex II of the OECD Guidance).
• Manage risks of support to public or private secu­rity forces, bribery, money laun­dering, and tax evasion by asking suppliers to put in place measur­able risk-mitigation actions intended to promote progres­sive perfor­mance improve­ment within a reason­able timescale.
• Improve internal risk assess­ment systems over time by tracking imple­men­ta­tion and risk-mitigation measures.
• If the refiner cannot be iden­ti­fied, adopt a risk manage­ment plan to be able to even­tu­ally demon­strate signif­i­cant measur­able improve­ments to your efforts to do so.

Manufacturers — Step 4

Audit control point

Support an audit of the smelter, refiner, and/or other key points of trans­for­ma­tion by:

• providing finan­cial resources for inde­pen­dent third-party audits of refiners and smelters
• becoming members of industry programmes or promoting smelter and refiner partic­i­pa­tion in audit programmes
• peri­od­i­cally assessing the quality of industry-led vali­da­tion programmes or inde­pen­dent audits of the smelters or refiners that choose to partic­i­pate in such schemes.

Manufacturers — Step 5

Communicate and report on due diligence

• Report publicly on your company’s due dili­gence efforts for respon­sible supply chains of minerals from conflict-affected and high-risk areas each year.
• Reports should focus on the key find­ings from the risk assess­ment and actions taken by the company to address iden­ti­fied risks (e.g. manage­ment systems estab­lished; steps taken to iden­tify smelters and refiners in the supply chain; risk assess­ment method­ology imple­mented; assess­ments conducted to iden­tify smelter and refiner risks and corre­sponding due dili­gence measures in line with the OECD Guidance; steps taken to manage risks; and efforts made to monitor and track perfor­mance for risk mitigation).
• Disclose infor­ma­tion with due regards taken of busi­ness confi­den­tiality and other compet­i­tive concerns (i.e. price infor­ma­tion and supplier relationships).

End-user companies — Step 1

Establish strong management systems

• Adopt a policy for respon­sible supply chains of minerals.
• 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.
• Communicate company policy, actions and expec­ta­tions related to respon­sible sourcing to suppliers. Companies should incor­po­rate these expec­ta­tions into supplier contracts and consider other ways to support the capa­bil­i­ties of suppliers to fulfil respon­sible sourcing expectations.
• Establish an internal system of trans­parency, infor­ma­tion collec­tion, and records of supply chain due dili­gence processes, find­ings and resulting deci­sions. In partic­ular, main­tain records on the iden­tity of smelters & refiners, or any other suppliers at points of trans­for­ma­tion where the mineral is processed to reach commer­cial market quality, once this infor­ma­tion is collected in Step 2.

End-user companies — Step 2

Identify, assess, and prioritise risks

• Identify your company’s suppliers and collab­o­rate with them to iden­tify the key points of trans­for­ma­tion in the supply chain where the mineral is processed to reach commer­cial market quality (e.g. smelters or refiners for metals).
• Engage with the key points of trans­for­ma­tion (e.g. smelters or refiners for metals). Obtain prelim­i­nary infor­ma­tion on the country of origin and the transit and trans­porta­tion routes used between the mine and refiners, or other point of trans­for­ma­tion to iden­tify any rele­vant red flags. 
• Assess whether smelters and refiners have conducted all neces­sary due dili­gence steps for any red-flagged supply chains that have been, or should have been, iden­ti­fied (e.g. by reviewing the above may be best achieved through an industry scheme or other collab­o­ra­tive initiative.
• If, due to the complexity of your supply chains, you are having diffi­culty iden­ti­fying the refiners or other points of trans­for­ma­tion in your supply chain, while your efforts are ongoing you may iden­tify through such industry schemes or collab­o­ra­tive initia­tives the refiners or other points of trans­for­ma­tion that meet the require­ments of this Guidance in order to source from.
• If relying on find­ings from an industry schemes or collab­o­ra­tive initia­tives, review those find­ings to ensure they are cred­ible, up-to-date, and cover risks specific to your supply chain.

End-user companies — Step 3

Manage risks

• Inform senior manage­ment of the risks iden­ti­fied (e.g. iden­tify priority suppliers; iden­tify smelters and refiners and assess their rela­tive risk levels and corre­sponding due dili­gence actions; docu­ment any infor­ma­tion gaps; and clarify the chain of custody).
• Identify and track which suppliers respond to infor­ma­tion requests and which do not. Follow up with suppliers and esca­late unco­op­er­a­tive suppliers to senior management.
• Disengage from suppliers asso­ci­ated with smelters or refiners that may be contributing to conflict or to the most serious human rights impacts (as defined in Annex II of the OECD Guidance).
• Manage risks of support to public or private secu­rity forces, bribery, money laun­dering, and tax evasion by asking suppliers to put in place measur­able risk-mitigation actions intended to promote progres­sive perfor­mance improve­ment within a reason­able timescale.
• Improve internal risk assess­ment systems over time by tracking imple­men­ta­tion and risk-mitigation measures.
• If the refiner cannot be iden­ti­fied, adopt a risk manage­ment plan to be able to even­tu­ally demon­strate signif­i­cant measur­able improve­ments to your efforts to do so.

End-user companies — Step 4

Audit control point

Support an audit of the smelter, refiner, and/or other key points of trans­for­ma­tion by:

• providing finan­cial resources for inde­pen­dent third-party audits of refiners and smelters
• becoming members of industry programmes or promoting smelter and refiner partic­i­pa­tion in audit programmes
• peri­od­i­cally assessing the quality of industry-led vali­da­tion programmes or inde­pen­dent audits of the smelters or refiners that choose to partic­i­pate in such schemes.

End-user companies — Step 5

Communicate and report on due diligence

• Report publicly on your company’s due dili­gence efforts for respon­sible supply chains of minerals from conflict-affected and high-risk areas each year.
• Reports should focus on the key find­ings from the risk assess­ment and actions taken by the company to address iden­ti­fied risks (e.g. manage­ment systems estab­lished; steps taken to iden­tify smelters and refiners in the supply chain; risk assess­ment method­ology imple­mented; assess­ments conducted to iden­tify smelter and refiner risks and corre­sponding due dili­gence measures in line with the OECD Guidance; steps taken to manage risks; and efforts made to monitor and track perfor­mance for risk mitigation).
• Disclose infor­ma­tion with due regards taken of busi­ness confi­den­tiality and other compet­i­tive concerns (i.e. price infor­ma­tion and supplier relationships).