Miners — Step 1

Establish strong management systems

• 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

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 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).