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.