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).