Developed by

ADVANCING REPORTING ON
RESPONSIBLE MINERAL SOURCING
 Table of Contents
About this toolkit............................................................................ 3 11. Reporting on Due Diligence ............................................. 33
11.1 OECD Due Diligence Guidance for Responsible
Disclaimer........................................................................................... 3 Supply Chains of Minerals from Conflict-Affected and
High-Risk Areas............................................................................. 33
1. List of acronyms and abbreviations.................................... 4 11.2 Information-sharing challenges in the value chain.36
11.3 How can an organization report on due diligence
2. How to navigate this resource............................................. 5 using the GRI Standards?........................................................... 38
11.4 What type of information should be disclosed on
3. Executive summary................................................................... 6 management and due diligence?............................................. 40

4. Background and context for responsible mineral 12. How can organizations report on the impacts that
sourcing .............................................................................................. 7 they are involved with related to sourcing minerals?...... 52
12.1 How can organizations report on adverse impacts
5. What is the global response to social impacts in related to mineral sourcing?..................................................... 54
mineral supply chains?................................................................... 9 12.2 How can companies report on positive impacts
related to mineral sourcing?..................................................... 57
6. How does responsible mineral sourcing contribute to
achieving the SDGs?....................................................................... 11 Appendix A: Key Q&A................................................................. 63

7. What are stakeholder expectations regarding Appendix B: Key terms related to mineral sourcing........ 65
reporting and what is the relevance for business?............ 13
Appendix C: Current state of reporting............................... 71
8. What are governmental expectations and
requirements related to responsible mineral sourcing?.. 16 About GRI.......................................................................................... 73
8.1 Dodd-Frank Wall Street Reform and Consumer
Protection Act............................................................................... 16 About the RMI................................................................................. 73
8.2 EU Mineral Supply Due Diligence Regulation........... 18
8.3 EU directive for disclosure of non-financial and Acknowledgments.......................................................................... 74
diversity information.................................................................... 19
Development of this resource................................................... 75
9. How do we identify material topics related to mineral
sourcing and report on this process?..................................... 23
9.1 How do companies identify whether topics related
to mineral sourcing are material and which minerals
they should cover in reporting?.............................................. 23

10. How can companies report on how they identified

material topics related to mineral sourcing?....................... 28

2
About this toolkit Disclaimer
This toolkit provides guidance primarily to downstream This publication, prepared by GRI and the RMI, is
companies,1 to report effectively on their commitments, intended for general guidance on matters of interest
due diligence, and positive impacts related to mineral only and does not constitute professional advice. No
sourcing in the supply chain, looking specifically at the representation or warranty (express or implied) is given
social impact2 of such activities.3 The guidance draws as to the accuracy or completeness of the information
from internationally recognized frameworks, such as contained in this publication, and, to the extent
the OECD Due Diligence Guidance for Responsible Supply permitted by law, GRI and the RMI, their members (if
Chains of Minerals from Conflict-Affected and High-Risk applicable), employees and agents do not accept or
Areas (OECD Due Diligence Guidance for Responsible assume any liability, responsibility or duty of care for any
Supply Chains), regulatory requirements, the results of consequence of anyone acting, or refraining to act, in
the GRI-RMI Corporate Leadership Group on Reporting reliance on the information contained in this publication
on Responsible Mineral Sourcing (CLG or GRI-RMI or for any decision based on it.
Corporate Leadership Group) organized by GRI and
the Responsible Minerals Initiative (RMI), and voices GRI and the RMI are committed to a multi-stakeholder
from relevant stakeholders including upstream suppliers, approach. This document was created through
smelters and refiners, civil society organizations, and consultation with stakeholders that have specific
socially responsible investors. expertise or interest in responsible mineral sourcing
and public reporting, from a variety of constituencies
The resources in the toolkit can serve companies to including investment institutions, civil society
improve reporting on addressing social impacts related organizations, upstream and downstream supply chain
to minerals sourcing. The document also provides actors, and international multilateral organizations. Any
examples of reporting practices.4 It highlights the benefits expectations shared with us by external stakeholders
of reporting on responsible mineral sourcing, identifies during this consultation process are incorporated in the
common challenges and opportunities and expectations toolkit on an aggregated basis.
of different stakeholder groups. GRI and the RMI
consider best practice in reporting if an organization has GRI and the RMI greatly appreciate the support by the
met stakeholder expectations. The toolkit is not meant government of Sweden, which co-funded this project
to be prescriptive guidance, rather it can be a means through Sida (Swedish International Development
to understand the synergies in stakeholders’ reporting Cooperation Agency).
expectations, including those reflected in the OECD
Due Diligence Guidance for Responsible Supply Chains Copyright © 2019. Stichting Global Reporting Initiative
and the GRI Standards. It is not an exhaustive guide, (GRI). All rights reserved.
given the maturing landscape of reporting expectations If you find this document helpful, we encourage you
and practice. to share a link to it on your own blog or website.
Recommended citation: GRI and the RMI (2019),
In line with the missions of GRI and the RMI, this toolkit Stakeholder expectations and best practices - Advancing
will remain free and publicly available. More information reporting on responsible mineral sourcing. For any other
on the development of this resource can be found here. purpose, please seek prior written permission from GRI.

1  Downstream companies process metals and minerals into finished products, while ‘upstream’ entities are those that extract, process and refine the raw materials
– these include mining companies, raw material traders, smelters and refiners. For an illustration, please see Figure 4. Source: ec.europa.eu/trade/policy/in-focus/
conflict-minerals-regulation/regulation-explained/
2  Social impact refers primarily to impacts covered in the so-called Annex II risks from the OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High Risk Areas.
3  For more information on the scope of this publication in the wider context of responsible sourcing, see Appendix A, What does sourcing responsibly mean with
regard to mineral sourcing?
4  Inclusion of examples from reporting organizations does not imply endorsement by GRI. These examples are included as a means of illustrating current reporting
practice and as a source of inspiration.
3
 1. List of acronyms and abbreviations

CMRT The RMI’s Conflict Minerals Reporting Template

CSO Civil Society Organization
CRT RMI’s Cobalt Reporting Template
CMR Conflict Minerals Reports
CAHRAs Conflict-affected and High-risk Areas
CLG Corporate Leadership Group
Dodd-Frank Act U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502
DRC Democratic Republic of the Congo
EU European Union
Form SD Specialized Disclosure Form
GAAP Generally Accepted Accounting Principles
Guiding Principles UN Guiding Principles on Business and Human Rights
IPSA Independent Private Sector Audit
IFRS International Financial Reporting Standards
IPIS International Peace Information Service
KPIs Key Performance Indicators
OECD Organisation for Economic Co-operation and Development
RCOI Reasonable Country of Origin Inquiry
RMAP Responsible Minerals Assurance Process
RSN Responsible Sourcing Network
SEC Securities and Exchange Commission
Sida Swedish International Development Cooperation Agency
SIQ Smelter Information Questionnaire
SOR Smelter or refiner
3TG Tantalum, tungsten, tin and gold
RMI The Responsible Minerals Initiative
SDGs Sustainable Development Goals
UN PRI UN Principles for Responsible Investment

4
2. How to navigate this resource

While this toolkit is primarily concerned with the reporting expectations for downstream
companies on mineral value chains, the resources, approaches, and tools can be relevant to
companies throughout the value chain, or in other commodity value chains where extraction and
trade are linked to conflict and adverse impacts on human rights.

Background information can be found in the following

sections:

\\ Background and context for responsible mineral

sourcing
\\ What is the global response to issues surrounding
mineral sourcing?
\\ How does responsible mineral sourcing contribute to
achieving the Sustainable Development Goals (SDGs)?
\\ What are stakeholder expectations regarding
reporting?
\\ Regulatory expectations for mineral sourcing

To expand sustainability reporting to include

aspects related to mineral sourcing, organizations
can explore the process to establish whether topics
related to minerals sourcing are material to their
organization. Identifying whether your organization has
significant impacts on the economy, environment, or
society through the mineral value chain and/or whether
the impacts substantively influence your stakeholders’
assessments or decisions indicates whether contents
related to minerals sourcing should be included in
reporting. If existing regulation affects your organization
or entities in your supply chain, reporting may already be
necessary for legal compliance.

This toolkit also contains information that can help

organizations improve current reporting on due
diligence and reporting on the impacts of mineral
sourcing. These sections consolidate the input received
from participants in the GRI-RMI Corporate Leadership
Group on Reporting on Responsible Mineral Sourcing:5
they summarize challenges, provide advice to address
them and present specific disclosures and suggestions
of information to be reported to guide the reporting
process. Reporting examples are presented on pages
with a dark blue border. 

5  Learn more about GRI’s Corporate Leadership Groups here.

5
 3. Executive summary

Although consumers may not realize it, minerals are Further, companies can find resources for reporting on
ubiquitous in everyday products. Minerals such as their due diligence and supportive measures taken, and
tantalum, tungsten, tin and gold (3TG) and cobalt are can select the reporting contents applicable to their
essential components to our mobile phones, computers own sustainability reporting. The reporting contents
and cars. In the past decade, a growing expectation that presented in this toolkit originate from regulations,
companies will respect human rights, labor rights, the international instruments such as relevant OECD
environment, and business ethics in their operations guidance documents, the GRI Standards, reporting
and throughout their supply chains, has drawn more templates such as the RMI’s Conflict Minerals Reporting
attention and made companies in the mineral value chain Template (CMRT) or the Cobalt Reporting Template
identify, cease, prevent, or mitigate, as well as track and (CRT), as well as suggestions made by participants in the
communicate6 the adverse impacts of mineral extraction GRI-RMI Corporate Leadership Group meetings. These
and trade in their value chains, and to publicly disclose contents can be integrated into wider sustainability
actions and outcomes. reporting.

Reporting expectations for businesses are articulated The toolkit also includes a section on information-
in globally recognized frameworks including the UN sharing challenges in the value chain such as business
Guiding Principles on Business and Human Rights and confidentiality. It further supports companies when
the OECD Due Diligence Guidance for Responsible reporting on responsible mineral sourcing with
Supply Chains of Minerals from Conflict-Affected and information to meet specific stakeholder demands for
High-Risk Areas (OECD Due Diligence Guidance for transparency on the actual risks and adverse impacts
Responsible Supply Chains), as well as regulations based that an organization identified, and an indication of
on the latter, including the U.S. Dodd-Frank Wall Street the information needed to respond to interest on the
Reform and Consumer Protection Act, Section 1502 effectiveness of due diligence processes, or progress, as
(Dodd-Frank Act) and the more recent European Union well as on the positive impacts that organizations have.
(EU) Mineral Supply Due Diligence Regulation. However,
the expectation of civil society, investors and other Throughout, the toolkit offers examples of current
stakeholders has moved towards reporting that goes reporting practice and lists of tools that can aid in
beyond complying with regulation. reporting on due diligence, supportive measures and
impacts related to mineral sourcing.
For downstream companies that seek to meet the
expectations of a wide variety of stakeholders, it is
helpful to know how this can done most effectively. The
toolkit explores ways to identify significant impacts and
stakeholder interest. GRI’s concept of materiality brings
into focus how stakeholder interest or significant impacts
render topics related to mineral sourcing as material and
thus should be reported.

6  Pg. 21, http://mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf

6
4. Background and context for responsible mineral sourcing

Responsible mineral sourcing means addressing impacts The DRC has a long history of conflict, and its
of sourcing minerals that lead to negative economic, consequences, particularly smuggling, have tended to
environmental, or social impacts. This can be done spill over into neighboring Uganda, Rwanda, and Burundi.
through a combination of measures, including policies, This has been partly sustained financially by mining in the
due diligence, and remediation. It can also mean making region.9 While the extraction of 3TG greatly contributes
positive contributions in places where the sourcing is to the local economy, it has also fueled conflict and
happening. human rights abuses in the African Great Lakes Region.
Rebel groups and local militias alike have intercepted the
Globally, the natural resources sector plays a significant flow of money via extortion, and used the revenues for
social, economic and political role, accounting for a their activities. By 2014, almost three million civilians had
quarter of global GDP.7 Commodities like diamonds, been displaced from the eastern DRC due to ongoing
gemstones, copper, coal, cobalt, mica, as well as armed conflict;10 and the minerals mined in the region,
tungsten, tantalum, tin and gold (known as 3TG), are particularly 3TG, became widely known as conflict
refined or processed and exported across the world and minerals.11
manufactured into products people use every day. But
their extraction has been linked to funding non-state While not formally considered a conflict mineral, cobalt
armed groups – diamonds and gold in Cote d’Ivoire, has also been linked to human rights abuses in the
gold, tungsten, tantalum, and coal in Colombia, diamonds DRC.12 Largely used in batteries for electric vehicles
in Zimbabwe, gemstones in Myanmar, gemstones, copper and electronic devices, the demand for cobalt is on the
and timber in Afghanistan, and tin, tantalum, tungsten rise: the price has more than tripled since 2016. Half of
and gold in the Democratic Republic of the Congo the world’s supply of cobalt is sourced from the DRC
(DRC).8 and is sometimes linked to child labor in the artisanal
and small-scale mining sector. 13 This means supply
chain due diligence will remain of utmost importance.14,
15
Stakeholder groups have pushed for companies and
governments to address risks in the cobalt supply chain
due to the presence of serious human rights abuses.16

7  http://www.worldbank.org/en/topic/extractiveindustries/overview
8  https://www.globalwitness.org/sites/default/files/GlobalWitnessConflict_ResourcesAndTheirSupplyChains-Logo.pdf
9  http://www.easterncongo.org/about-drc/history-of-the-conflict
10  https://www.globalwitness.org/en-gb/campaigns/conflict-minerals/conflict-minerals-eastern-congo/
11 It should be noted that the term ‘conflict minerals’ refers to the strong potential link of 3TG and other minerals or derivatives to directly or indirectly
contributing to conflict and human rights abuses. International expectations are not to avoid sourcing these minerals, but to ensure that products are conflict-
free, i.e., when sourcing, ensure that they do not contain minerals that directly or indirectly finance or benefit armed groups in the DRC or an adjoining
country. For exact definitions in key references, see Appendix B on key terms. 
12  http://go.asyousow.org/mtd17
13  https://www.amnesty.org/en/documents/afr62/3183/2016/en/
14  https://www.bloomberg.com/news/articles/2018-02-21/apple-is-said-to-negotiate-buying-cobalt-direct-from-miners
15  https://www.bloomberg.com/news/articles/2018-02-15/sweden-hunts-for-cobalt-as-electrical-vehicle-race-boosts-demand
16  https://www.sourceintelligence.com/cobalt-new-conflict-mineral/
7
 Calling for due diligence on minerals value chains is a
global response to the link between resource extraction
and human rights abuses. The past decade has seen the
emergence of international guidance and regulation to
decouple the link between global sourcing of 3TG and
other minerals from perpetuating conflict and human
rights abuses. This toolkit acknowledges the growing
breadth of geographies and commodities linked to
human rights abuses as well – while setting a focus on
reporting on sourcing 3TG from the DRC and adjoining
countries, the contents in this toolkit may inspire
reporting on minerals beyond 3TG and cobalt and from
geographic areas outside of the area.

Mineral sourcing can also lead to environmental impacts

including erosion, deforestation, biodiversity loss,
and water pollution. In the process of gold mining,
for example, mercury emissions into the soil and
water lead to contamination of resources used for
consumption.17, 18 Although this toolkit focuses on social
impacts, environmental impacts should be included in
reporting if they relate to topics that are material for the
organization.

17  https://www.bsr.org/our-insights/blog-view/sustainable-sourcing-of-
minerals-in-the-democratic-republic-of-the-congo
18  http://congomines.org/system/attachments/assets/000/000/349/original/
PACT-2010-%20ProminesStudyArtisanalMiningDRC.pdf?1430928581
8
5. What is the global response to social impacts in mineral supply
chains?

The presence of 3TG and cobalt in everyday items In Europe, the EU Mineral Supply Due Diligence
such as cell phones, computers and cars means that Regulation, passed in 2017, to be enforced in 2021, will
the impacts of mineral sourcing are present in everyday require that upstream companies (EU importers of 3TG
consumer life.19 With growing awareness, activist minerals and metals) follow the five steps of the OECD
organizations, local and international governmental and Due Diligence Guidance for Responsible Supply Chains and
non-governmental bodies, and investors have pushed that EU member states address issues of organizations’
for better governance, ownership of responsibility, and non-compliance.23 Unlike the Guidance, both of these
transparency on the part of the business sector. regulations take a more narrow definition of minerals
within scope, focusing specifically on 3TGs. But as calls
In 2010, the OECD published a global guidance for for transparency in minerals supply chains increase, more
organizations on conducting due diligence and sourcing attention is also being given to the sourcing of minerals
minerals responsibly and reporting the results – the such as cobalt, copper, and mica, and human rights risks
OECD Due Diligence Guidance for Responsible Supply in these supply chains.24, 25, 26 Another example is the
Chains.20 The guidance does not explicitly define a set Kimberley Process, established in the early 2000s to
of ‘conflict minerals’ nor does it focus on the African prevent the trade of conflict diamonds. Understanding
Great Lakes Region, though it does contain specific how responsible sourcing and due diligence processes
supplements for due diligence on tin, tantalum, tungsten, are being applied across minerals, metals, and gemstones
and gold. The Guidance is applicable to all minerals and can lead to greater insight into effective approaches in
includes a global geographic scope, focusing on conflict- different mineral value chains. Future work on this topic
affected and high-risk areas (CAHRAs).21 can help identify opportunities for collaborative action
that is still needed to report how common adverse
Laws such as Dodd-Frank Act of 2010, have also called impacts related to mineral sourcing are addressed.
attention to the issue, recommending that publicly
traded companies employ due diligence systems aligned
with recognized international or national frameworks to
understand whether conflict minerals are present within
their supply chains, to take corresponding actions, and to
report the results.22

19  https://www.fastcompany.com/1726263/regulation-takes-aim-reputation-dodd-franks-conflict-minerals-provision
20  http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
21  CAHRAs are characterized by “…the presence of armed conflict, widespread violence or affected areas and other risks of harm to people. Armed conflict
may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of
liberation, or insurgencies, civil wars, etc. High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil
infrastructure and widespread violence. Such areas are often characterized by widespread human rights abuses and violations of national or international law.”
Http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf, p. 13
22  https://www.sec.gov/opa/Article/2012-2012-163htm---related-materials.html
23  http://ec.europa.eu/trade/policy/in-focus/conflict-minerals-regulation/regulation-explained/
24  http://go.asyousow.org/mtd17
25  https://www.dol.gov/agencies/ilab/resources/reports/child-labor/congo-democratic-republic
26  https://www.responsible-mica-initiative.com/the-mica-issue.html
9
 While the OECD Due Diligence Guidance for Responsible
Supply Chains is applicable to any region, and the adverse
impacts of mineral sourcing are global, regulatory
influence to date has focused efforts on the African
Great Lakes Region. Civil society organizations, such
as Global Witness, have also called attention to other
regions where sourcing is linked to the Annex II risks
described in the OECD Due Diligence Guidance for
Responsible Supply Chains. Much of the work presented
in this toolkit can be extrapolated and applied to any
CAHRAs. These include Colombia, where the sourcing
of gold, tungsten, and tantalum funds armed groups;
Myanmar, where gemstone sourcing is under control
of ‘abusive military forces’; and Afghanistan, where
the sourcing of gemstones, copper, and timber funds
warlords, according to Global Witness.27

10
6. How does responsible mineral sourcing contribute to achieving
the SDGs?
The 2030 Agenda for Sustainable Development and For mineral sourcing, prominent adverse impacts
the Sustainable Development Goals (SDGs) are an are related to conflict minerals and are reflected in
unprecedented opportunity to positively contribute to SDG Target 8, which calls for “sustained, inclusive
environmental and societal challenges and for companies and sustainable economic growth, full and productive
in all sectors to transparently report on their efforts. employment and decent work for all.”30 Specifically,
Historically, mining has been associated with many of the SDG Target 8.7, which calls for “immediate and effective
challenges the SDGs are trying to address – including measures to eradicate forced labor, end modern slavery
environmental degradation, population displacement, and human trafficking and secure the prohibition and
worsening economic and social inequality, armed elimination of the worst forms of child labor, including
conflicts, gender-based violence, tax evasion and recruitment and use of child soldiers, and by 2025 end
corruption, increased risk for many health problems, and child labor in all its forms,”31 refers to issues like forced
human rights violations.28 labor, child labor, and other abuses that are likely to
exist within the mining sectors in CAHRAs around the
Figure I Mineral sourcing linkage to SDGs 8, 12, and 16 world.32 Responsible mineral sourcing is thus a significant
global contributor to reach this SDG target.33

Companies are beginning to understand how the

elimination of adverse impacts related to mineral
sourcing contributes to achieving the SDGs and have
already begun linking this topic to SDGs in their
reporting.29

28  http://unsdsn.org/wp-content/uploads/2016/11/Mapping_Mining_SDGs_An_Atlas.pdf
29  e.g.: Pg. 10, https://h20195.www2.hpe.com/V2/GetDocument.aspx?docname=A00015938ENW
30  https://sustainabledevelopment.un.org/sdg8
31  https://sustainabledevelopment.un.org/sdg8
32  https://www.somo.nl/global-mica-mining/?utm_source=SOMO+Newsletter&utm_campaign=d78d95c017-EMAIL_CAMPAIGN_2018_03_20&utm_
medium=email&utm_term=0_ba1b8b451d-d78d95c017-246499681
33  https://www.freetheslaves.net/wp-content/uploads/2015/03/The-Congo-Report-English.pdf
11
 Figure 2 Extract from Hewlett Packard Enterprise’s (HPE) 2017 Living Progress Report which illustrates how
companies are linking their sustainability strategies and targets to the SDGs34

SDG 12, which aims to “ensure sustainable consumption

and production patterns”,35 also reflects impacts
of mineral sourcing. Sustainable production and
consumption requires collaboration and communication
between the producer and end users across entire
supply chains in order to identify efficiencies and provide
downstream users or consumers with information about
the origin of the raw materials and products they use.36
Promoting human rights due diligence and transparent
reporting of impacts can be seen as a responsible
sourcing approach that helps to promote more
sustainable consumption and production in the mining
sector.

Further, SDG 16, which calls to “promote peaceful and

inclusive societies for sustainable development, provide
access to justice for all and build effective, accountable
and inclusive institutions at all levels”,37 is relevant to
mineral sourcing. Particularly SDG Target 16.4, which
calls to “significantly reduce illicit financial and arms
flows, strengthen the recovery and return of stolen
assets, and combat all forms of organized crime” by
2030.38 Increased transparency and due diligence will
contribute towards this goal by highlighting areas and
mines controlled by arms groups, avoiding illicit transfers
of funds to such groups, ensuring transparent reporting
of revenue flows, and supporting the involvement of
citizens and communities in extractives development.39

34  https://h20195.www2.hpe.com/v2/Getdocument.aspx?docname=a00048490enw
35  https://sustainabledevelopment.un.org/sdg12
36  http://unsdsn.org/wp-content/uploads/2016/11/Mapping_Mining_SDGs_An_Atlas.pdf
37  https://sustainabledevelopment.un.org/sdg16
38  https://sustainabledevelopment.un.org/sdg16
39  http://unsdsn.org/wp-content/uploads/2016/11/Mapping_Mining_SDGs_An_Atlas.pdf
12
7. What are stakeholder expectations regarding reporting and
what is the relevance for business?

Regulators, investors, consumers, and other stakeholders Investors are also demanding information.44, 45 For
have certain expectations regarding responsible minerals example, In 2014, a number of investors expressed
sourcing and request transparency for their informed their support of an EU Mineral Supply Due Diligence
decision-making. Meeting these expectations is one Regulation, asking for any new regulation to be
important driver for companies to report how they harmonized with the Dodd-Frank Act.46 Further, when
address actual and potential impacts, through due Section 1502 of the Dodd-Frank Act was being revisited
diligence and supportive measures. Further, collecting by the US government in 2017, 127 investors and
data to meet stakeholder information expectations helps investor groups voiced their support for Section 1502,
companies to successfully manage compliance, supply, pointing to the positive changes it had contributed to by
and reputational risk, among others. diminishing revenue flows to non-state armed groups.
In a letter addressed to the United States Securities
Global expectations regarding respect for human rights, and Exchange Commission (SEC), the investor groups,
for example those included in the UN Guiding Principles with a collective $4.8 trillion in assets, describe how
on Business and Human Rights (Guiding Principles) for conflict minerals due diligence is material to them as
reporting on the adverse impacts related to human it helps them assess social and reputational risks in an
rights issues,40, 41 are relevant for companies’ sourcing organization’s supply chain, and assess an organization’s
activities for minerals from conflict-affected and high- efforts to mitigate mineral supply risks.47 Examples of
risk areas. In implementing the UN’s ‘Protect, respect, reports and campaigns that outline investor expectations
and remedy’ framework,42 the Guiding Principles ask can be seen in the Box A below.
companies to identify their impacts on human rights,
take concrete actions to address them, implement Box A Investor expectations
measures to mitigate adverse impacts in the future,
•  Investor Alliance for Human Rights (IAHR): Investor
and communicate43 how impacts are addressed. For Expectations on Conflict Mineral Reporting
example, Principle 17 of the UN Guiding Principles
•  Triodos: Responsible sourcing of minerals
asks companies to conduct human rights due diligence
engagement
processes and, where necessary, address adverse impacts
which the business may cause, contribute to or can be •  Tri-State Coalition for Responsible Investment (TRI-

directly linked to as a result of “businesses’ own activities CRI): Shifting Gears Campaign
or as a result of their business relationships with other •  UN Principles for Responsible Investment (PRI):
parties” (Principle 13). Drilling Down into the Cobalt Supply Chain: How
Investors Can Promote Responsible Sourcing
Practices

40  http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
41  https://www.shiftproject.org/media/resources/docs/Shift_MaturityofHumanRightsReporting_May2017.pdf
42  https://www.business-humanrights.org/en/un-secretary-generals-special-representative-on-business-human-rights/un-protect-respect-and-remedy-framework-
and-guiding-principles
43  Pg. 17, http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
44  https://investorsforhumanrights.org/sites/default/files/attachments/2018-06InvestorExpectationsConflictMineralReporting_5.31.18_FINAL.pdf
45  https://www.unpri.org/social-issues/how-investors-can-promote-responsible-cobalt-sourcing-practices/2975.article
46  https://www.actiam.nl/nl/verantwoord/Documents/Land/Investor-statement-on-EU-conflict-minerals-legislation.pdf
47  http://news.bostoncommonasset.com/wp-content/uploads/2017/03/Conflict-Minerals-Rule-Investor-Statement-Submission-3-7-17.pdf
13
 “As part of industry working groups, including one set A growing number of resources and publications
up by the Principles for Responsible Investment, we are becoming available to these audiences – beyond
collaborated to encourage the expansion of disclosure individual company reports – that analyze and evaluate
beyond the requirements of the Dodd-Frank Act how companies report on their mineral due diligence
[…] One software giant, for example, acknowledged efforts. Examples of evaluative studies can be found in
that additional reporting and further discussion on the Box B below.
this issue, internal as well as external, was warranted.
The company substantially improved its disclosure Box B Evaluative studies analyzing current reporting
and committed to adhering to industry best practice practices
on conflict minerals in its supply chain. After gaining •  Amnesty International: Time to Recharge (2017)
significant reassurance about the extensive supply •  Enough Project: Conflict Minerals Rankings (2010,
chain management procedures the company has in 2017)
place, we met our engagement objective. Another •  Development International: Conflict Minerals Issuer
consumer technology leader pioneered supply chain Evaluations (2015, 2016, 2017, 2018)
transparency especially in cobalt and acknowledged •  Global Witness: Time to Dig Deeper (2017)
that mining communities are especially vulnerable •  Know the Chain: Company Benchmarks
to human rights violations. Building on their existing •  Responsible Sourcing Network (RSN): Mining the
community work, we hope to see that on the ground Disclosures (2015, 2016, 2017, 2018)
social impact data be better integrated into their
supply chain management process and is reflected in
their supplier progress report.”

HERMES EQUITY OWNERSHIP SERVICES OF

HERMES INVESTMENT MANAGEMENT

Many companies have committed to responsible sourcing

to match their peers and to respond to the expectations
of a more sustainability-focused market,48 as civil society
organizations and consumers have also taken an interest
in the impacts of mineral sourcing and companies’
efforts in responsible sourcing in general or minerals due
diligence in particular. Some companies, like Fairphone,
have built their business models on creating socially
sustainable supply chains, including responsibly-sourced
minerals.49, 50 In the jewelry sector, companies such as
Brilliant Earth and JEM sell traceable, responsibly-sourced
diamonds and gold.51, 52 Consumers also have higher
access to information – organizations like the Enough
Project have made it easier for consumers to be more
discerning by ranking the efforts of consumer electronics
and jewelry companies on criteria including conducting
mineral due diligence across value chains and reporting.53

48  https://www.washingtonpost.com/business/economy/why-apple-and-intel-dont-want-to-see-the-conflict-minerals-rule-rolled-back/2017/02/23/b027671e-f565-
11e6-8d72-263470bf0401_story.html?utm_term=.b94d0ae817d9
49  https://www.fairphone.com/en/
50  https://tonyschocolonely.com/nl/nl
51  https://www.brilliantearth.com/conflict-free-diamonds/
52  http://www.jem-paris.com/en/world_of_jem/commitments
53  Find more information on the methodology, evaluation criteria, and company responses here: https://enoughproject.org/demandthesupply?utm_
source=shares&utm_campaign=Rankings2017
14
Industry organizations have also articulated their
own mineral supply chain due diligence standards
and expectations for reporting via the development
and evolution of mineral/metal specific supply chain
standards. Examples of voluntary industry standards
related to responsible mineral sourcing and reporting on
due diligence can be found in Box C below.

Box C Examples of industry expectations on

responsible mineral sourcing and reporting
•  Aluminium Stewardship Initiative Performance
Standard (2017)
•  CRAFT (Code of Risk-mitigation for ASM engaging
in Formal Trade) Standard (2018)
•  Initiative for Responsible Mining Assurance (IRMA)
Standard for Responsible Mining (2018)
•  International Council on Mining and Metals
(ICMM) Performance Expectations (Performance
Expectation 10) (2018)
•  International Tin Association, Code of Conduct
•  London Bullion Market Association (LBMA)
Responsible Gold Guidance (2018)
•  Responsible Jewellery Council (RJC) Chain of
Custody Certification (2017), Code of Practices
Certification (2019)
•  RMI Standards for Tin, Tantalum, Tungsten, Gold, and
Cobalt
•  World Gold Council: Conflict-Free Gold Standard
(2012)

Appendix C contains more information on several

evaluative studies that have analyzed current practices
related to responsible minerals sourcing and reporting
from different entities in the mineral value chain. It
looks at reporting practices vis-à-vis the company’s
implementation of the five steps outlined in the OECD
Due Diligence Guidance for Responsible Supply Chains
and/or based on criteria related to environmental and
social impacts, such as worker safety or environmental
impact assessments. Findings across the studies and
across value chain entities (downstream reporters,
smelters and refiners, mineral exporters, and small and
mid-tier mining companies) demonstrate an overall lack
of reporting, especially when it comes to disclosing
information on due diligence processes.

15
 8. What are governmental expectations and requirements
related to responsible mineral sourcing?

While not legally binding, the OECD Due Diligence Guidance for Responsible Supply Chains has been
widely adopted as a recommended framework by certification schemes and regulatory instruments.
International attention to the adverse impacts of mineral sourcing has led to legislation, namely
the Dodd-Frank Act and the EU Mineral Supply Due Diligence Regulation. These will be presented
in this chapter, along with the EU Non-Financial Reporting Directive, with a particular focus on
reporting expectations. Both the Dodd-Frank Act and the EU Mineral Supply Due Diligence
Regulation reference and uphold the OECD Due Diligence Guidance for Responsible Supply Chains.

8.1 Dodd-Frank Wall Street Reform and ii. Any other mineral or its derivatives determined
Consumer Protection Act by the Secretary of State to be financing conflict
in the Democratic Republic of the Congo or an
What is it and what is its purpose? adjoining country.”54
The Dodd-Frank Act was signed into U.S. federal law
in 2010, bringing about significant changes to financial The EU Mineral Supply Due Diligence Regulation has
regulation. Section 1502 of this Act, also known as the taken a similar definition.55
Conflict Minerals Provision, requires public companies
in the United States to determine whether 3TG
‘conflict minerals’ from the DRC and/or nine adjoining
countries are present in their supply chains through
appropriate supply chain due diligence using a recognized
international framework like the OECD and then to
disclose this to the SEC using a Specialized Disclosure
Form (Form SD).

The purpose was to identify the risk of sourcing conflict

minerals and dissuade companies from continuing to
engage in trade supporting armed conflict. Section
1502 was made applicable to all SEC issuers (including
foreign issuers) that manufacture or are contracted to
manufacture products that use conflict minerals.

Section 1502’s defines the term ‘conflict mineral’ to

mean:
i. “Columbite-tantalite (coltan), cassiterite, gold,
wolframite, or their derivatives, which are limited
to tantalum, tin, and tungsten, unless the Secretary
of State determines that additional derivatives are
financing conflict in the Democratic Republic of
the Congo or an adjoining country; or

54  https://www.sec.gov/rules/final/2012/34-67716.pdf, pg. 352. An adjoining country is defined as any state that shares an internationally recognized border with
the DRC.
55  http://ec.europa.eu/trade/policy/in-focus/conflict-minerals-regulation/regulation-explained/
16
What companies are in scope of this regulation? Application of OECD Due Diligence Guidance
The industries that are most affected by the regulation for Responsible Supply Chains to Section 1502
due to their use/applications of 3TG are electronics, requirements
communications, aerospace, automotive, jewelry, and The RMI Five Practical Steps for Conflict Minerals
industrial products.56 Due Diligence and SEC Disclosure describes the
steps companies should take to fulfil Dodd-Frank
At its conception, Section 1502 aimed to make a obligations using the OECD Due Diligence Guidance for
significant positive impact to break the link between Responsible Supply Chains. The latter are much broader
the minerals trade and armed conflict in the DRC than the SEC requirements. Most critically, the definition
and adjoining countries. While there is no regulatory of due diligence differs between the two.
penalty for companies that choose not to conduct due
diligence on their 3TG supply chains, companies that While the SEC ruling defines it as the measures an
do not disclose may be punished by the market. In the issuer takes to “exercise due diligence on the source
spring of 2017, enforcement of part of Section 1502 was and chain of custody of those conflict minerals”60, the
retracted, risking a reversal of the progress achieved in OECD describes it as an “on-going, proactive, and
promoting responsible mineral sourcing practices in the reactive process through which companies can identify,
DRC region.57 Following this ruling, both the quality of prevent, mitigate, and account for how they address
disclosures and the number of Specialized Disclosure their actual and potential adverse impacts as an integral
Forms fell compared to previous years, according to a part of business decision-making and risk management
study by the Responsible Sourcing Network (RSN).58 systems.”61 Once more, in the OECD framing, due
The lack of regulatory enforcement means companies diligence is broader, focusing on a continued engagement
are less likely to report – however, companies in sectors with suppliers, going beyond due diligence as a tool to be
that are more prevalent in consumers’ everyday lives, used for legal compliance.62
such as the technology and jewelry sectors, have stated
that their reporting on their efforts in addressing conflict A study conducted by Development International
minerals issues will continue.59 found that there were many gaps across the quality of
Conflict Minerals Reports (CMR) filings in 2016. While,
“Issues around raw material sourcing and responsible
on average, compliance with SEC rules was quite high,
procurement of minerals and metals have become
alignment with the OECD’s Guidance showed room for
more prominent in recent years. For our signatories
improvement.63
and their long-term approach to value appreciation
in their portfolios, assessing information around
these topics as part of the investment decision-
making process has become increasingly important.
Compliance with all applicable regulation and going
beyond the basic requirements in reporting has
become a crucial step that is reviewed in decision-
making processes within investment communities.”

UN PRINCIPLES FOR RESPONSIBLE INVESTMENT

(UN PRI)

56  http://www.ey.com/Publication/vwLUAssets/EY_CnflictMinerals/$FILE/EY_ConflictMinerals.pdf
57  https://www.reuters.com/article/us-usa-trump-conflictminerals/white-house-plans-directive-targeting-conflict-minerals-rule-sources-idUSKBN15N06N
58  https://www.sourcingnetwork.org/mining-the-disclosures-2018
59  https://www.sourcingnetwork.org/blog/2017/12/6/when-theyre-not-worried-about-regulations-companies-arent-worried-about-conflict-minerals-disclosures
60  https://www.sec.gov/files/formsd.pdf
61  http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
62  https://docs.wixstatic.com/ugd/f0f801_f9f01edf6f7644778e729bb8f295ad56.pdf
63  https://docs.wixstatic.com/ugd/f0f801_f9f01edf6f7644778e729bb8f295ad56.pdf
17
 8.2 EU Mineral Supply Due Diligence mirror the five steps outlined in the OECD Due Diligence
Regulation Guidance for Responsible Supply Chains:
“The due diligence framework requires responsible importers
What is it and what is its purpose? of the mineral and metal within the scope of the Regulation
In May 2017, the EU signed the EU Mineral Supply Due to establish a strong company management system; to
Diligence Regulation (Regulation 2017/821) into law, identify and assess risks in the supply chain; to design and
to come into effect on January 1, 2021. The regulation implement a strategy to respond to identified risks; to carry
requires that EU importers of 3TG meet international out independent third-party audits of supply chain due
responsible sourcing standards, such as those set out diligence at identified points in the supply chain; and to
by the OECD Due Diligence Guidance for Responsible report on supply chain due diligence.
Supply Chains, with the aim of stemming the flow of
minerals that fund conflict. The European Commission In addition, responsible importers of those minerals and
will develop and maintain a list of conflict-affected metals are required to make available on an annual basis,
and high-risk areas, although individual companies are where applicable, the identity of all smelters and/or refiners
still responsible for conducting their own analysis and supplying them, as well as to provide independent third-
applying due diligence accordingly.64 party audit assurances and pass them on to Member States’
competent authorities and to downstream purchasers, with
What companies are in scope of this regulation? due regard to business confidentiality and other competitive
The EU Mineral Supply Due Diligence Regulation will concerns.”67
affect organizations that import tin, tungsten, tantalum,
or gold minerals and metals in volumes above a certain Supply chain due diligence in the context of this
threshold into the EU, no matter where they originate. regulation is also explicitly defined as an “ongoing,
An estimated 600 to 1000 importers in the EU will be proactive and reactive process through which economic
directly affected, and a further 500 smelters and refiners operators monitor and administer their purchases and
of 3TG inside and outside of the EU will be indirectly sales with a view to ensuring that they do not contribute
touched by the rules.65 to conflict or the adverse impacts thereof.”68

EU member states are responsible for enforcing the This regulation establishes that the EU will consult
regulation and investigating non-compliance. The with the OECD to publish an annual list of responsible
European Commission’s guidance indicates that if a smelters and refiners whose sourcing processes are
Member State finds an EU importer in non-compliance, compliant, based on data collected from disclosures.69
it will need to order the importer to address the non-
compliance within a given deadline (chosen by the Overall, the regulation has been positively received,
Member State) and follow up to ensure compliance.66 although stakeholders have pointed out shortcomings.
Global Witness, for example, has said it does not address
Application of OECD Guidance to EU Directive minerals and metals imported into the EU in finished
requirements components and products, and that it sends a mixed
The EU directive goes further than Section 1502 of the message to smaller companies that seem to be exempt
Dodd-Frank Act by specifically requiring the use of OECD from due diligence according to the text.70
Due Diligence Guidance for Responsible Supply Chains for
conducting due diligence; the requirements listed directly

64  http://ec.europa.eu/trade/policy/in-focus/conflict-minerals-regulation/regulation-explained/
65  http://ec.europa.eu/trade/policy/in-focus/conflict-minerals-regulation/regulation-explained/
66  http://ec.europa.eu/trade/policy/in-focus/conflict-minerals-regulation/regulation-explained/
67  http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52014PC0111
68  http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R0821
69  http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52014PC0111
70  https://www.globalwitness.org/en/blog/why-eus-new-deal-responsible-mineral-sourcing-missed-opportunity/
18
8.3 EU directive for disclosure of non-financial Tools and resources: Further references
and diversity information Several law firms have developed resources for
understanding these regulations: e.g., Dodd-Frank
What is it and what is its purpose? flowchart and EU Mineral Supply Due Diligence
The EU Non-Financial Reporting Directive (Directive Regulation flowchart.
2014/95/EU) provides rules for disclosing on non-
financial topics like environmental and social aspects,
anti-corruption, and diversity. Since 2018, certain
companies are required to publish non-financial
statements in their annual reports.71 The key
performance indicators (KPIs) used to report on these
topics are at the discretion of the reporting organization,
although the EU published non-binding guidelines on
non-financial reporting and KPIs in June 2017.72 These
Guidelines on non-financial reporting include reporting
KPIs for companies on conflict minerals:

A. the proportion of direct relevant suppliers having

adopted and implemented a conflict minerals due
diligence policy consistent with the OECD Due
Diligence Guidance for Responsible Supply Chains
B. the proportion of responsibly sourced tin,
tantalum, tungsten or gold originating in conflict-
affected and high-risk areas
C. the proportion of relevant customers
contractually requiring conflict minerals due
diligence information under the OECD Due
Diligence Guidance for Responsible Supply Chains

The European Commission released a methodology for

reporting non-financial information, based on its review
of the OECD Due Diligence Guidance for Responsible Supply
Chains and the five-step framework.73

Which companies are in scope of this directive?

This directive applies to large public-interest companies
with more than 500 employees operating in the EU.
Approximately 6,000 companies in the EU need to
report according to this directive, including listed
companies, banks, and insurance companies.

71  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014L0095
72  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017XC0705(01)
73  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017XC0705(01)
19
20
As Table I shows, there is significant alignment in
reporting requirements across these frameworks. It is
important to note that as sourcing/trading risks and
adverse impacts become identified and communicated
regarding other mineral supply chains, regulations or
other government policy tools may begin to encompass
minerals beyond 3TG.74

Table I Description of relevant regulatory instruments on conflict minerals

EU Minerals Supply Chain Due Diligence EU Non-Financial Reporting
Dodd-Frank Act Section 1502
Regulation Directive
Law / Dodd-Frank Wall Street Reform and Regulation (EU) 2017/821 of the European EU Directive:
Regulation Consumer Protection Act Section 1502 Parliament and of the Council laying down
(July 2010) supply chain due diligence obligations for Guidelines on non-financial
Union importers of tin, tantalum and reporting
tungsten, their ores, and gold originating (Guidance created for
from conflict-affected and high-risk areas understanding type of information
(May 2017) that can be reported, June 2017)

Affiliated SEC Final Rule (August 2012) Non-binding guidelines for the identification
documents of conflict-affected and high-risk areas and
FAQ Conflict Minerals (May 2013 / April other supply chain risks (August 2018)
2014)
The European Commission will release
Partial Stay of the Conflict Minerals Rule an online platform where downstream
(May 2014) companies can voluntarily share information
on their due diligence for metals and
SEC Statement on the Conflict Minerals minerals.
Rule and Court Decision (April 2014)
Reporting Required reporting from May 31, 2014 January 1, 2021 2018
date Entered into force in 2014, with
Note: The European Commission encourages first filings due in 2018 covering
all companies the regulation covers to start the 2017 financial year.
carrying out due diligence before this date.

Applicability Mandatory for all companies, foreign Upstream companies must comply with Mandatory for large public-interest
and domestic, that file with the U.S. mandatory due diligence rules companies (e.g., listed companies,
SEC (publicly traded companies) and banks, insurance companies) with
manufacture or contract to manufacture Downstream companies fall into two more than 500 employees
any product for which 3TG are categories:
necessary for the functionality of the - those importing metal-stage products into
product. the EU must comply with mandatory due
diligence rules
- those operating beyond the metal stage do
not have obligations under the regulation;
but they are expected to use reporting
and other tools to make their due diligence
transparent, including, for example, under the
non-financial reporting directive
Materials / Ores and concentrates containing tin, Ores and concentrates containing tin, Ores and concentrates containing
metals tantalum or tungsten, and gold tantalum or tungsten, and gold tin, tantalum or tungsten, and gold

Exceptions Investment companies that are required The Regulation does not apply to EU
to file reports under the Investment importers who import less than a certain
Company Act are not subject to the amount and recycled metals or stocks
rule. created before 1 February 2013.
Minerals’ Countries that have an internationally Conflict-affected and high-risk areas (global) Conflict-affected and high-risk
countries recognized border with DRC and areas (global)
of origin include Angola, Burundi, Central African
addressed in Republic, Republic of the Congo,
the regulation Rwanda, South Sudan, Tanzania, Uganda,
74  Reporting according
and to information included in this publication does not imply compliance with regulation.
Zambia.
21
 Due Diligence Requires companies to annually Requires importers of minerals and metals Companies are expected to disclose
Requirement disclose whether any conflict to put in place management systems to relevant information on due diligence
Summary minerals that are necessary to support their due diligence, to ensure responsible supply chains for
the functionality or production conduct supply chain due diligence, manage tin, tantalum, tungsten and gold from
of a product originated in the identified risks and provide specified conflict-affected and high-risk areas.
Democratic Republic of the Congo information to their immediate
or an adjoining country and, if so, to customers, in line with the OECD Due Disclosures should be consistent with
provide a report describing, among Diligence Guidance for Responsible Supply the OECD Due Diligence Guidance for
other matters, the measures taken Chains. Responsible Supply Chains, including its
to exercise due diligence on the supplements. Companies are expected
source and chain of custody of those Importers must, on an annual basis, to disclose relevant information on the
minerals. publicly report as widely as possible on performance of their policies, practices
their supply chain due diligence policies and and results on conflict minerals due
practices for responsible sourcing, including diligence. They should also disclose the
a summary of any third-party audit that is steps taken to implement the ‘five-step
commissioned. framework’ for risk-based due diligence
in the mineral supply chain as set out
in the OECD Due Diligence Guidance
for Responsible Supply Chains, taking
into account their position in the supply
chain.

Companies are then expected to

disclose KPIs relating to the nature and
number of risks identified, the measures
taken to prevent and mitigate these
risks; and to how the company has
strengthened its due diligence efforts
over time.
What Description of the products •  Description of the mineral, including its •  Proportion of responsibly sourced
needs to be containing 3TG, the facilities used trade name and type; tin, tantalum, tungsten or gold
reported: to process 3TG, the country of •  Country of origin of the minerals; originating in conflict-affected and
Description of origin of the 3TG, and the efforts to •  Quantities and dates of extraction, high-risk areas
mineral determine the mine or location of if available, expressed in volume or
origin. weight;
•  Where minerals originate from conflict-
affected and high-risk areas or, where
other supply chain risks as listed in the
OECD Due Diligence Guidance for
Responsible Supply Chains have been
ascertained by the Union importer,
additional information is required.
What A description of the measures the Supply chain due diligence policies and •  Proportion of direct relevant
needs to be company has taken to exercise practices for responsible sourcing, the suppliers having adopted and
reported: due diligence on the source and report must contain the steps taken for implemented a conflict minerals due
Description of chain of custody conflict minerals, management systems, risk management, diligence policy consistent with the
due diligence which must conform to a nationally and summary reports of the third-party OECD Due Diligence Guidance for
or internationally recognized due audits. Responsible Supply Chains
diligence framework. •  Proportion of relevant customers
contractually requiring conflict
minerals due diligence information
under the OECD Due Diligence
Guidance for Responsible Supply
Chains
Enforcement In 2014, the SEC provided guidance Each EU Member State must check Each EU Member State should ensure
that indicated that the Independent whether EU importers comply with the that adequate and effective means
Private Sector Audit requirement is regulation. exist to guarantee disclosure of non-
not necessary unless the company financial information by undertakings in
labels its products ‘DRC Conflict Member States’ authorities will examine compliance with the Directive.
Free’ in its Conflict Minerals Report. documents and audit reports. If needed,
they can carry out on-the-spot inspections EU Member States should ensure that
As of 2015, companies are of an importer’s premises. effective national procedures are in
not required to use explicit place to enforce compliance with the
determination labels (e.g., ‘DRC If a Member State finds an EU importer obligations outlined in this Directive,
Conflict Free’) for the 3TG in their has not complied with the regulation, it and that those procedures are available
products. will order the firm to address the problem to all persons and legal entities having
within a given deadline and follow-up to a legitimate interest, in accordance
In 2017, the SEC’s Division of make sure it does so. with national law, in ensuring that
Corporation Finance announced that the provisions of the Directive are
it will not recommend that the SEC respected.
bring enforcement actions against
companies that do not comply with
22 the disclosure requirements.
9. How do we identify material topics related to mineral sourcing
and report on this process?

Stakeholders benefit from clear and transparent reporting on how organizations address
sustainability impacts related to mineral sourcing. Reporting can inform stakeholders about an
organization’s policies, processes, progress, and outcomes related to various topics.

GRI’s Reporting Principles can help an organization identify the impacts that its activities have or
which topics are of interest to stakeholders – and should be reported. Section I of this chapter
describes how an organization can determine whether topics related to responsible mineral sourcing
are material and should be reported, while Sections II and III present how information on this
process can be communicated using the GRI Standards and the value of this exercise.

9.1 How do companies identify whether topics Figure 3 shows how these two dimensions mentioned in
related to mineral sourcing are material and the Materiality principle can indicate if mineral sourcing
which minerals they should cover in reporting? should be considered a material topic. A topic is material
if it substantively influences stakeholders’ assessments
Companies should first understand how GRI defines and decisions OR if an organization has significant
materiality, and how the concept can be applied to impacts related to the topic through its operations or
identify which information related to mineral sourcing value chain. Each organization determines the threshold
should be covered in reporting. at which a topic is material – this exercise can also help
clarify the topic’s relevance relative to other sustainability
Understanding how material topics are defined topics the organization is considering.
According to GRI 101,75 material topics (topics that
define the contents that need to be reported) are those Figure 3 Materiality Matrix: A matrix with two
that: dimensions of materiality can be used to illustrate
\\ “Reflect the reporting organization’s significant
whether topics related to mineral sourcing are material,
economic, environmental, and social impacts; or
by plotting these among other sustainability topics,
\\ Substantively influence the assessments and decisions
according to influence on stakeholders’ decisions and
of stakeholders,”
significance of impacts on the economy, environment,
In the GRI Standards, “impact’ refers to the effect an and society.
organization has on the economy, the environment, and/
or society, which in turn can indicate its contribution
(positive or negative) to sustainable development.”
Impact can be positive, negative, actual, potential, direct,
indirect, short-term, long-term, intended, or unintended.

75  GRI 101: Foundation (2016)1.3 Materiality, pg. 10

23
 GRI’s Materiality principle reflects the interests of a “In the past few years, Microsoft has received fewer
wide range of stakeholders (“employees, shareholders, stakeholder requests related to 3TGs because our
suppliers, vulnerable groups, local communities, and Conflict Minerals Report answers the majority of their
NGOs or other civil society organizations, among questions. In the meantime, stakeholder interest in
others”76), and is wider than the definition of materiality responsible sourcing has focused on a broader range
used across various financial accounting standards, of raw materials. We’ve responded to this interest
including, for example, the International Financial through greater transparency about the raw materials
Reporting Standards (IFRS) and Generally Accepted critical to our operations in our Devices Sustainability
Accounting Principles (GAAP), which focuses on Report. We will continue providing stakeholders
stakeholders with financial interests as the primary target increased transparency as we advance our programs in
group.77 this area.”

For more information on Materiality and other Principles MICROSOFT
for defining report content in the GRI Standards see
page 7ff in GRI 101: Foundation (2016). In many cases the topics that relate to an organization’s
significant impacts and those important to stakeholders
Ways to identify whether topics related to mineral may overlap, though not always. For instance, a topic can
sourcing are material, and which minerals to cover become material if stakeholders believe it is critical in the
In determining which topics related to mineral sourcing sustainability space, even if an organization has assessed
are material, an organization should identify the impacts that the impacts related to the topics are not significant.
– both positive and negative – that stem from mineral The GRI Standards require the inclusion of such a topic
sourcing and assess their significance (the first dimension in reporting, giving the company an opportunity to
for identifying material topics). In general, ‘significant explain to stakeholders the prioritization for inclusion of
impacts’ are those that are a subject of established certain minerals based on factors including the amount
concern for expert communities, or that have been of minerals used, leverage within the supply chain, and
identified using established tools, such as impact potential for negative impacts.
assessment methodologies or life cycle assessments.

Identifying whether mineral sourcing-related topics are

considered by stakeholders to influence their decisions
and assessments is part of the second dimension
described in the Materiality principle.78 Stakeholder
interest in a topic may be a result of new regulations on
the topic – in this case, the topic would be considered
material and would need reporting.

76  GRI 101: Foundation (2016)1.1 Stakeholder Inclusiveness, pg. 8

77  “Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions that the primary users of general purpose
financial statements make on the basis of those financial statements, which provide financial information about a specific reporting entity” See https://www.ifrs.
org/news-and-events/2018/10/iasb-clarifies-its-definition-of-material/
78  GRI 101: Foundation (2016)1.3 Materiality, pg. 10
24
 Box D Useful resource for understanding impacts of sourcing related to specific minerals/materials
The 2018 Material Change Report, developed through a partnership between the RMI and Drive Sustainability, and produced
by the Dragonfly Initiative, focuses on the electronics and automotive sectors, identifying the minerals most commonly used
in those sectors and the related impacts. The ‘Materials heat map’ developed for the report (pp. 36-37) helps understand the
types of impacts and the strength of the ‘hotspots’ that result from sourcing these minerals and can inform the assessment of
the significance of impacts resulting from sourcing certain minerals. See here a snapshot of this heat map displaying impacts of
sourcing a range of minerals and intensity of these impacts.

Materials heat map key

Materials heat map Not Applicable
N/A
Missing Data
MD
Low Moderate High Very high

Importance to Industry

Industry consumption Function criticality Residual end-of-life waste Virgin material consumption Estimated rate of depletion

Mineral /Material Automotive Electronic Automotive Electronic Automotive Electronic Automotive Electronic Automotive Electronic Mineral /Material
Aluminium / Bauxite Aluminium / Bauxite

Antimony Antimony

Beryllium Beryllium

Bismuth Bismuth

Chrome & Chromium MD MD MD MD Chrome & Chromium

Cobalt Cobalt

Copper Copper

Gallium Gallium

Germanium Germanium

Glass (silica sand) MD MD MD Glass (silica sand)

Gold  Gold 

Graphite (natural) Graphite (natural)

Indium  MD Indium 

Lead Lead

Leather* N/A N/A N/A MD N/A N/A N/A Leather*

Lithium Lithium

Magnesium MD Magnesium

Manganese Manganese

Mica MD MD MD MD MD MD Mica

Molybdenum Molybdenum

Nickel  Nickel 

Niobium MD Niobium

Palladium Palladium

Plastics MD MD MD MD MD MD MD Plastics

Platinum Platinum

Rare earth elements** Rare earth elements**

Rhodium Rhodium

Rubber (natural)* N/A N/A N/A N/A N/A N/A Rubber (natural)*

Ruthenium MD MD MD Ruthenium

Silver Silver

Steel / Iron Steel / Iron

Tantalum MD Tantalum

Tin Tin

Titanium Titanium

Tungsten Tungsten

Vanadium MD N/A N/A N/A N/A N/A Vanadium

Zinc Zinc

Figure 5
*Leather and rubber are sometimes found in the accessories of electronics products, such as watch straps or smartphone cases and covers and 1% of rubber is consumed by
electronics industry globally across all product ranges.. The electronics industry’s consumption of leather and rubber is tiny and they do not perform a critical functions for The “hotspots” in this heat map draw attention to potential issues associated with the production of a material, but do not imply a definitive measure of risk or impact.
any electronics product and they are therefore rated as non ‘applicable’ for their importance to the electronics industry. The use of this report and information in this report is covered by the conditions of a Creative Commons-Attribution-NonCommercial-NoDerivative Works License.
**Praseodymium, Cerium, Dysprosium, Gadolinium, Neodymium, Samarium, Terbium, Yttrium Please always credit the Responsible Minerals Initiative, Drive Sustainability and The Dragonfly Initiative for the work they have done compiling and analysing this information.

In practice, mineral sourcing is referred to or Gauging impacts:

integrated in other sustainability topics in different \\ Where in the supply chain do impacts occur?

ways. “Responsible sourcing and lifecycle impacts”,79 \\ Which sourced minerals should we assess in terms of

“responsible sourcing of minerals”80, and “conflict their economic, environmental, and social impacts?
minerals in products”81 are examples of terms that \\ What impacts result from mineral sourcing in our

reporting organizations currently use. These generalized supply chain?

titles can capture a wide range of minerals and related \\ What is our ability to have leverage over this issue?

impacts, although the significance of impacts may differ

from mineral to mineral. Further, some companies may * During the GRI-RMI Corporate Leadership Group
identify impacts of mineral sourcing that relate to topics (CLG) on reporting on responsible minerals sourcing,
covering environmental issues, human rights issues such participants gave examples of how they identify impacts,
as child labor, or occupational health and safety. including:
\\ Conducting media scans to identify risks or impacts:

In identifying material topics to report on, an This has long been a staple of the compliance officer’s
organization may face practical questions depending on toolkit, but can now be used as part of the CSR
experience with the topic: manager’s toolkit, to monitor and address issues, like
those classified as having adverse impacts on human
rights.
\\ Leveraging resources: Assessing knowledge that

comes from credible, accessible, and regularly

updated knowledge platforms can add input as an
organization defines report content

79  Microsoft 2017 Annual Sustainability Report, pg. 11, http://download.microsoft.com/download/0/0/6/00604579-134B-4D0E-97C3-D525DFB7890A/

Microsoft_2017_CSR_Annual_Report.pdf
80  Hewlett Packard Enterprises 2017 Living Progress Report, pg. 73, https://h20195.www2.hpe.com/v2/Getdocument.aspx?docname=a00048490enw
81  Micron 2018 Sustainability Report, pg. 8, https://www.micron.com/-/media/client/global/documents/general/about/sustainability_report_gri_combined.pdf?la=en
25
 Stakeholder engagement in applying the Materiality Mapping the organization’s value chain is critical, to
principle get clarity regarding the types of actors that play a
Stakeholder engagement is crucial to gather information role in the organization’s impacts from the upstream
while defining report content and ensures that the to the downstream. For companies, the supply chain’s
content of the report is appropriate and meaningful complexity is often seen as a challenge. Proactive
for the relevant stakeholders. An organization may engagement with tier-1 suppliers, can be a starting point
think about the following questions to begin involving to gain valuable insights on the information actually
stakeholders and understanding their interests. available in the upstream compared to the information
requested in the downstream. While perspectives of
Gauging stakeholder interest: companies further upstream in the supply chain from
\\ Who are the key stakeholders the company would tier-2 suppliers to mine sites are typically more difficult
like to address and how can we reach them and to capture, they will also provide valuable insights into
collect their concerns? risks, impacts, and mitigation strategies that can inform
\\ Which stakeholders are influenced by the company’s an organization’s due diligence system and reporting.82
approach to mineral sourcing and how?
\\ How can the company consolidate the topics and Internal employees, CSOs, or peer and industry
priorities of different stakeholder groups? organizations should also be included in stakeholder
\\ Does the company have the ability to address their engagement efforts. These interactions can provide
concerns? valuable insight into which impacts of mineral sourcing
\\ How can the company respond to these stakeholders’ are significant and how the topic can be managed. Box
concerns? E and Box F show example stakeholder organizations,
consultants and tools useful for the stakeholder
CLG participants gave examples of how they conduct engagement component of the Materiality principle.
stakeholder engagement, including:
\\ Reaching out internally: Hosting a forum or surveying

employees can help your organization gather

information on the sustainability topics that matter
internally
\\ Communicating with civil society organizations

(CSOs), academics, industry organizations:

Understanding what outside actors with an interest in
sustainability issues have noted as important can help
inform which topics may be considered material in
your report

82  https://blog.assentcompliance.com/wp-content/uploads/2015/02/Assent-Smelter-FAQ.pdf
26
 Box E Examples of organizations whose work relates
to mineral sourcing impacts and responsible mineral
sourcing challenges
•  Alliance for Responsible Mining’s Fairmined Standard
•  Amnesty International
•  BetterChain
•  Bilateral German Congolese Cooperation Project (BGR)
•  Development International
•  Enough Project
•  Eastern Congo Initiative
•  Global Witness
•  International Conference on the Great Lakes Region
•  IMPACT
•  IPIS Research
•  Kumi Consulting
•  Levin Sources
•  PACT
•  Public Private Alliance for Responsible Minerals Trade
(PPA)
•  RCS Global Group
•  Responsible Minerals Initiative (RMI)
•  Responsible Sourcing Network (RSN)
•  Responsible Trade LLC
•  Solutions for Hope
•  The Dragonfly Initiative

Box F Examples of tools that assist with materiality

assessments.
•  EU Raw Materials Information System
•  Initiative for Responsible Mining Assurance’s Responsible
Mining Map
•  Fairphone Material Profiles Report
•  OECD Material Risk Portal
•  RMI – DRIVE Material Change Report
•  RMI’s Risk Readiness Assessment

This guidance and these resources can help organizations

draw out a plan for defining report content. This
plan may vary depending on an organization’s place in
the value chain, the identified stakeholders, and the
importance of this material topic relative to others. The
process for defining report content is intended to evolve
over time and should be updated periodically.83

83  Guidance for reporting on this process is described in Section 1.8

Comparability in GRI 101: Foundation (2016) (pg. 14) and can be
described using GRI Disclosure 102-49.
27
 10. How can companies report on how they identified material
topics related to mineral sourcing?

“From a stakeholder perspective, identifying mineral sourcing as a material issue indicates a company is committed
to work on this topic and thus it is valuable for stakeholders to learn about it and engage companies on it.”

RESPONSIBLE SOURCING NETWORK

The GRI Standards offer standardized disclosures to The pages following table 2 contain examples that
report how material topics were identified. Relevant illustrate the points mentioned in table 2. Inclusion of
reporting disclosures from the GRI Standards on how to examples from reporting organizations does not imply
identify material topics are listed in Table 2. endorsement – these examples are included as a means
of illustrating current reporting practice and as a source
of inspiration.

Table 2 Guide to GRI disclosures that can be helpful for reporting on stakeholder engagement and how material topics
have been identified
Disclosure/Standard Selected contents
Reporting on stakeholder engagement
Disclosure 102-40 List of A list of stakeholder groups engaged by the organization.
stakeholder groups
Disclosure GRI 102-42 Identifying The basis for identifying and selecting stakeholders with whom to engage.
and selecting stakeholders

Disclosure GRI 102-43 Approach to The organization’s approach to stakeholder engagement, including frequency
stakeholder engagement of engagement by type and by stakeholder group, and an indication of
whether any of the engagement was undertaken specifically as part of the
report preparation process.
Disclosure GRI 102-44 Key topics Key topics and concerns that have been raised through stakeholder
and concerns raised engagement, including:
•  how the organization has responded to those key topics and concerns,
including through its reporting;
•  the stakeholder groups that raised each of the key topics and concerns.
Reporting in accordance with the Materiality principle, identified topics and impacts
Disclosure 102-46 Defining report •  An explanation of the process for defining the report content and the
content and topic Boundaries topic Boundaries.
•  An explanation of how the organization has implemented the Reporting
Principles for defining report content.

Disclosure 102-47 List of material A list of the material topics identified in the process for defining report
topics content
GRI 103: Management Approach Explanation of the material topic and its Boundary
(2016)

28
rs, we work to fully Stakeholder Communication Methods
in the AA1000
y, tension, influence, and
evel of communication
Communication Consult
their respective needs.
Example of reporting on theDocument,
Information, approach to capturing
Report, information in the process
Survey, Meeting, of defining report content
Feedback mechanism
Website, Presentation
(from Acer, 2018)

In its sustainability report (2018) the electronics company Acer identifies ‘conflict minerals’ as a material topic in its
Dialogue Collaborate
report developed in accordance with GRI Standards. The organization describes the steps taken to identify material
Workshop, Forum, Leaders meeting Partnership, Multi-stakeholder Initiative
topics and provides an overview of its procedure for managing issues of stakeholder concern. Contents from this
excerpt could be included when reporting on the following GRI disclosures: Disclosure 102-42 Identifying and selecting
stakeholders and Disclosure 102-43 Approach to stakeholder engagement.
Procedure for managing issues of stakeholder concern

Suppliers

Inclusivity Materiality Responsiveness

Identify Stakeholder Focus Issues Stakeholder Engagement
Media Engagement Types Materiality Analysis Performance Evaluation
and Reporting

Some of the stakeholders Acer identified included internal employees, advocacy organizations,
2017 ACER CORPORATE RESPONSIBILITYcustomers,
REPORT suppliers,
industry organizations, and academic groups. Workshops, surveys, and partnerships and multi-stakeholder initiatives
were the main methods of engagement. In its reporting on its process for defining report content, Acer includes
a description of the different stakeholders the organization consulted and the communication methods taken. For
each type of stakeholder group, Acer describes the importance of this group to Acer, lists the issues of concern
of this stakeholder group, the main communication channels used to interact with this group, the results of this
communication in the reporting year and where in the sustainability report information on this groups’ issues of
concern can be found.84 Regarding the minerals sourcing space, Acer reports that the company works with the RMI
and participates in the RMI’s Cobalt Working Group and Tin Working Group. Contents from the below excerpts
reflect reporting on the following GRI disclosures: Disclosure 102-46 Defining report content and topic Boundaries
and Disclosure 102-47 List of material topics.
122

Other Standard Disclosures

Disclosure Chapter Page No. / Description External Assurance

Information Security Governance
Acer-EC1 Information Security Governance Legal Compliance 51 Assured by KPMG

Customer Service
Acer-EC2 Multiple service channels Customer Service 68 Assured by KPMG
Acer-EC3 Enhancing service quality Customer Service 69-70

Innovative Research & Development and Product Services

Acer-EC4 Innovative technology and application UN Sustainable Development Goals 58 Assured by KPMG
Innovation and Research 65-67

Acer-EC5 Open source and collaborative innovation Innovation and Research 67 Assured by KPMG

Acer-EC6 Acquisition and protection of intellectual property rights Innovation and Research 65 Assured by KPMG

Product Responsibility and Customer Safety

Acer-EN1 Halogen-free products launched Circular Economies and Product Life Cycle 74 Assured by KPMG

Corporate citizenship and philanthropy

Acer-SO1 Activities of corporate citizenship and philanthropy Employing Skills to Impact Society 　101-109 Assured by KPMG
Acer-SO2 Digital Inclusion activity Employing Skills to Impact Society 　106 Assured by KPMG

Talent Attraction
Acer-SO4 Investment in and development of talent pool Employee Care and Development 92-96 Assured by KPMG

Conflict Minerals
Acer-SO5 Publish of Smelter List and annual Conflict Minerals Report Sustainable Supply Chains 41-43 Assured by KPMG

port

Table 84  Acer Sustainability Report, 2018, pp. 19-21: https://static.acer.com/up/Resource/AcerGroup/Sustainability/Reports_Certificates/20180815/2017-corporate-

responsibility-report.pdf
29
 Acer (continued)

22

Identification of Material Topics and Boundaries

Acer uses the Global Reporting Initiative (GRI) Standard as the framework for establishing a process for identifying material sustainable development topics and providing the
information upon which CSR report disclosures are based, ensuring stakeholders receive the information they need.

Material Topics

27 Sustainability Topics

Inventory of Sustainability Issues Compacting Sustainability Topics

Enumerating Identification
sustainableIdentification ofrelating
development topics Material
of Material
to Acer Topics
and the Topics
and
ICT industry, drawn Boundaries
and Boundaries
Topics listed above with similar content are combined into one; a total of 27 topics result,
from material topics from GRI Standard, UN Sustainable Development Goals (SDGs), the categorized under four headings: governance, economy, society, and environment.
Dow Jones Sustainability Indices (DJSI), survey items, the Sustainability Accounting
Acer(SASB),
Standards Board uses Acer
the
anduses
Global
the theReporting
Global Global Reporting
Initiative
e-Sustainability Initiative
Initiative(GRI)
(GeSI).Standard
(GRI) Standard
as the framework
as the framework
for establishing
for establishing
a process a process
for identifying
for identifying
materialmaterial
sustainable
sustainable
development
development
topics a
information
information
upon which
uponCSR
which
report
CSRdisclosures
report disclosures
are based,
areensuring
based, ensuring
stakeholders
stakeholders
receive the
receive
information
the information
they need.
they need.
nd

n Material
Material
TopicsTopics
Investigation and Verification of

d 495 Surveys 27 Sustainability

27 Sustainability
TopicsTopics
Material Topics Investigation Ordering of Material Topics Identification of Material Topics and Boundaries
Inventory
Inventory
of Sustainability
of Sustainability
Issues Issues Compacting
Compacting Sustainab
Sustainability To
Through open online and company internal surveys, we Analyzing the returned surveys using the opinions of By pairing material issues with GRI Standard Aspects, we
collected 27 topics of concern to our stakeholders. A internal stakeholders (where employees includes senior identify material topics for disclosure and their
Enumerating Enumerating
sustainable sustainable
developmentdevelopment
total of 495 valid surveys were returned, an increase of topics relating
topics relating
to Acer and
management) to
on Acer
the
the and
ICTasindustry,
issues the ICT industry,
baselines drawn
for assessingdrawn boundaries.Topics
Topics listed listedwith
above above withcontent
similar similar content are combine
are combined into o
from
18% material
on the from material
previoustopics from
topics
year in terms ofGRIfrom
Standard,
total GRI Standard,
number UN Sustainable
UNtheSustainable
Development
level Development
of importance toGoals
external(SDGs),
Goals the
(SDGs),
stakeholders the
(a total categorized
categorized under
under four four headings:
headings: governance,
governance, econ
economy, so
returned,
Dow Jones indicating
Dow that our
Sustainability
Jones stakeholders
Indicesare(DJSI),
Sustainability takingsurvey
Indices a (DJSI),items,
surveyofthe
nineSustainability
items,categories of stakeholder)
22
the Sustainability
Accounting for each issue. A matrix
Accounting
greater interest in Acer’s operations and want to provide of material issues is drawn up and submitted to the
Standards
feedback.
Standards
Board (SASB),
Board and(SASB),theand
Global
thee-Sustainability
Global e-Sustainability
InitiativeInitiative
(GeSI). (GeSI).
corporate sustainability officer, with the ordering results
ty verified by audit in line with trends in sustainable
and development, the industrial environment, and the
company’s status.

ifying material sustainable development topics and providing the

ey need. Investigation
Investigation
and Verification
and Verification
of of
02 SUSTAINABLE VALUES, STURDY MODELS 2017 ACER CORPORATE RESPONSIBILITY REPORT
495 Surveys
495 Surveys

MaterialMaterial
Topics Investigation
Topics Investigation Ordering
Ordering
of Material
of Material
Topics Topics Identification
Identification of Mat

ThroughSustainability
Compacting Through
open online
openandonline
company
Topics and company
internalinternal
surveys,surveys,
we we Analyzing
Analyzing
the returned
the returned
surveys surveys
using theusing
opinions
the opinions
of of By material
By pairing pairing materi
issues
collectedcollected
27 topics27oftopics
concern
of concern
to our stakeholders.
to our stakeholders.
A A internalinternal
stakeholders
stakeholders
(where employees
(where employees
includesincludes
senior senior identify identify
materialmaterial
topics fo
total of 495
totalvalid
of 495
surveys
valid surveys
were returned,
were returned,
an increase
an increase
of of management)
management)
on the issues
on theasissues
baselines
as baselines
for assessing
for assessing boundaries.
boundaries.
ed above with similar content are combined into one; a total of 27 topics result,
18% on18% the previous
on the previous
year in terms
year inofterms
total number
of total number the levelthe
of importance
level of importance
to external
to external
stakeholders
stakeholders
(a total (a total
d under four headings: governance, economy, society, and environment.
returned,returned,
indicating
indicating
that ourthat
stakeholders
our stakeholders
are taking
areataking a of nine categories
of nine categories
of stakeholder)
of stakeholder)
for eachforissue.
eachA issue.
matrixA matrix
greater interest
greater interest
in Acer’sinoperations
Acer’s operations
and want and
to want
provide
to provide of material
of material
issues isissues
drawnisup drawn
and submitted
up and submitted
to the to the
feedback.feedback. corporate
corporate
sustainability
sustainability
officer, withofficer,
thewith
ordering
the ordering
results results
lity verified verified
by auditby in audit
line with
in line
trends
withintrends
sustainable
in sustainable
development,
development,
the industrial
the industrial
environment,
environment,
and theand the
company’s
company’s
status. status.

02 SUSTAINABLE
02 SUSTAINABLE
VALUES,
VALUES,
STURDYSTURDY
MODELS
MODELS 2017 ACE
20
Identification of Material Topics and Boundaries

ions of By pairing material issues with GRI Standard Aspects, we

des senior identify material topics for disclosure and their
ssessing boundaries.
ers (a total
ue. A matrix
o the
ng results
ble
d the

30
Example of reporting on the approach for defining report content (from Teck, 2017)

Mining company Teck describes its extensive process for assessing which topics are material in its 2017 Sustainability
Report. On a three-year cycle, there is identification, prioritization, and validation of topics. The inclusion of internal
and external opinion over the course of the three-year process for defining report content is clear from Teck’s
description. The company carried out interviews with internal and external stakeholders, and looked at industry
reports, survey results, and workshops. The topics considered most material to the company were determined in
interviews with stakeholders.85 Contents from this excerpt could be included when reporting on the following GRI
disclosures: Disclosure 102-42 Identifying and selecting stakeholders, Disclosure 102-43 Approach to stakeholder
engagement and Disclosure 102-46 Defining report content and topic Boundaries.
Teck 2017 Sustainability Report

Material Topics

In our report, a material topic is one that reflects our company’s significant economic, environmental
and social impacts, or that could substantively influence the assessments and decisions of our
stakeholders, per guidance from the Global Reporting Initiative. For each of our 11 material topics,
we provide information as to why the topic was material in 2017, Teck’s approach to managing
risks and opportunities associated with that topic, our performance, and our outlook for 2018.

2017 Materiality Assessment In 2017, we conducted a comprehensive materiality

assessment and began a new three-year cycle. During the
The content of our annual sustainability reporting is
identification phase, we conducted research on trends in our
determined through a detailed materiality assessment, which
industry and evaluated internal strategy documents, including
is a process for identifying and evaluating the topics that
the five-year plans for each of our business units. We also
mattered most to our business and our communities of
mapped our impacts and the boundary of our material topics
interest during the previous year and for the near-term future.
across the value chain with a cross-functional group of 16
Our annual process for determining material topics follows internal experts. In this phase, we identified 26 potentially
a three-year cycle and involves three steps: identification, material topics.
prioritization and validation. The first year involves intensive
During the prioritization phase, we conducted one-on-one
consultation and research to identify a full list of topics, which
interviews with 20 internal and external stakeholders and
are analyzed by internal experts and external stakeholders and
used more than 20 inputs such as industry reports, survey
validated by our senior management team. Topics in the
results and internal workshops to determine the most
mining industry are typically consistent year over year, given
significant risks and opportunities facing our business and our
the long-term nature of operations. As such, the second and
communities of interest in the past year. During interviews
third years build on the results from the first year, and the
with internal and external stakeholders, a range of topics
assessment is updated to reflect emerging issues.
were identified as most significant in terms of risks and
opportunities in 2017. For internal stakeholders, the most
Figure 6: Materiality Assessment Process
significant topics were water management, relationships with
communities, and business ethics. For external stakeholders,
the topics that were considered most significant were energy
and greenhouse gas emissions, biodiversity, and dialogue with
Id communities. In this phase, 15 topics were identified as
n potentially meeting our threshold for reporting.
en
io
at

ti f

· Research
d

ica

We recognize that many of our

Vali

and
· Senior Benchmarking
t i on

Management
Engagement
· Impact
Mapping
material topics are interrelated;
for example, a topic such as
Relationships with Indigenous
· Internal and External
Engagement Peoples is connected to several
· Analysis
topics, such as Biodiversity and
Pr i o
ritiz a ti o n
Reclamation, Water Stewardship
and Human Rights.

85  Teck 2017 Sustainability Report, http://www.teck.com/media/Teck-2017-Sustainability-Report.pdf

24 31
 Example of reporting on the approach to stakeholder engagement (from Wolfram Bergbau und Hütten AG)

Being an upstream entity, the company identifies a number of stakeholder groups along the mineral supply chain in its
2017 Due Diligence Report, and describes its approach to engaging with each group in the context of complying with
regulation and also providing positive impacts on the ground.86 Contents from this excerpt could be included when
reporting on the following GRI disclosures: Disclosure 102-42 Identifying and selecting stakeholders and Disclosure
102-43 Approach to stakeholder engagement.

OECD Step-5 Report for 2017 Page 10

Involvement of Affected Stakeholders

Aim of the Conflict Mineral regulations is to protect the most vulnerable groups at or near the upstream
end of the mineral supply chains: local miners, their families, and the population of the mining countries
at large; from violence, human rights violation and child labour. With its purchasing policy, WBH tries to
provide a positive impact:
 no boycott of minerals from CAHRAs per se as this would deprive the communities from income
and the chance of development. Instead, the company allows for active sourcing when the supply
chain fulfils ethical standards and does not support conflict.
 For approved supply chains, providing incentives to continuously improve the conditions on the
mine site and to give a helping hand with respect to technical development.

This approach can only work with the help of all actors along the supply chain:
 Mine operators (companies or cooperatives) need to be loyal and not look for the “last penny” at
each individual sale of concentrates. A reliable longer-term offtake relation is required to make
collaboration and technical help worthwhile.
 The same applies to intermediates and especially the exporting traders. In addition, they need to
be open (e.g., provide adequate information and ITSCI sheets), play to the rules of WBH and the
traceability providers, even if they consider them excessive, and demonstrate diligence and
precision when it comes to the tagging systems.
 The traceability providers (ITSCI, BSP, others, if they become available) have to do their best to
maintain credibility. With own site visits and plausibility assessments, WBH has established a back-
up system, but especially for smaller suppliers, reliable traceability by tagging is currently the only
system that is acceptable for 3rd party audits of the smelters. Shortcomings in the programmes are
noted and brought to the attention of the providers.
 RMI’s RMAP as the currently only active “Conflict Free Smelter Program” needs to maintain its high
standards and credibility without losing the balance between feasibility, practicalities and
expectations of the downstream. WBH feels that a stronger focus on timely re-audits and duration
of the “active smelter” status is required, respectively some public disclosure to explain delays and
changes to supply patterns for audited smelters.
 Direct customers have been supportive when WBH discussed resumption of sourcing from Central
Africa in 2014. It is important that the entire downstream supply chain accepts Central African
supplies if cleared by the traceability providers and RMI, which in turn, as described above, requires
strong focus on credibility of these organisations.

The two current traceability providers, ITSCI and BSP, are involved in fierce competition and a “war of
words” (incident reports, public letters…), which has the potential to impact on the overall reputation of
the process and thus, is contra-productive for both sides. WBH’s supplier use both systems, and the
company calls for fair competition without trying to impose new barriers. ITSCI is supporting very small
producers, and for a fair competition, BSP would need to avoid cherry-picking either.
86  http://www.responsiblemineralsinitiative.org/media/docs/WBH_2017.pdf
32
ITSCI’s system of incident reporting and base line studies is partly lacking the transparency required for
11. Reporting on Due Diligence

The OECD Due Diligence Guidance for Responsible In this chapter, the focus lies on due diligence processes
Business Conduct outlines the due diligence process and related to social impacts. Section I provides an overview
supporting measures including embedding responsible of the OECD Due Diligence Guidance for Responsible Supply
business conduct into policy and management systems, Chains and offers a list of tools that help create due
identifying and assessing adverse impacts, ceasing, diligence systems. Section II explores information-sharing
preventing, or mitigating adverse impacts, track challenges that reporting companies may want to pay
and communicating how impacts are addressed,87 attention to. Section III focuses on GRI’s management
and remediating when appropriate. The OECD Due approach and how it can be used together with the
Diligence Guidance for Responsible Supply Chains guides OECD Due Diligence Guidance for Responsible Supply
organizations on proactive and progressive due diligence Chains Step 5 reporting expectations. Section IV offers
and reporting within mineral supply chains, specifically. collected suggestions of more specific contents that can
This is one of the sector specific guidance documents be reported in alignment with the OECD Due Diligence
that complement the OECD Guidance, such as for Guidance on due diligence. Finally, section IV presents
garment supply chains or the financial sector.88 some reporting examples on due diligence.

Stakeholders value understanding information on

progress and limitations, acknowledging that due 11.1 OECD Due Diligence Guidance for
diligence is never ‘complete’, but rather a continual Responsible Supply Chains of Minerals from
process based on factual circumstances in the supply Conflict-Affected and High-Risk Areas
chain, which may change over time. A company’s
approach to due diligence and disclosure is driven by The 2010 OECD Due Diligence Guidance for Responsible
factors including customer requirements for the accuracy Supply Chains is the first example of an internationally
and completeness of due diligence disclosures and backed, formal initiative to encourage responsible supply
information. Transparency and reporting on progress chain management of minerals from conflict-affected
and limitations can demonstrate a commitment to and high-risk areas.89 It seeks to cultivate transparent
improvement over time and build trust. supply chains and sustainable corporate engagement in
the mineral sector, enable high-risk countries to profit
“When it comes to active measures to reduce the risk,
from their natural resources in a responsible manner, and
which can be sensitive or confidential, it is about
prevent resource extraction and trade from contributing
finding a balance between the need to understand if
to conflict, human rights abuses, and security issues.90 It
upstream entities are actively committed to managing
applies to all minerals and is global in geographic scope,
risk and understanding if those measures do in fact
although it focuses on CAHRAs.
reduce the risk.” 

ATEA SVERIGE

87  For more guidance on communicating how impacts are addressed, see also pg. 33 https://mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-
Responsible-Business-Conduct.pdf
88 For a full list of sector guidance, see http://mneguidelines.oecd.org/duediligence/
89  http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
90  http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
33
 The OECD Due Diligence Guidance for Responsible Supply Step 2: Identify and assess risk in the supply chain
Chains: Organizations should identify risks in their supply chains
\\ Is based on a continuous proactive and reactive by assessing the potential for adverse impacts mentioned
approach. in the OECD’s Annex II risks, particularly in view of the
\\ Expects the operating company to take responsibility organization’s own supply chain policies and management
in respecting human rights and avoiding contribution systems. Risk assessments are triggered by red flags
to conflict and puts emphasis on taking actions such as: minerals originating from or transported
proportional to the risk of conflict minerals being through CAHRAs, from areas where there are limited
present in the supply chain. reserves or expected production levels of minerals
\\ Encourages audits, assessments and constructive are in question, or from an area in which minerals
engagement to make responsible trade possible, from CAHRAs are known to transit (referenced in the
rather than disengaging with suppliers operating in OECD Due Diligence Guidance for Responsible Supply
CAHRAs. Chains as “red flag location of mineral origin or transit”).
\\ Understands that complete adherence cannot always Additionally, supplier red flags can trigger risk assessment
be achieved right away. – these red flags include suppliers or upstream entities
\\ Advises continuous ‘reasonable and good faith efforts’ that supply minerals from a red flag location of mineral
that promote engagement in the troubled area.91 origin or transit or have done so in the past year. 93
\\ Asks companies to publicly report on supply chain

due diligence practices. Cooperation and data sharing with other industry
actors are considered critical. Efforts at identifying and
The Guidance takes a global view of mineral sourcing mitigating risks often involve multiple tiers of the supply
and is applicable across all minerals and metals, with chain and can be stunted by information limitations.
specific supplements for tin, tungsten, tantalum, and gold. Thus, it is important to identify supply chain actors,
It applies throughout the mining value chain, engaging request information, and engage with them through
upstream and downstream actors in establishing information review.
traceability, collaborating, and sharing information on
their efforts. Step 3: Design and implement a strategy to
respond to identified risks
The Guidance consists of five steps that help upstream Companies should devise a strategy to respond to
and downstream companies establish, implement, and any identified risks, through a risk mitigation plan that
report on due diligence systems for their supply chains.92 addresses risks identified in Step 2. Risk management can
be done though continued trade in conjunction with risk
Step 1: Establish strong company management mitigation, the temporary suspension of trade while risk
systems mitigation happens, or the disengagement with a supplier
Organizations should establish strong management if mitigation does not appear feasible.94 It is important
systems supported by a supply chain policy for minerals for companies to first attempt to mitigate identified risk
from CAHRAs, an internal management system to rather than disengage unless they deem risk mitigation
implement this policy, and a system of controls and not feasible or unacceptable. The guidance encourages
transparency over the supply chain. Engagement with cooperation with other industry actors and NGOs to
suppliers and a grievance mechanism are also included as help suppliers build their due diligence capabilities.
part of the company management system.

91  http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
92  http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
93  These are red flag triggers listed in the Supplement on Tin, Tantalum, and Tungsten. In the Supplement on Gold, there are additional red flag triggers relating
heightened red flag potential if gold is claimed to originate from recycled/scrap or mixed sources from a red flag location of mineral origin or transit. Risk
potential is heightened if gold is sourced from areas where money laundering laws, anti-corruption laws, and similar laws are weakly enforced or there is an
informal banking system and cash is widely used. Additionally, “anomalies or unusual circumstances…which give rise to a reasonable suspicion” can trigger a red
flag. http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
94  These strategies, and the circumstances in which each of them should be employed, are defined in the OECD Due Diligence Guidance for Responsible Supply
Chains of Minerals from Conflict-Affected and High-Risk Areas, Annex I and II.
34
Step 4: Carry out independent third-party audit of
smelter due diligence practices
An independent third party should carry out an audit of
the smelter or refiner (SORs) due diligence. These audits
may be managed by an independent institutionalized
mechanism.

Step 5: Report annually on supply chain due

diligence
Companies should publicly report on their due diligence
practices every year and may do so as part of their
corporate responsibility reporting. For upstream
companies this means describing company management
systems, publishing a risk assessment, and the steps
taken to manage risks. It is also recommended that
upstream companies describe the steps that they
have taken to manage risk, as well as steps taken for
capability-training and stakeholder engagement. For
SORs, the OECD recommends published audit reports.

Reporting for downstream companies involves reporting

on company management systems, risk assessment,
and management of risks. Additionally, if a downstream
company has undergone an audit such as an IPSA, it may
publish the summary of the report or a summary of the
audit conclusions.

Box G List of free, publicly available tools that help in

creating due diligence systems related to the topic of
responsible minerals sourcing and getting involved in
in-region initiatives
•  Conflict-Affected and High-Risk Areas (CAHRAs)
Resource Page
•  RMI Five Practical Steps for Conflict Minerals Due
Diligence and SEC Disclosure (2017)
•  RMI Responsible Minerals Assurance Process (RMAP)
•  RMI Public Due Diligence Report Writing Guidance
(2018)
•  RMI Smelter Identification Questionnaire (SIQ)
•  Supply Chain Mapping Tool
•  OECD Due Diligence Guidance Information Page
•  UN Guiding Principles on Business and Human Rights
(2011)
•  World Gold Council: Conflict-Free Gold Standard
(2012)

35
 11.2 Information-sharing challenges in the \\ This could potentially be applied to other actors in
value chain the supply chain
\\ Use company-wide CMRTs rather than product-
The complexity of the mineral value chain leads to level CMRTs: Reduce workload and strain related to
limitations in information sharing between value product-level CMRTs
chain actors. Actors along the value chain have noted \\ Training and awareness: Provide training and
confusion about what information needs to be collected awareness raising to supply chain actors on how to
and reported, what information is reasonable to request/ complete the CMRT and gather relevant information
report, and what information should be disclosed
Box H Tools for supply chain data exchange
publicly. A commonly used tool to gather information
•  CMRT Drafting Guide (May 2017)
across the supply chain is the RMI Conflict Minerals
•  Conflict Minerals Reporting Template (CMRT) and
Reporting Template (CMRT) for 3TG and the Cobalt Cobalt Reporting Template (CRT): These standardized
Reporting Template (CRT) for cobalt. reporting templates facilitate the transfer of information
on mineral country of origin and smelters and refiners
Addressing data exchange challenges (helps identify which smelters and refiners should
Downstream companies and mid-tier suppliers undergo an audit – see Step 4).
•  IPC 1755 Conflict Minerals Data Exchange Standard
experience challenges in gathering and validating
•  RMI Minerals Due Diligence Training for Suppliers
information from the large amounts of suppliers in their
•  Smelter Information Questionnaire (SIQ): A survey to
supply chains. identify smelters and refiners in global supply chains.
•  Standard Smelter List and Revision History
Challenges with data collection:
\\ Participants in the GRI-the RMI Corporate Leadership Confidentiality considerations
Group highlighted the added workload that product- Smelters and refiners are often described as the ‘pinch
level CMRTs generate. point’ in the supply chain due to the relatively few
\\ There is a lack of understanding or awareness on key numbers of actors (as shown in Figure 4). Information
issues (for example, whether smelters source from held by smelters and refiners can be considered business
the ‘covered countries’, or a common understanding confidential – this relates to any information that could,
of what constitutes a conflict-affected or high-risk for example, reveal specific suppliers or mines.
area)
\\ Language barriers, including spelling and punctuation, Box I Business confidentiality as defined by the OECD
might yield invalid data. in the OECD Due Diligence Guidance for Responsible
Supply Chains Supplement on Gold95
\\ Government reports and statistics may be outdated,
“Business confidentiality and other competitive or security
incomplete, or unreliable. concerns means, without prejudice to subsequent evolving
\\ Fluidity of the supply chain leads to variance in data interpretation: price information; supplier identities and
collection, depending on the point of collection in the relationships (however the identity of the refiner and the
supply chain and time of collection local exporter located in red flag locations should always be
\\ Confidentiality concerns have been raised by suppliers disclosed except in cases of disengagement); transportation
to share supply chain data – in particular, where routes; and the identity of information sources and whistle-
blowers located in conflict-affected and high-risk areas, where
supply chains are less complex
revealing the identity of such sources would threaten their
safety. All information will be disclosed to any institutionalised
Opportunities to improve data collection: mechanism, regional or global, once in place with the mandate
\\ Establish common definitions: Use common to collect and process information on minerals from conflict-
definitions to make communication easier between affected and high-risk areas.”
entities in the value chain. One example is the CID or Supplement on Gold Tungsten
Company ID system developed by the RMI to assign
a commonly accepted unique identifier to each entity.

95  This definition is taken from the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
Supplement on Gold. This differs slightly from the business confidentiality requirements highlighted in the Supplement on Tin, Tantalum and Tungsten.
36
Downstream organizations may not have visibility
into the entire process that occurs upstream due to
the number of supply chain actors from the point of
extraction and complex flow of minerals in the supply
chain (see Figure 4) and the confidentiality considerations
mentioned above. To help protect confidentiality and
bring efficiency and scalability to upstream due diligence
in CAHRAs, companies may utilize upstream assurance
mechanisms, spot checks for mines not covered by
upstream assurance systems, self-assessments, industry
reporting mechanisms, and audits. This information, may
not always be public due to non-disclosure agreements.

Figure 4 Actors in the mineral value chain

Upstream Downstream

Road Trading Refiners and Metal traders Component Consumer

Mine
transport house smelters and exchanges manufacturers goods

# of actors

Addressing confidentiality challenges

Navigating the landscape of confidential and business
sensitive information and balancing it with growing desire
for transparency, data collection, verification, exchange
and reporting is challenging. Here are some tools and
ways of working that help address these challenges:

\\ Sharing information with independent third-party \\ Clear communication, scoping, limitations and
auditors for verification purposes under non- expectation-setting can be established via Terms and
disclosure agreements Conditions when any type of data is collected
\\ Sharing information with industry initiatives under
non-disclosure agreements \\ Data voluntarily shared by individual companies
\\ Information shared with industry initiatives can be should be pursuant to OECD Step 5 reporting or
aggregated and anonymized before being shared more mandatory reporting under minerals regulations
widely (either publicly or to selected stakeholders), (e.g., Dodd-Frank Act or EU Minerals Due Diligence
pursuant to terms of signed non-disclosure Regulation)
agreements. This allows for reporting of trends
without divulging confidential or business sensitive
information

37
 Challenges related to leverage over impacts 11.3 How can an organization report on due
resulting from sourcing in supply chain diligence using the GRI Standards?
Downstream companies may feel that distance from the
point of extraction, the number of supply chain actors, Companies can use the GRI Standards to describe their
complexity in the flow of minerals, and the low volume due diligence process and results. For topics identified
of minerals used/sourced limits the influence they have as material, organizations are required to report their
using a supply chain due diligence approach. The OECD management approach for the topic. If an organization
Due Diligence Guidance for Responsible Business Conduct has identified topics related to ‘mineral sourcing’ or
addresses this point by recommending that companies ‘conflict mineral sourcing’ as material, it is required to
increase leverage by “introducing responsible business report its management approach for this topic.
conduct and due diligence expectations into commercial
contracts, establishing commercial incentives linked to A management approach disclosure is a “narrative
responsible business conduct criteria, and establishing description about how an organization manages
longer-term relationships with… suppliers or business its material topics and their related impacts.” The
relationships.”96 The Guidance also suggests that the Standard GRI 103: Management Approach (2016) can
challenges of conducting due diligence can be eased be used to report how the organization manages the
through: topic, the purpose of the management approach or a
description of policies, commitments, goals and targets,
\\ Industry-wide cooperation in building capacity to responsibilities, resources, grievance mechanisms, specific
conduct due diligence actions, such as processes, projects, programs and
\\ Cost-sharing within industry for specific due diligence initiative.
tasks
\\ Participation in initiatives on responsible supply chain The connection between due diligence and GRI’s
management disclosures on the management approach can be seen
\\ Coordination between industry members who share in the Specialized Disclosure (Form SD) forms that
suppliers companies file in response to the Dodd-Frank Act (read
\\ Cooperation between upstream and downstream more about the Dodd-Frank Act here). The information
companies in Form SD typically mirror the steps described in the
\\ Building partnerships with international and civil OECD Due Diligence Guidance for Responsible Supply
society organizations Chains, which is the recommended framework to use
for risk assessment and due diligence. For companies
More recommendations on developing common subject to reporting according to the Dodd-Frank Act,
expectations in collaboration with suppliers that can be the mandated reporting requirements can be integrated
reported on can be found in the OECD Due Diligence in reporting using the GRI Standards disclosures.
Guidance for Responsible Business Conduct.

96  Pg. 79, http://mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf

38
Example of linkage between Dodd-Frank Specialized Disclosure forms and GRI Standards
Box J contains an excerpt from the 2018 Specialized Disclosure form from The Boeing Company, annotated with
GRI Standards references. The information reported in the example could be added to the information reported for
these GRI Standards. Understanding how this information can be cross-referenced is useful for building and including
a comprehensive GRI index that gives stakeholders a quick one-stop overview where information can be found across
multiple documents and webpages.97

In this way, an organization reporting in accordance with GRI’s framework can integrate responsible mineral sourcing
topics into its current disclosures. At the same time, organizations new to minerals due diligence disclosure or those
planning an initial disclosure have various options to consider for framing and organizing the issue.

Box J Excerpt from Boeing Specialized Disclosure form (2018) (GRI Standards annotations added by GRI)
OECD Step 1. Establish Strong Company Management Systems

Conflict Minerals Policy

We are committed to promoting economic development in Africa through responsible commercial engagement. As part of
this commitment, Boeing has adopted a conflict minerals policy related to our sourcing of 3TG, which is available on www.
boeingsuppliers.com. [GRI 103: Management Approach (2016): e.g. reporting on policies related to the topic]

Internal Team
Boeing has established a management system to support supply chain due diligence related to 3TG. Our management system
includes a team of subject matter experts from functions such as supplier management, engineering, finance, law, global
engagement, and our Boeing International organization. The team of subject matter experts is responsible for implementing
our conflict minerals compliance strategy. [GRI 103: Management Approach (2016): e.g. reporting on responsibilities related to
the topic]

Control Systems
Together with other major manufacturers in aerospace and other sectors, we were members for the year covered by this
report of the following initiatives that are working to develop conflict-free supply chains: the OECD Multi-Stakeholder
Group, Responsible Minerals Initiative (formerly the Conflict-Free Sourcing Initiative), the International Tin Association
(formerly known as the International Tin Research Institute) Tin Supply Chain Initiative, the Public Private Alliance for
Responsible Minerals Trade and the Aerospace Industries Association Conflict Minerals Working Group.
We have established and maintain a records retention policy with respect to relevant documentation.
[GRI 103: Management Approach (2016): e.g. reporting on specific actions such as processes, projects, programs and initiatives
related to the topic]

Supplier Engagement
Our supply chain team, which includes representatives from a number of management functions within Boeing as well as
representatives of certain of our suppliers, meets on at least an annual basis to discuss best practices among our suppliers.
We also maintain an electronic portal that provides detailed instructions to suppliers and resources related to conflict
minerals, including the Template, our conflict minerals policy, as well as FAQs from the Aerospace Industries Association and
the U.S. Securities and Exchange Commission. [GRI 103: Management Approach (2016): e.g. reporting on specific actions such as
processes, projects, programs and initiatives related to the topic]

Grievance Mechanism
We have processes to receive and act on concerns - written or oral - expressed by employees and others about possible
improper or unethical business practices or violations of company policies

97  GRI 102: General Disclosures (2016), pg. 38

39
 11.4 What type of information should be
disclosed on management and due diligence?

The OECD Due Diligence Guidance for Responsible

Supply Chains explicitly encourages companies to
publicly report on their due diligence practices every
year. As seen in section III, the OECD Due Diligence
Guidance for Responsible Supply Chains recommends
that downstream companies report on their company
management systems, risk assessment systems, and steps
taken to manage risks. For upstream companies, the
recommendations are similar but include an additional
recommendation of publishing summary audit reports.

The five steps described by the OECD Due Diligence

Guidance for Responsible Supply Chains have been adopted
by other due diligence frameworks and regulatory
instruments. For example, reporting on these steps
can be seen explicitly in Specialized Disclosure Forms
published by companies to meet the expectations of the
Dodd-Frank Act. Downstream companies have used the
RMI’s Conflict Minerals Reporting Template (CMRT) and
Cobalt Reporting Template (CRT) to gather information
from upstream entities in their value chain with the aim
of aggregating and reporting this information publicly.
The CMRT facilitates information exchange/reporting to
comply with the Dodd-Frank Act and is being updated
to facilitate reporting under the EU Mineral Supply Due
Diligence Regulation.

Participants in the GRI-RMI Corporate Leadership

Group were asked to reflect on the specific due
diligence-related information they considered meaningful
to report. This information is included below, along with
questions from the CMRT/CRT, and their link to GRI
Standards in Table 4. These contents are categorized
according to the OECD Due Diligence Guidance for
Responsible Supply Chains five step framework to
demonstrate the type of information that can be
reported for each step.

When reporting on mineral sourcing, an organization

may choose from the collected suggestions for contents
below, depending on its specific circumstances and
interests by its stakeholders.

40
41
 The pages after Table 4 contain examples of extracts of
reporting on some of the contents mentioned above.
Inclusion of examples from reporting organizations does
not imply endorsement – these examples are included as
a means of illustrating current reporting practice and as a
source of inspiration.

Table 4 Suggestions for reporting on due diligence

Collected suggestions of contents that can be reported in alignment with the OECD Due Diligence GRI Standards under which
Guidance for Responsible Supply Chains contents can be reported
Reporting on Step 1: Establish strong company management systems
Questions collected from •  Have you established a supply chain policy? GRI 103: Management
CMRT and CRT and •  Is your supply chain policy publicly available on your website? Approach (2016
OECD-based due diligence •  Do you require your direct suppliers to source the 3TG from smelters
indicators derived by whose due diligence practices have been validated by an independent third-
Development International party audit program?
criteria 1 •  Have you implemented due diligence for your mineral supply chain? (e.g.,
communicating and incorporating into contracts your expectations to
suppliers; identifying and assessing risks in the supply chain; designing and
implementing a strategy to respond to identified risks; verifying your direct
supplier’s compliance to its supply chain policy.)
•  Does your company conduct 3TG surveys of your relevant suppliers?
•  Do you review due diligence information received from your suppliers
against your company’s expectations? (e.g., third-party audit, documentation
review only, internal audit)
•  Does your review process include correction action management?
•  Is your company required to file an annual conflict minerals disclosure with
the SEC?
•  Do you require suppliers to exercise due diligence over the cobalt
supply chain in accordance with the OECD Due Diligence Guidance for
Responsible Supply Chains?
•  Do you require your direct suppliers to source cobalt from smelters whose
due diligence practices have been validated by an independent third-party
audit program?
•  Do you require smelters’ due diligence practices to cover, at a minimum, all
risks in the OECD Due Diligence Guidance for Responsible Supply Chains
Annex II Model Policy, as well as the worst forms of child labor?
•  Is any 3TG intentionally added or used in the product(s) or in the production
process?
•  Does any 3TG remain in the product?
•  Does 100 percent of the 3TG (necessary to the functionality or production
of your products) originate from recycled or scrap sources?
•  If no, what percentage of the 3TG (necessary to the functionality or
production of your products) originate from recycled or scrap sources?
•  Has all applicable smelter information received by your company been
reported in this declaration?
•  Is any of the cobalt intentionally added or used in the product(s) or in the
production process?
•  Are suppliers sourcing through SORs that have successfully undergone an
independent third-party audit (via the RMI, LBMA, RJC, etc.)?
•  Does your company provide or utilize a grievance mechanism?

See reporting examples from IBM and Philips in next section for an example of
reporting on the due diligence contents described above

GRI-RMI Corporate •  Does the company have a responsible sourcing policy or equivalent for GRI 103: Management
Leadership Group minerals (including cobalt and other non-3TG minerals, if material) that is Approach (2016)
suggestions aligned with relevant aspects of the OECD Due Diligence Guidance for
Responsible Supply Chains, the UN Guiding Principles on Business and
Human Rights, and the ILO standards?

1  Development International, Dodd-Frank Section 1502 Filing Evaluation, 2016, pp. 52-57: https://docs.wixstatic.com/ugd/
f0f801_9502a3a2a8f143a7b5d863792a01318a.pdf
42
Reporting on Step 2: Identify and assess risks in the supply chain
Questions taken from •  What percentage of relevant suppliers have provided a response to your GRI 102: General
CMRT and CRT supply chain survey? Disclosures (2016),
•  Do any of the smelters in your supply chain source the 3TG from the Disclosure102-9 Supply
covered countries (DRC or adjoining countries)? chain
•  Do any of the smelters in your supply chain source minerals from a Conflict-
Affected and High-Risk Area? GRI 308: Supplier
•  Have you identified all of the smelters supplying cobalt to your supply chain? Environmental Assessment
•  Have you assessed whether the smelters/refiners in your supply chain have (2016)
carried out all 5 steps of due diligence?
•  Have you supported, including through participation in industry-driven
programs, joint spot checks and/or audits at the smelter/refiner’s facilities?
•  Have you identified the presence of Annex II risks in the supply chain?
GRI-RMI Corporate •  What percentage of relevant suppliers have provided a response to your GRI 102: General
Leadership Group supply chain survey? Disclosures (2016),
suggestions •  Number or percentage of suppliers implementing OECD DD guidance Disclosure102-9 Supply
•  Percentage of suppliers with a Risk Readiness Assessment completed chain
See reporting example from Apple on how risk assessment data is reported
utilizing the RMI Risk Readiness Assessment
Reporting on Step 3: Design and implement a strategy to respond to identified risks
Questions taken from •  Do you review due diligence information received from your suppliers GRI 102: General
CMRT and CRT and against your company’s expectations? (e.g., 3rd party audit, documentation Disclosures (2016),
OECD-based due diligence review only, internal audit) Disclosure102-9 Supply
indicators derived by •  Does your review process include corrective action management? chain
Development International •  What are the established procedures or guidelines that determine the
response to findings of human rights / child labor violations? GRI 308: Supplier
•  Is there a process for measuring SOR(s)’ demonstrated significant and Environmental Assessment
measurable improvement within six months from the adoption of their risk (2016)
management plans?
•  Was designated senior management briefed on the gathered information and
the actual and potential risks identified in the supply chain risk assessment?
•  Are upstream suppliers utilizing or supporting an upstream verification and
due diligence system that provides components of risk assessment and
mitigation or has the company implemented concerted capacity-building
efforts with measured outcomes that target the upstream?
Reporting on Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices
GRI-RMI Corporate •  Percentage of smelters that have been validated by an independent third-
Leadership Group party audit program
suggestions •  Percentage of smelters which are active in an independent third-party audit
program but are not yet conformant
•  Percentage of smelters that are not participating in an independent third-
party audit program
Additional contents that can be reported for Step 5: Report annually on supply chain due diligence
Questions taken from •  Do you publish audit reports with due regard taken of business GRI 102: General Disclosures
CMRT and CRT and confidentiality and other competitive concerns? (2016), Disclosure 102-9
OECD-based due diligence •  Do you publish an annual report on due diligence for responsible supply Supply chain
indicators derived by chains of minerals from conflict-affected and high-risk areas?
Development International •  Do you report on risks identified in the supply chain and how those risks
are mitigated?
See reporting examples from HP Inc. and Microsoft to see how results from due
diligence can be reported

43
 Example of reporting on participation in due diligence programs like the Responsible Minerals Assurance
Process (RMAP) and clear breakdown of steps taken for due diligence (from IBM, 2017)

In this excerpt from IBM’s sustainability report, the company highlights its participation in the RMI and how it
uses its tools and resources such as the Responsible Minerals Assurance Process (RMAP). Further, IBM
extensively describes its aspects of its due diligence work in four steps that lay out how the company has
established a standard, performed a Reasonable Country of Origin Inquiry (RCOI), conducted due diligence on in-
scope suppliers, and is working with smelters and refiners to make sure they are included in RMAP or equivalent
50
programs. IBM cites disclosures like number of responses from 2017 Corporatesuppliers
in-scope Responsibility Reportand
received | Supply chain
percentage of
SORs identified by in-scope suppliers that are conflict-free. Contents from this excerpt could be included when
98

reporting on the following GRI disclosures and Standards: Disclosure 102-9 Supply chain and GRI 103: Management
Approach (2016).

IBM participates in the Responsible Minerals 3) Performing due diligence by surveying our name
Initiative (RMI), along with over 350 other companies in-scope direct suppliers using the RMI’s are pu
and industry groups, focused on working to resolve Conflict Mineral Reporting Template (CMRT) to Repor
challenges associated with this issue. IBM and ascertain the SORs present in the supply chain.
RMI members are working together to identify, vet, In-sco
converse with and lead the entire portfolio of mem- 4) Working with those SORs to gain their SORs
ber-identified SORs to participate in the Responsible engagement in RMAP or equivalent programs. are re
Minerals Assessment Program (RMAP). RMAP In the spirit of collaborative work, IBM accepts from
was created for SORs that play a crucial role in the the LBMA Good Delivery List, Responsible Miner
extended supply chain, as they are the point at Jewellery Council Chain of Custody Certification, organ
which concentrated ores are refined into the high- TI-CMC as proof of conflict-free stature. them
er-level materials that cascade into technology inform
products. Readers are encouraged to access the To determine information about its upstream comp
RMI website for information on the many tools and sources of 3TG, IBM used multiple iterations of the miner
programs being driven by this important initiative RMI CMRT with its in-scope direct suppliers. The nars a
at responsiblemineralsinitiative.org. CMRT was developed to provide companies with a con
a common format for their upstream suppliers suppl
IBM’s due diligence measures for conflict minerals to identify the use of 3TG, the SORs used in the our co
conform to the framework set forth in the Organi- extended supply chain and, where possible, the
sation for Economic Co-operation and Development country of origin of 3TG. In the fourth quarter of Anoth
(OECD) Due Diligence Guidance for Responsible 2017, IBM deployed the CMRT to our in-scope direct
Supply Chain of Minerals from Conflict-Affected and suppliers representing greater than 95 percent of are as
High-Risk Areas. Our work to date can be summa- our total supply chain expenditures for our covered als. O
rized in four categories: products. We received responses from all of the assoc
in-scope suppliers and learned the identities of 307 to con
1) Establishing a supply chain standard for upstream 3TG SORs located in 61 countries. By proce
conflict minerals. comparing the IBM-identified SORs to the RMAP list with o
and the results of our further due diligence on SORs SORs
2) Performing a Reasonable Country of Origin not participating in one of those third-party audit and V
Inquiry (RCOI) regarding the potential processes, we determined at the end of 2017 that This w
sources of conflict minerals in our products. 92 percent of the SORs identified by our in-scope prom
suppliers were conflict-free or pursuing assessment prepa
(up from 86 percent at year-end 2016). The specific barrie

98  IBM Supply Chain Report, 2017, pg. 50. https://www.ibm.com/ibm/responsibility/2017/assets/downloads/IBM-2017-CRR-SupplyChain.pdf

44
 Example of reporting on provision of definitions related to conflict minerals in sustainability report for
external stakeholders and description of expectations for suppliers communicated in policy (from HP Inc.,
2017)

In this excerpt from HP’s Sustainable Impact Report (2017), the company provides general information on the issue of
conflict minerals, familiarizing the reader with the definition and primary problem of sourcing conflict minerals. HP also
provides a description of its policy for suppliers and demonstrates year-over-year performance data through metrics
such as number of suppliers compliant or in process, number of suppliers believed to source recycled/scrap or from
outside covered countries, and number of suppliers with unknown status.99 Contents from these excerpts could be
included when reporting on the following GRI disclosures and Standards: Disclosure 102-9 Supply chain and GRI 414:
Supplier Social Assessment (2016).
ucts and solutions Appendix

. We also ran policies and monitoring practices, and are A multi-actor supply chain
Chongqing with broadening our vigilance beyond conflict Across our complex, global, multi-actor
knowledge of minerals to a wider range of minerals supply chain, we have the most influence over
and geographies. Through collaborative our direct suppliers. However, in the case of
efforts, we aim to expand the market for trace and precious minerals we recognize
oss the responsibly sourced minerals. that we must work to influence the practices
ember of
of those much deeper in the supply chain. HP
ion Network
m, which has Conflict minerals is an end user of 3TG metals and is typically
four to 10 supply chain stages removed from
xposure of “Conflict minerals” refers to the mineral
the smelters that purchase and process the
the electronics precursors of the metals tantalum, tin,
ore into metals. While conflict minerals are
collaborative tungsten, and gold (3TG) as defined in the
rarely used in large volumes in any one IT
allenges U.S. Securities and Exchange Commission
product or by one company, 3TG metals are
ng chemicals (SEC) rule requiring a conflict minerals
found in relatively small amounts in virtually
uppliers disclosure. Revenue from mining these
all electronic products. For this reason, it is
017, we minerals in the Democratic Republic of
important for HP to work with peers across
ent measuring Congo (DRC) and adjoining countries has
the IT industry to collectively engage the
tandardized been widely linked to funding for groups
entire supply chain in efforts to eradicate
ata on process engaged in extreme violence and human
minerals that may have directly or indirectly
ase study for rights atrocities.
supported armed groups.
al, and adapted
procedure
ds find safer Conceptualization of HP’s supply chain
cals. Conceptualization of HP’s 3TG supply chain

urcing
materials
ed violence or
ceptable. To
99  HP Inc., 2017 Sustainable Impact Report, p. 46-47, http://www8.hp.com/h20195/v2/GetPDF.aspx/c05968415.pdf

e responsibly, 45
 HPchain
Supply Inc. (continued)
Operations Products and solutions Appendix

ted risks • Supporting multi-stakeholder Performance

Operations collaboration
Products to establish secure,
and solutions conflict-
Appendix In 2017, we received acceptable responses Status of all supplier-reported
ound ore free sources of 3TG ores from the DRC to RMI Conflict Minerals Reporting Templates 3TG facilities*
st opportunity from suppliers representing about 98%
350
upporting
isks. Suppliers
multi-stakeholder Performance of our 3TG procurement spend, including
llaboration
melters is to establish secure,
HP sets clearconflict-
expectationsInof2017,
3TG we
suppliers both final
received acceptable Status of all supplier-reported
assembly and commodity
responses 300

ee sources
the risk of of 3TG ores from
in our the DRC
Supply Chain Socialto
and Environmental
RMI These responses detailed 3103TG facilities*
suppliers.Templates
Conflict Minerals Reporting 250

upply chain Responsibility Policy, General

fromSpecification 3TG about
suppliers representing facilities,
98%91% of which were compliant 200
350
pliers
orted armed for the Environment, and of
Supplier Code
our 3TG procurement or in process
spend, to become compliant with an
including 150
etstoclear
rs of Conduct. We assess
expectations of 3TG suppliers
source these suppliers’ independent assessment 300
both final assembly and commodity program, and/
100
Supply Chain Socialresponses
rsmelters to the RMI’s Conflict
and Environmental Minerals
suppliers. or that
These responses we reasonably
detailed 310 believe
250 exclusively

onsibility
ble Minerals Reporting Template,
Policy, General Specification which gives companies source
3TG facilities, 91% of which wereconflict minerals from
compliant 200 recycled or
50

he Environment,
n as CFSI) andaSupplier
commonCode
format for sharing
or ininformation scrap sources
process to become compliant withoranfrom outside of the Covered 0
150
nduct. about 3TG sources
We assess these suppliers’ with business partners 2016 201
e Process independent assessmentCountries
program,(as of March 2018).
and/
100
onses and suppliers
to the RMI’s Conflict
party sourcing Mineralsacross the supply
or thatchain. We
we reasonably believe exclusively
Unknown 31 28
rtinguse
mall Template,
of request corrective
which gives companies action from suppliers U.S. recycled
source conflict minerals from Securities
or and Exchange
50

mmon
fluence,format
so whereinformation
for sharing needed, and provide them
scrap training
sources Commission
or from outside conflict minerals
of the Covered 0 report Believed to source recycled/ 20 22
scrap2016
or from outside
2017 the
t 3TG
and upon request. If
sources with business partners
conflict- any 3TG supplier reports
Countries (as of March 2018).
In May 2018, we filed our Form SD and Covered Countries
suppliers across thesourcing
ork with our fromWe
supply chain. a smelter that triggers one of Conflict Minerals Report with the U.S. SEC
Unknown 31 or in process
28 **
estto
try drive action from suppliers indicators,
corrective our potential risk weSecurities
U.S. work with and Exchange
disclosing our due diligence efforts and
Compliant 260 260

eng.
needed,
We require thethem
and provide supplier to establish whether
training unverified
Commission conflictresults.
minerals report
See our SEC ConflictBelieved
Minerals to source recycled/ *
Report. 20 22
As of March 2018.
material is potentially used in HP products. scrap or from outside the **
request.from
emoving If any 3TG supplier reports In May 2018, we filed our Form SD and Smelters or refiners listed by RMI as currently RMAP
Covered Countries compliant (including certification or accreditation by sim
cing nota smelter When
from
hat do we identify
that triggers a risk ofConflict
one of this occurring, weReport with the U.S. SEC
otential
dit request the supplier
risk indicators, we work with
program. to remove the
Minerals
smelter Other regions andCompliant
mineralsor in process **
independent assessment programs cross-recognized
by RMAP260 260
such as the Responsible Jewellery Council’s
disclosing our due diligence efforts and (RJC) Chain-of-Custody Certification Program, or the
upplier to establish from our unverified
whether supply chain. results. See our SEC ConflictLearning fromReport.
Minerals our experience combating
* As of March 2018.
London Bullion Market Association’s (LBMA) Responsibl
rals in our
erial is potentially used in HP products. conflict minerals in the DRC and surrounding
** Smelters
Gold Programme) or in the process of becoming RMAP
or refiners listed by RMI compliant.
as currently RMAP
Smelters
n we identify a risk of this occurring, we compliant (including certification or accreditation by similar
countries, we are expanding monitoring and
est the supplier
purchase and to remove the smelter
To identify
Other regions and minerals
and disclose these smelters supplier engagement activities
independent assessment programs cross-recognized
to such
by RMAP 3TGasfrom
the Responsible Jewellery Council’s
(RJC) Chain-of-Custody Certification Program, or the
our supply
ergo third- chain. and refiners, between January
Learning all regions,
and from our experience as well as otherLondon
combating minerals linked
Bullion Market Association’s (LBMA) Responsible
Gold Programme) or in the process of becoming RMAP
December 2017 HP surveyed conflict to social
minerals in the DRC
suppliers and human rights risks.
and surrounding
compliant.
elters
liers of which contributed material, countries, we are expanding monitoring and
components,
supplier Our expanded
engagement activities approach is in response to
to 3TG from
entify or manufacturing
and disclose these
3TG (“3TG smelters for products containing
efiners, between
melters to 3TG. Each
January all reported
and smelter or refiner regions, as
waswell as other minerals linked of minerals sourcing
growing awareness
issues
risks.beyond the DRC and surrounding
mber identified
2017 HP surveyed
g audits in at least one oftothe
suppliers social
RMIand human rights
Conflict
countries covered by the U.S. Dodd–Frank
Minerals
h contributed material, Reporting Templates we received.
components,
Our expanded approach is in response to
anufacturing for products containing
growing awareness of minerals sourcing
Each smelter or refiner reported was
rt
issues beyond the DRC and surrounding
ified in at least one of the RMI Conflict www.hp.com/sustainableimpact
countries covered by the U.S. Dodd–Frank
rals Reporting Templates we received.

www.hp.com/sustainableimpact 47

46
Example of a visual layout of the due diligence process (from Philips, 2017)

Philips informs its stakeholders of its due diligence approach and multi-stakeholder initiatives through a visual in its
2017 Annual Report. The infographic provides a broad overview of how Philips is working with stakeholders on the
supply side (to promote in-region projects) and demand side (to share knowledge and best practices), through the five
steps of the OECD Due Diligence Guidance for Responsible Supply Chains.100 Contents from the below excerpt could be
included when reporting on GRI 103: Management Approach (2016).

100  Philips 2017 Annual Report, pg. 207, https://www.results.philips.com/publications/ar17#/downloads

47
 smelter outreach on behalf of the RMAP Smelter Engagement Team to further the RMAP program.

2. Carried Out Independent Third-Party Audit of Supply Chain Due Diligence

ExampleAsofcontemplated
reporting onby OECD Guidance,
provision our due diligence
of year-over-year program
detail on status ofleveraged
smeltersindependent SOR Minerals
by Responsible audits.
AssuranceThe Process
audits conformed to the
(RMAP) audit RMAP(from
status and other similar2018)
Microsoft, programs. Microsoft obtained SOR data from
the RMAP Conformant Smelter List using Reasonable Country of Origin Inquiry Data for member
MSFT. The list identifies SORs that have undergone assessment through the RMAP or industry
In this reporting example from Microsoft’s Form SD in compliance with Section 1502 of the Dodd-Frank Act, the
equivalent program, such as Responsible Jewellery Council (“RJC”) or London Bullion Market
company provides specific, quantitative data to showcase its efforts in reaching an active status among
Association (“LBMA”). We used the list to support certain statements contained in this CMR.
smelters in the RMI’s
Microsoft RMAP auditinprogram.
also participated Microsoft
RMAPs Smelter reports on Team
Engagement the increase
duringinthe
the2017
percentage
reportingof conformant
year.
smelters over the years and breaks this rate down by tin, tantalum, tungsten, and gold refiners. The company
3. Reported
also goes into more granularityon
ofSupply
RMAP Chain Due Diligence
audit statuses, including ‘outreach required’, ‘in communication’, and
others to show where ongoing work is needed. Contents from the below excerpts could be included when
101

reportingWeonhave filed our GRI

the following CMRdisclosures
with the SEC
andand concurrently
Standards: posted
Disclosure it onSupply
102-9 our Responsible Sourcing
chain and GRI website,
414: Supplier Social
which provides
Assessment (2016). additional information about Microsoft’s RSRM Program Results of our RSRM
program are presented in Microsoft Devices Social and Environmental Accountability Report for FY17.
These disclosures meet the fifth step of the OECD Guidance.
Table 1 (below) summarizes the conflict mineral status of the 306 SORs identified in Microsoft’s supply
chain during the 2017 reporting year.
IV. SOR INFORMATION
The RMAP classifies audit status in the following manner:
A. 3TG Processing Facilities
• Conformant: SOR has been audited and found to conform with the relevant audit protocols,
including RMAP, LBMA, or RJC;
Microsoft has made a reasonable good faith effort to collect and evaluate information concerning
3TG SORs provided byRequired:
• Outreach our in-scope suppliers.
SOR is not The
yet active and vast majority
outreach ofRMAP
is needed by our in-scope suppliers provided
member companies
data at a company or divisional
to encourage level. This
SOR participation level of disclosure was expected given the multiple tiers of
in RMAP;
supply chain actors positioned between our in-scope suppliers and 3TG SORs.
• Active: SOR has been engaged but is not yet conformant;

Our supplier• survey data revealed

In Communication: SOR is705
notpotential 3TG
yet active but SORs
is in in the Microsoft
communication supply
with RMAP and/orchain.
memberWe validated
company;
the data by removing duplicate SORs, reconciling multiple SOR names for a single entity, and
eliminating •otherwise invalid SOR names. We then verified if the alleged SORs were active and
Communication Suspended – Not Interested: SOR has strongly communicated a lack of
participants in interest
the RMAP audit program. We determined
in participation; 10 that 306 SORs met this criteria.

Non-Conformant: SOR was audited but found not to conform to the relevant RMAP protocol
The Figures• below provide a visual depiction of the SORs identified in Microsoft’s supply chain by
RMAP audit• status.
RMI Due Figure 2 categorizes
Diligence the SORs
Vetting Restriction by RMAPSOR
- Not Applicable: audit status
cannot and reporting
be audited year. Figure 2
as per RMI’s
indicates that the numbervetting
due diligence of conformant
process; SORs increased from 249 to 253. Figure 3 categorizes the
SORs by 3TG mineral and audit status. A comparison from the 2016 reporting year showed that
• Communication Suspended – Temporarily Ceased Operations: Facility has temporarily ceased
tungsten increased in the number and percentage of conformant and active smelters.
operations

Figure 2. Identified SORs by CFSP Audit Status (2013-2017 Reporting Years)

Table 1: Summary of RMAP Audit Status of Identified SORs

300 Number of SORs

Identified in Microsoft RMAP Audit Status
Supply Chain
Conformant (Indicates RMAP, 252
249LBMA and/or RJC
252
250 conformant)
26 Outreach Required
8 Active 213
5 In Communication
200 6 Communication Suspended - Not Interested
6 Non-Conformant
RMI Due Diligence Vetting Restriction - Not
2
148 Applicable
150
Communication Suspended - Temporarily Ceased
1
Operations

100
78
67 13
55
101  Microsoft, 2018 Conflict Minerals Report, https://www.microsoft.com/en-us/download/details.aspx?id=56968
50 43 40
48
29 28 27 26
Reporting example: Visual depiction
intel.com/responsibility Introduction of Our
due diligence
Business compliance
Environment summary
Supply Chain and information
Diversity Social Impact onAppendix
non-3TG
minerals like cobalt (from Intel, 2017)

Intel’s 2017 sustainability report breaks down the proportion of compliant and active smelter or refiners
(SORs) and reflects on the progress made since 2011. Further, the company reports on use of cobalt in its
products and describes the due diligence process used to ascertain whether the cobalt is responsibly sourced.102
Contents from the below excerpt could be included when reporting on the following GRI Standards:
Pursuit of Responsible GRI 414:
Mineral Sourcing

Supplier Social Assessment (2016) and GRI 414: Supplier Social Assessment (2016).
To maintain the positive progress we’ve made to date
on 3TG and cobalt, we will continue to build upon these
significant results to improve responsible sourcing across
our product lines and materials as we enter new markets
and acquire new companies. More information is available
on our Responsible Minerals website.

Results of our Due Diligence Program 3TG SMELTERS AND REFINERS Cobalt. We use cobalt in Intel’s next-generation 10nm
COMPLIANCE SUMMARY microprocessor manufacturing technology. We have
3TG Progress. Through our annual supply-chain survey
1% surveyed direct suppliers providing Intel with products
process, our suppliers have identified 267 operational 100%
80% 80% 30% 14% 10% 8% 99% containing cobalt to validate that any DRC-originated
smelter and refiner facilities that may process the 3TG 90%
90% 92% cobalt does not use child labor. All suppliers supported
contained in products provided to us. Approximately 86%
80% our cobalt inquiry. We are awaiting information on the
99% of these smelters and refiners participate in an
70% smelters and refiners in our extended supply chain—
independent third-party assurance program, or we 70%
those that supply our direct suppliers. Although these
have reasonably concluded through our own efforts 60%
cobalt supply chains have asserted the cobalt is respon-
that their products are conflict free1 (see chart at right). 50%
sibly sourced, we continue our work to identify all cobalt
Approximately 98% of our relevant suppliers use only
40% smelters or refiners and mineral countries of origin to
smelters and refiners whose products are from conflict-
30% confirm that the underlying supply chain meets our
free sources. Our annual conflict minerals disclosure filed
standards. Our suppliers identified the following cobalt
with the U.S. Securities and Exchange Commission (SEC) 20%
20% 20% suppliers: Dynatech Madagascar Company; Glencore
contains additional information regarding our 10%
Nikkelverk AS; Freeport Kokkola; Kola Mining and
3TG due diligence practices and is available on our 0% Metallurgical Company; and Sumitomo Metal Mining
Responsible Minerals website. 2011 2012 2013 2014 2015 2016 2017
Co., Ltd.
Compliant/Intel Validated/Active Not Active
1
“Conflict-free” refers to products, suppliers, supply chains, smelters, and refiners that, based on our due diligence, do not contain or source tantalum, tin, tungsten, or gold that directly or indirectly finance or benefit armed
groups in the Democratic Republic of the Congo or adjoining countries.
Supply Chain Responsibility 44

102  https://www.intel.com/content/www/us/en/corporate-responsibility/csr-report-builder.html
49
 Example of reporting on the development of due diligence tools like the Risk Readiness Assessment (RRA)
and inclusion of data on non-3TG minerals like cobalt (from Apple, 2018)

In Apple’s 2018 Supplier Responsibility Progress Report, the company displays third-party assessment participation for
smelters working with 3TG and cobalt. The additional information from Apple on smelter and refiner participation in
third-party assessments gives context to reporting on the status of smelters and refiners. Here, Apple goes beyond
the expectations of Section 1502 of the Dodd-Frank Act, which focuses on reporting on 3TG – Apple has included
reporting on cobalt for 2016 and 2017.103 Contents from the below excerpt could be included when reporting on the
following GRI disclosures and Standards: Disclosure 102-9 Supply chain and GRI 103: Management Approach (2016).

Third-Party Assessment Participation

3TG and Cobalt

300

256 260
242 100% 100%
225 100%
225 211
186
175 88%

150

109

75 44%

14%
0
2% 6%
2009 2010 2011 2012 2013 2014 2015 2016 2017
3TG 3TG 3TG 3TG 3TG 3TG 3TG 3TG and 3TG and
Cobalt Cobalt

Identified Smelters Smelters Participating

in Third-Party Audits

We’re proudly recognized as a worldwide leader in the responsible sourcing

of minerals in our products.

“Apple proved to be the top industry leader in the

Enough Project’s 2017 conflict minerals rankings due
#1 Ranking
to the company’s leading work on supply chain risk
Enough Project assessment and mitigation, active participation in
multi-stakeholder working groups, and support for
programs in Congolese mining communities.“
John Prendergast
103  https://www.apple.com/supplier-responsibility/pdf/Apple_SR_2018_Progress_Report.pdf
Founding Director, Enough Project
50
Reporting example on mid-stream actor’s identification of risks and follow-up actions (from Umicore, 2017)

Umicore included an annex in their 2017 compliance report for cobalt, specifically detailing identified risks in the
supply chain for that year, along with the level of risk, whether the supplier was ‘material’ (contributing more than 1%
to the total yearly cobalt supply), follow-up actions and the status of these cases. The annex demonstrates a proactive
approach to reporting on risks in mineral supply chains other than 3TG.104 Contents from the below excerpt could
be included when reporting on the following GRI Standards: GRI 205: Anti-corruption (2016) and GRI 414: Supplier
Social Assessment (2016).

104  https://www.umicore.com/en/cases/sustainable-procurement-framework-for-cobalt/compliance-report
51
 12. How can organizations report on the impacts that they are
involved with related to sourcing minerals?

“Too many companies write generic one-pagers on “It’s important to ensure that individual incident
what they commit to doing rather than what they indicators, like cases of forced labor, are
have actually done. While supply chain due diligence complemented wherever possible by bigger picture
and reporting alone will not end conflict in eastern indicators that track local development at the
Congo or prevent corruption and human rights provincial level, including security and violence rate
abuse, they are important steps toward making (real and perceived), human development indicators
sure that companies’ mineral supply chains are not (like school completion rate, local poverty rates) and
conduits for such harms and are part of the solution local government improvement rates (revenues from
to these complex issues. Detailed public reporting by minerals for example). Such information puts individual
companies on how they have identified and addressed indicators in context.”
supply chain risks over time helps to create and
demonstrate progress towards this end.” ATEA SVERIGE

ENOUGH PROJECT For organizations it is difficult to link their due diligence

efforts through the supply chain to specific human
rights outcomes in the upstream. That is why providing
Participants in GRI and the RMI’s Corporate Leadership
contextual information describing mine-level/on-the-
Group spoke about difficulties in understanding what
ground issues is especially important. One factor
needs to be reported when it comes to impacts at the
complicating this explicit linkage is the challenge of
furthest upstream part of the supply chain, at the mine
confidentiality. Since downstream companies cannot
site and its local community. Guidance and tools for
typically identify individual mines they source from
reporting on the process of due diligence (how impacts
and are not expected to do so under the OECD Due
are addressed) should be complemented with similar
Diligence Guidance for Responsible Mineral Supply
resources for reporting on actual adverse impacts, as
Chains, it becomes difficult to link due diligence
well as reporting positive impacts within the region
processes such as audits or engagement with smelters
where sourcing, processing, and trading occurs.
to direct (positive or negative) outcomes within the
mines and local communities. However, an organization’s
Companies discussed the related challenges of selecting
contextual information about on-the-ground efforts
metrics for reporting this type of information, including
to address adverse impacts, the leverage they exert
reporting consistently year on year, and finding
in the supply chain, and goal to promote positive
comparable ways of reporting across varying industries.
impacts provides stakeholders with a view as to the
Many expressed worries of setting unachievable targets.
organization’s broad support for addressing human rights
In addressing this concern, CSOs suggest that target-
issues related to its mineral sourcing.
setting should be step-wise rather than take the form
of ambitious goals like ‘100% conflict-free.’ Further,
leveraging external data sources and providing context
to describe the mine-level/on-the-ground situation can
lessen negative reactions to reported information.

52
 Current Practice: Reporting more in-depth
measurement of impact on mining communities
Methodologies and approaches are beginning to emerge
for measuring impact deeper in the supply chain. For
example, in its 2019 Conflict Minerals Report, Apple
provides a summary of its efforts and partnerships with
organizations to measure adverse impacts on human
rights in its 3TG supply chain.

Inclusion of examples from reporting organizations does

not imply endorsement – these examples are included as
a means of illustrating current reporting practice and as a
source of inspiration.

Apple also maintains a grievance mechanism through a dedicated 3TG email address that allows suppliers to report concerns or grievances
in connection with 3TG mining, processing, and trading. The concerns or grievances submitted through this mechanism are then reviewed
with the participation of relevant Apple business teams, and follow-up activities are conducted as appropriate.

Going Beyond: Working Together with Stakeholders for Progress

Apple works to make industry-wide progress on responsible minerals sourcing, beyond its own supply chain. As part of this commitment,
Apple engaged with a broad range of civil society, industry, and government experts and partnered with the Enough Project, an international
human rights organization, to convene a series of expert group meetings to discuss opportunities to work collectively on innovative
approaches to the responsible sourcing of minerals in the supply chain.

Starting in 2017, as part of its commitment to industry-wide progress, Apple benchmarked the scope and requirements of dozens of third-
party sustainability standards, including upstream protocols for mineral processors and mining companies, and published this information in
its Responsible Sourcing Standard. Continuing through 2018, Apple analyzed additional third-party sustainability standards and updated its
benchmarking to include organizations and standards that had been strengthened and now aligned with Apple’s standards in specific risk
categories. Apple also updated its risk mapping requirements in support of the principles of the Extractive Industries Transparency Initiative at
the mining company level.

In 2018, Apple also supported the development of certain industry-wide standards, including the Responsible Artisanal Gold Solutions
Forum’s Artisanal Gold Due Diligence Toolkit; the Code of Risk-mitigation for ASM (artisanal and small-scale mining) engaging in Formal
Trade (CRAFT Code) developed by the Alliance for Responsible Mining and RESOLVE, Inc., a nonprofit organization; and the Blockchain
Guidelines of the Responsible Business Alliance’s Responsible Minerals Initiative (“RMI”).

Apple also worked with the International Organization for Migration (“IOM”) to provide background information and related support in
connection with the development of a set of guidelines for industry actors on how to address confirmed allegations in the upstream supply
chain in accordance with UN Guiding Principles. In 2018, IOM published these guidelines as the Remediation Guidelines for Victims of
Exploitation in Extended Mineral Supply Chains in English, French, Spanish, and Chinese and made them available to other industries.

In 2018, Apple chaired the board of the Responsible Business Alliance, served on the Steering Committee of the RMI, continued its
participation in the European Partnership for Responsible Minerals, and served on the Governance Committee of the Public-Private Alliance
for Responsible Minerals Trade. Apple also contributed to several RMI working groups, including, but not limited to, the working groups for tin,
gold, and other minerals; the smelter engagement team; the blockchain team; and the minerals reporting template team.
 
Apple Inc. | 2018 Conflict Minerals Report | 5

In this chapter, Section I deals with reporting adverse

impacts related to mineral sourcing while Section II
provides guidance for reporting on positive impacts
related to mineral sourcing.

53
 12.1 How can organizations report on adverse iii. the worst forms of child labour;
impacts related to mineral sourcing? iv. other gross human rights violations and abuses such
as widespread sexual violence;
The impact of mineral sourcing touches economic, v. war crimes or other serious violations of
environmental, and social dimensions. For example, international humanitarian law, crimes against
miners in the DRC describe challenges such as armed humanity or genocide.”
looting of the mines – thus depriving them of their work
and livelihood – and illegal taxes that they must pay The Annex II Model Policy also includes “direct or
to state and non-state armed groups.105 The situation indirect support to non-state armed groups”, “bribery
is further complicated because just as in some cases and fraudulent misrepresentation of the origin of
military groups depend on mines for revenue, Congolese minerals”, “money laundering”, and “payment of taxes,
people also depend on mines for their livelihood.106 The fees and royalties to governments and private/public
majority of mines in the DRC are artisanal and small- security forces”. These “adverse impacts associated with
scale, meaning mining is often conducted via hand-tools extracting, trading, handling, and exporting minerals from
and minimal mechanization is used.107 conflict-affected and high-risk areas” are summarized
in Table 5 along with the GRI Standards under which
Women and children often face a greater burden reporting on these impacts can be integrated.111
compared to men, as women are frequently victims
of sexual violence and children are forced to work for Current Practice: Reporting on adverse impacts
a variety of social and economic reasons.108 Further, Some companies have begun early efforts to measure
women and children who work in the mines often and report on actual adverse impacts that they identify
lack the resources to receive an education and remain and aim to address through their due diligence efforts
illiterate.109 that attempt to address adverse impacts.
See an example below. Inclusion of examples from
The OECD Due Diligence Guidance for Responsible Supply reporting organizations does not imply endorsement –
Chains has described the following impacts as “serious these examples are included as a means of illustrating
abuses associated with the extraction, transport or trade current reporting practice and as a source of inspiration.
of minerals” in its Annex II, “Model Supply Chain Policy
for a Responsible Global Supply Chain of Minerals from
Conflict-Affected and High-Risk Areas” (Annex II Model
Policy):110

i. any forms of torture, cruel, inhuman and degrading

treatment;
ii. any forms of forced or compulsory labour, which
means work or service which is exacted from any
person under the menace of penalty and for which
said person has not offered himself voluntarily;

105  https://www.globalwitness.org/mining-for-our-minerals/
106  https://www.bsr.org/reports/BSR_Conflict_Minerals_and_the_DRC.pdf
107  https://www.bsr.org/reports/BSR_Conflict_Minerals_and_the_DRC.pdf
108  https://www.globalwitness.org/en-gb/campaigns/conflict-minerals/conflict-minerals-eastern-congo/
109  http://www.cidse.org/articles/business-and-human-rights/conflict-minerals/gender-based-violence-and-mining-fuelled-conflict.html
110  In the Responsible Minerals Sourcing CLG, participants often referred to this list as “Annex II risks” or “Annex II impacts”
111  While not a focus of Table 5, impacts of mineral extraction can also be seen in the environmental dimension. Mining can have consequences for example for
water, soil, and air including erosion, deforestation, biodiversity loss, and water pollution. Artisanal mining, too, has led to impacts such as deforestation to allow
more space for the mine and operations, poor waste management, and water contamination due to mineral washing. In the process of gold mining, mercury
emissions into the soil and water also leads to contamination of resources used for consumption. Site rehabilitation in the artisanal mining industry is not always
done.
54
 GRI 103: 103-1 Explanation of the material Ethical trade and human rights (p. 14-15, 39-40)
Management topic and its Boundary
approach 2016
103-2 The management approach Our approach to ethics and sustainability (p. 61-62)
and its components

103-3 Evaluation of the Colleague wellbeing (p. 54)

management approach Performance against 2017 targets (p. 63-65)
We include relevant performance benchmarks throughout the Report

Example
GRI 407: of reporting
Freedom of
407-1 on risk
Operations of labor
and suppliers
which the right to freedom
in exploitation
As per our Sound Sourcing Codeand modern
of Conduct we requireslavery (from
our suppliers to The
protect those rights;Co-op)
and suppliers must demonstrate the measures
taken to achieve this. Whilst we report the number of non-compliances and monitor implementation of corrective actions, we do not report by
association of association and collective operation type or geographic location. Freedom of Association and Collective Bargaining form part of our risk criteria which is covered during
and collective bargaining may be at risk audits.
bargaining 2016 Ethical trade and human rights (p. 43)
In itsChild
2017labour
sustainability reporting, the Co-op reports in detail on risks within the company’s extensive supply chains
withGRIa103:
focus on103-1
Management
humanExplanation
rights ofissues suchEthical
the material
topic and its Boundary
as forced labor
trade and human rights highlighted
(p. 14-15, 39-40) in a separate Modern Slavery Statement. The
approach 2016
extract below informs 103-2 onmanagement
The the company’s
approach awareness
Our approach to ethicsand transparency
and sustainability (p. 61-62) towards incidences of human rights abuses
and its components
occurring within their supply
103-3 Evaluation ofchain
the and shows
Performance that
againstthey actively
2017 targets (p. 63-65) addressed the issue.
112, 113
Contents from the below
management approach We include relevant performance benchmarks throughout the Report
excerpts could408-1
GRI 408: Child
be included when reporting
Operations and suppliers at
on GRI 409: Forced or Compulsory Labor (2016).
As per our Sound Sourcing Code of Conduct we do not allow child labour within our supply chain and we report figures relating to incidents that
labour 2016 significant risk for incidents occur and implementation of corrective actions. Our risk criteria and audit process for our supply chain has robust measures to contribute to
of child labour the effective abolition of child labour. However we do not include supplier information, operation type or geographic location in our published
report
Ethical trade and human rights (p. 43)

Forced or compulsory labour

GRI 103: 103-1 Explanation of the material Ethical trade and human rights (p. 14-15, 39-40)
Management topic and its Boundary
approach 2016
103-2 The management approach Our approach to ethics and sustainability (p. 61-62)
and its components

103-3 Evaluation of the Performance against 2017 targets (p. 63-65)

management approach We include relevant performance benchmarks throughout the Report

GRI 409: Forced 409-1 Operations and suppliers at Ethical trade and human rights (p. 14-15, 40-44). We report full details in our Modern Slavery Statement https://www.co-operative.coop/ethics/
or compulsory significant risk for incidents modern-slavery
labour 2016 of forced or compulsory
labour

10 Co-op Way reporting 2017 GRI Index All page references refer to our Co-op Way Report 2017, unless otherwise stated.

More reported information on how Co-op addresses modern slavery can be found here

112  https://assets.ctfassets.net/5ywmq66472jr/7wd32Ymn5uWyo8MA6MiWS6/2637772911d30a57d13215b2db69d737/GRI_Index_-_Co-op_Way_
reporting_2017.pdf
113  https://assets.ctfassets.net/5ywmq66472jr/1eKEGGvdjqbqRZ2dOdYAMZ/91328f8a9619d752ccf3b4a397c77f04/Modern_Slavery_Statement_2018.pdf
55
 Table 5 Suggestions for reporting on impacts of mineral sourcing
Impact resulting from mineral sourcing derived from OECD GRI Standards and Disclosures under which content can be
Annex II risk reported

Impact mentioned Incidents of bribery and fraudulent GRI 205: Anti-corruption (2016)
in OECD Due misrepresentation of origin of
Diligence Guidance
for Responsible Supply
minerals (by entities in the supply
Chains Annex II chain like smelters or refiners),
monetary impact
Incidents of money laundering, GRI 205: Anti-corruption (2016)
monetary impact
Presence of forced or compulsory GRI 409: Forced or Compulsory Labor (2016)
labor
Presence of worst forms of child GRI 408: Child Labor (2016)
labor
Occurrences of sexual violence Disclosure 406-1 Incidents of discrimination and
corrective actions taken
Incidents of torture, cruel, Disclosure 410-1 Security personnel trained in human
inhuman and degrading treatment rights policies or procedures
Disclosure 411-1 Incidents of violations involving rights of
Occurrences of war crimes, indigenous peoples
crimes against humanity, genocide Disclosure 412-1 Operations that have been subject to
Direct or indirect support to non- human rights reviews or impact assessments
state armed groups Disclosure 412-2 Significant investment agreements
and contracts that include human rights clauses or that
Payment of taxes, fees and
underwent human rights screening
royalties to governments and
public/private security forces
Your organization can also report on these adverse
impacts by using additional disclosures from other
sources to report on material topics covered by the GRI
Standards, as well as reporting the GRI disclosures [See
GRI 101]: “Any additional disclosures are expected to
be subject to the same technical rigor as the disclosures
in the GRI Standards, and to be consistent with other
established standards or reporting frameworks where
available and relevant.”1

Other established standards or reporting frameworks

your organization might consider in this case are the UN
Guiding Principles for Business and Human Rights and
the UN Guiding Principles Reporting Framework.
GRI-RMI Corporate •  number of incidents/types of GRI 403: Occupational Health and Safety (2018)
Leadership Group child labor (focus on worst
Suggestions
forms of child labor) occurring
in mining areas
•  number and types of incidents
(armed groups, criminal
activity)
•  number of deaths from mining
accidents (types - cave ins2

1  GRI 101: Foundation (2016), pg. 19

2  Note: a low number of incidents of human rights violations does not necessarily imply a low level of human rights violations, but could imply low levels of
reporting or mischaracterization.
56
12.2 How can companies report on positive Initiatives that pursue positive impacts and go beyond
impacts related to mineral sourcing? due diligence include local-level partnerships that
address human rights issues or focus on community-
Positive impacts of mineral sourcing might include building. Local organizations can lend their knowledge
economic support of miners’ livelihoods. They can and expertise, effectively focusing on opportunities to
also include an organization’s mineral sourcing-related create the most lasting, effective, and positive economic,
initiatives developed to promote positive change in the environmental, and social outcomes.
producing country.
The following pages contain examples of extracts of
Some of these positive impacts and related GRI reporting on some of the contents mentioned above.
disclosures are described in Table 6 below. Inclusion of examples from reporting organizations does
not imply endorsement – these examples are included as
Table 6 Mineral sourcing-related positive impacts a means of illustrating current reporting practice and as a
Positive impacts GRI Standards and source of inspiration.
related to mineral Disclosures under
sourcing which content can be
reported
Positive economic benefits GRI 413: Local Communities
imparted on the community (2016)
•  Jobs created
•  Infrastructure created

Some resources for gaining a deeper understanding of

mineral sourcing-related impacts are presented below.

\\ International Peace Information Service (IPIS) Conflict

Mapping
\\ Five years of implementing supply chain due diligence

“Reporting on the progress of our partnership with

Pact has provided useful information to a variety of our
stakeholders and enabled Microsoft to gain a deeper
understanding of issues from experts in minerals
sourcing. This means we can continue to learn and
increase the effectiveness of our programs supporting
responsible minerals sourcing at the source.”

MICROSOFT

Along with understanding how an organization identifies,

prevents, mitigates, and potentially remediates adverse
impacts of mineral sourcing, looking at how it promotes
positive impacts on the ground is also important. That
said, directly attributing negative and positive human
rights outcomes to an organization’s due diligence
processes and supportive measures can be challenging.

57
 Example of reporting on partnership with an international development organization involved in projects in
the DRC (from Microsoft, 2018)

8/1/2019 Working together to expand the fight against child labor in mining - Microsoft on the Issues
Many organizations work on mitigating the adverse impacts of mineral sourcing and many companies have partnered
with these organization in their goal to diminish their impacts. For example, in the excerpt below114 from a blog on
This starts with eliminating child labor in our own supply chain.
Microsoft’s corporate website (2018), the company describes its partnership with an international non-governmental
We do this through mapping our supply chain, requiring our Stay Connected
organization (Pact). Microsoft includes
suppliers information
comply with ouronpolicies
reductions
andinconducting
child labor in minestowhere the project has been
audits
active and provides detailsensure theyactivities
on specific — and their upstream
it supports suppliers
including — comply.programs
apprenticeship But this for adolescents and
increased capacity of localisorphanages.
a global issue requiring
Contents froma the
global response
below excerptbeyond
could bethe actionswhen reporting on GRI
included
of any one single company.
413: Local Communities (2016). Have the latest posts se
right to your inbox. Ent
That is why today we are announcing a deepened, long- your email below.
term partnership with Pact, a leading nonprofit international By providing your email addr
development organization. This commitment will enable Pact to you will receive email update
expand its critical work in the Democratic Republic of Congo to from the Microsoft on the Iss
reduce child labor in mining. blog.

This partnership builds on our existing work with Pact, with Email Add S
whom we’ve worked since 2015. Through this partnership, the
successful Watoto Inje ya Mungoti (Children Out of Mining)
project was launched; it uses interventions that are deeply
embedded in communities and local institutions to address the
economic and social root causes that lead to child labor in
mining. In mines where the project has been active, Pact has
found a reduction in child labor between 77 and 97 percent
over the course of the project to date, with variation influenced
by seasonal factors and the influx of new conflict-displaced
families, among other factors.

Through our expanded partnership, we will work with Pact to

provide more direct support to children and adolescents and
the local organizations that support them. Activities will include
developing an apprenticeship program for older adolescents,
improving the capacity of local orphanages, assessing state
child protection and welfare services, and supporting home-
based day care for younger children of miners.

The data and personal stories of change outlined in Pact’s most

recent report make it clear that these localized intervention
strategies are effective at driving change on the ground in
mining communities. And they reaffirm and support our overall
strategy to responsible sourcing.

“At the heart of Pact is the promise of a

better tomorrow. Through our long-term
partnership with Microsoft, we are making
continued, meaningful progress toward
addressing the economic and social root
causes that lead to child labor in mining.”
https://blogs.microsoft.com/on-the-issues/2017/08/30/working-together-expand-fight-child-labor-mining/
114 Source: https://blogs.microsoft.com/on-the-issues/2017/08/30/working-together-expand-fight-child-labor-mining/
58
 Example of reporting on partnership with an international non-governmental organization and support
“Private-sector involvement is one of the fastest
given to local in-region organizations (from Apple, 2018)
ways to achieve change at scale and is critical
for the systemic change necessary to tackle child
In Apple’s Supplier Responsibility Report (2018),115 the organization provides information on another initiative (Fund
labor in mining. Apple’s support of vocational
for Global Human Rights) that supports local organizations in the DRC to positively impact a range of problems
education promotes more career opportunities
associated with mining in the region, including social and economic issues. Contents from the below excerpt could be
for future generations.“
included when reporting on GRI 413: Local Communities (2016).
Mark Viso
President and CEO, Pact

In addition to our on-the-ground efforts with Pact, Apple awarded a grant to

the Fund for Global Human Rights in 2017. Since 2003, the Fund has worked
to advance human rights by providing resources to activists and grassroots
organizations that have the potential to generate positive change in over 17
countries. Apple partnered with the Fund to support their work in the DRC.
Local organizations in the DRC receive grants from the Fund working on a
range of issues, including the rights of women and children; economic and
social rights of mining communities; inclusive economic growth; judicial
advocacy; and health, safety, and fair compensation for mining communities.

e Supplier Responsibility 2018 Progress Report 25

115  https://www.apple.com/supplier-responsibility/pdf/Apple_SR_2018_Progress_Report.pdf
59
 9/19/2019 Congo Power | Google Sustainability

We know there are no quick solutions. History, as well as our own experience with communities around the world, tells
Example of reporting on pilot projects focused on making positive sustainability impacts in the DRC (from
us that environmental and economic changes in the DRC will demand time and patience. Most importantly, these
Google, 2018)
changes must be led by Congolese partners within the communities and supported by improved governance of the
energy and economic sectors.
Google provides another example of reporting on positive sustainability impacts made in the supply chain,116 including
numerous
Movingspecific initiatives
too rapidly on athe
or without ground
nuanced in the DRC;of athe
understanding notable
complexexample highlighted
social and in theinexcerpt
political factors from
play could leadGoogle’s
to
website below outlines pilot projects developed by the organization to develop clean energy solutions
unintended negative consequences. That’s why our multi-tiered Congo Power initiative, launched in late 2017, focusesin mining
communities in the
on bolstering DRC,
local while
efforts withenabling
measured,increased accessibility to energy within these communities.117 Contents from
scalable steps.
the excerpt could be included when reporting on GRI 413: Local Communities (2016).
Our first step was to help frame the DRC’s power potential through comprehensive discovery trips to gain firsthand
insights. From there, we conducted extensive field research to explore and evaluate potential projects that could help
the Congolese living at or near mining communities. And we’re now in the pilot phase.

Congo Power’s pilot projects fall into three major categories: point-of-use power solutions designed to support
individuals such as due diligence personnel and mining staff; microgrids designed to support residential communities
and targeted commercial, industrial, and agricultural use; and phased support and ongoing investment of funding and
technical expertise in regional electrification.

Solar energy can power electronic devices used to record gold transactions, supporting traceability.

Sustainability
https://sustainability.google/projects/congo-power/ 4/7

116  https://sustainability.google/responsible-supply-chain/
117  https://sustainability.google/projects/congo-power/
60
Example of reporting on partnerships that aim to tackle impacts of sourcing materials beyond 3TG like tin,
mica, and cobalt (Philips, 2018)

In Philips’ 2018 Annual Report, the organization reports on multi-stakeholder initiatives where it participates, including
the Responsible Mica Initiative. The company also works with phone manufacturer Fairphone, to engage with a cobalt
refiner that has subsidiaries in the DRC. The goal is to cooperate with artisanal and small-scale cobalt mine sites to
mitigate some of the identified impacts of sourcing cobalt.118 The excerpt could be included when reporting on GRI
413: Local Communities (2016).

118  https://www.results.philips.com/publications/ar17?type=annual-report#d16e65293
61
62
Appendix A: Key Q&A

What does sourcing responsibly mean with regard to

mineral sourcing?
Responsible mineral sourcing means addressing impacts
of sourcing minerals that lead to negative economic,
environmental, or social impacts. This can be done through a
combination of measures, including policies, due diligence, and
remediation.119 It can also mean making positive contributions
in places where the sourcing is happening.

The aforementioned impacts include those that constitute

serious abuses associated with the extraction, transport or
trade of minerals, referred to as Annex II risks throughout
this document. Reporting on due diligence and supportive
measures to address these risks in the Great Lakes region
forms the focus of this publication.

A key reference document is the OECD Due Diligence Guidance

for Responsible Supply Chains which provides steps “for detailed
due diligence as a basis for responsible global supply chain
management of minerals with a focus on respecting human
rights and avoid contributing to conflict through their sourcing
decisions, including the choice of their suppliers. By doing so,
this Guidance will help companies contribute to sustainable
development and source responsibly from conflict-affected
and high-risk areas, while creating the enabling conditions for
constructive engagement with suppliers” (pg. 12).

Which minerals should a company report on?

The OECD Due Diligence Guidance for Responsible Supply
Chains provides a framework for detailed due diligence,
including reporting, as a basis for responsible supply chain
management of all minerals. The objective of the OECD Due
Diligence Guidance for Responsible Supply Chains is to “help
companies respect human rights and avoid contributing to
conflict through their mineral sourcing practices with a view to
enabling countries to benefit from their mineral resources and
preventing the extraction and trade of minerals from

becoming a source of conflict, human rights abuses, and

insecurity” – thus its scope includes any minerals that may
contribute to conflict, human rights abuses, and insecurity.

119  Pg. 21, http://mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-

for-Responsible-Business-Conduct.pdf
63
 Minerals that are addressed in current supply chain due What are GRI’s requirements for external assurance for
diligence regulations include: tin, tungsten, tantalum, and gold reporting?
(3TG). More information on regulatory reporting expectations When preparing a report in accordance with GRI Standards,
for these minerals can be found here. reporting organizations must comply with the reporting
requirement for Disclosure 102-56, External assurance. This
Companies should identify the minerals and metals related to refers to “activities designed to result in published conclusions
sustainability topics that are material to their organization. For on the quality of the report and information contained within
example, the impacts of sourcing minerals outside 3TG, like it,” including assurance of systems and processes, such as the
cobalt, gemstones, diamonds, copper or mica, may render a application of the Materiality principle.
topic material due to significance of impacts or importance
to stakeholders. In this case, the organization is expected to Disclosure 102-56 External Assurance requires the following
include these minerals in their reporting activities. information:
a. “A description of the organization’s policy and current
Can a company source minerals from a conflict-affected practice with regard to seeking external assurance for the
and high-risk area? report.
An organization can first begin to understand whether it is b. If the report has been externally assured:
sourcing 3TG originating from a conflict- affected and high-risk i. A reference to the external assurance report,
areas by conducting a Reasonable Country of Origin Inquiry statements, or opinions. If not included in the
(RCOI). This requires a company to engage with its supply assurance report accompanying the sustainability
chain through data requests to understand whether further report, a description of what has and what has
due diligence is required. 120
RCOI, a term used in the Dodd- not been assured and on what basis, including the
Frank Act, is a process that may be helpful to any organization assurance standards used, the level of assurance
seeking to identify whether the materials used for its products obtained, and any limitations of the assurance
originate from conflict-affected and high-risk areas globally. process;
ii. The relationship between the organization and the
Companies can pursue responsible sourcing from conflict- assurance provider;
affected or high-risk areas through OECD-aligned due iii. Whether and how the highest governance body or
diligence processes. Companies can collect information from senior executives are involved in seeking external
their value chains using the RMI’s Conflict Minerals Reporting assurance for the organization’s sustainability report.”
Template (CMRT) or Cobalt Reporting Template (CRT) and
verify the information received.

120  https://conflictmineralsresources.com/what-is-rcoi/
64
Appendix B: Key terms related to mineral sourcing

This glossary provides an explanation for key terms used violence. Such areas are often characterized by widespread
within this toolkit, collected from commonly recognized key human rights abuses and violations of national or international
documents and tools related to mineral sourcing. law

Key terms from OECD Due Diligence Guidance Downstream: ‘Downstream’ means the minerals supply
for Responsible Supply Chains chain from smelters/refiners to retailers. ‘Downstream
Link to Guidance: http://trade.ec.europa.eu/doclib/docs/2018/ companies’ include metal traders and exchanges, component
august/tradoc_157243.pdf manufacturers, product manufacturers, original equipment
manufacturers (OEMs) and retailers. The Guidance
Annex II risks: The OECD Due Diligence Guidance for recommends, among other things, that downstream
Responsible Supply Chains defined “serious abuses associated companies identify, to the best of their efforts, and review
with the extraction, transport or trade of minerals” in its the due diligence process of the smelters/refiners in their
Annex II (“Model Supply Chain Policy for a Responsible Global supply chain and assess whether they adhere to due diligence
Supply Chain of Minerals from Conflict-Affect and High-Risk measures put forward in this Guidance. Downstream
Areas”): 121
companies may participate in industry-wide schemes that
assess smelters/refiners’ compliance with this Guidance and
i. “any forms of torture, cruel, inhuman and degrading may draw on the information these schemes provide to help
treatment; them fulfil the recommendations in this Guidance.
ii. any forms of forced or compulsory labour, which means
work or service which is exacted from any person under Upstream: In the Supplement on Tin, Tantalum and Tungsten,
the menace of penalty and for which said person has not ‘upstream’ means the mineral supply chain from the mine
offered himself voluntarily; to smelters/refiners. ‘Upstream companies’ include miners
iii. the worst forms of child labour; (artisanal and small-scale or large-scale producers), local
iv. other gross human rights violations and abuses such as traders or exporters from the country of mineral origin,
widespread sexual violence; international concentrate traders, mineral re-processors and
v. war crimes or other serious violations of international smelters/refiners…This Guidance calls on these upstream
humanitarian law, crimes against humanity or genocide.” companies to provide the results of risk assessments to their
downstream purchasers and have the smelters/refiners’ due
Annex II risks also include support to non-state armed groups, diligence practices audited by independent third parties,
private public security forces, bribery, money laundering, non- including through an institutionalized mechanism.
payment of taxes, and fraud.
Key terms from Dodd-Frank Act Section 1502
Conflict-Affected High-Risk Areas (CAHRAs): Conflict- Link to legislation: https://www.sec.gov/rules/
affected and high-risk areas are identified by the presence of final/2012/34-67716.pdf
armed conflict, widespread violence or other risks of harm to 1. Adjoining country. The term adjoining country means a
people. Armed conflict country that shares an internationally recognized border
may take a variety of forms, such as a conflict of international with the Democratic Republic of the Congo.
or non-international character, which may involve two 2. Armed group. The term armed group means an armed
or more states, or may consist of wars of liberation, or group that is identified as a perpetrator of serious human
insurgencies, civil wars, etc. High-risk areas may include areas rights abuses in annual Country Reports on Human
of political instability or repression, institutional weakness, Rights Practices under sections 116(d) and 502B(b) of
insecurity, collapse of civil infrastructure and widespread the Foreign Assistance Act of 1961 (22 U.S.C. 2151n(d)
and 2304(b)) relating to the Democratic Republic of the
Congo or an adjoining country.
121  In the Responsible Minerals Sourcing CLG, participants often referred to this list as “Annex II risks” or “Annex II impacts”
65
 3. Conflict mineral. The term conflict mineral means: internationally recognized due diligence framework”
i. Columbite-tantalite (coltan), cassiterite, gold, means a nationally or internationally recognized due
wolframite, or their derivatives, which are limited diligence framework established following due-process
to tantalum, tin, and tungsten, unless the Secretary procedures, including the broad distribution of the
of State determines that additional derivatives are framework for public comment, and is consistent with the
financing conflict in the Democratic Republic of the criteria standards in the Government Auditing Standards
Congo or an adjoining country; or established by the Comptroller General of the United
ii. Any other mineral or its derivatives determined by States.
the Secretary of State to be financing conflict in the
Democratic Republic of the Congo or an adjoining Key terms from EU Mineral Supply Chain Due
country. Diligence Regulation
4. DRC conflict free. The term DRC conflict free means Helpful guide:
that a product does not contain conflict minerals http://trade.ec.europa.eu/doclib/docs/2017/march/
necessary to the functionality or production of that tradoc_155423.pdf
product that directly or indirectly finance or benefit EU legislation:
armed groups, as defined in paragraph (d)(2) of this item, https://eur-lex.europa.eu/eli/reg/2017/821/oj
in the Democratic Republic of the Congo or an adjoining
country. Conflict minerals that a registrant obtains from For the purpose of this Regulation, the following definitions
recycled or scrap sources, as defined in paragraph (d)(6) apply:
of this item, are considered DRC conflict free. a. minerals’ means the following, as listed in Part A of Annex
5. DRC conflict undeterminable. The term DRC conflict I:
undeterminable means, with respect to any product •  ores and concentrates containing tin, tantalum or
manufactured or contracted to be manufactured by a tungsten, and
registrant, that the registrant is unable to determine, after •  gold;
exercising due diligence as required by paragraph (c)(1) of b. ‘metals’ means metals containing or consisting of tin,
this item, whether or not such product qualifies as DRC tantalum, tungsten or gold, as listed in Part B of Annex I;
conflict free. c. ‘mineral supply chain’ means the system of activities,
6. Conflict Minerals from Recycled or Scrap Sources. organisations, actors, technology, information, resources
Conflict minerals are considered to be from recycled or and services involved in moving and processing the
scrap sources if they are from recycled metals, which are minerals from the extraction site to their incorporation in
reclaimed end-user or post-consumer products, or scrap the final product;
processed metals created during product manufacturing. d. ‘supply chain due diligence’ means the obligations of
Recycled metal includes excess, obsolete, defective, and Union importers of tin, tantalum and tungsten, their
scrap metal materials that contain refined or processed ores, and gold in relation to their management systems,
metals that are appropriate to recycle in the production risk management, independent third-party audits and
of tin, tantalum, tungsten and/or gold. Minerals partially disclosure of information with a view to identifying and
processed, unprocessed, or a bi-product from another addressing actual and potential risks linked to conflict-
ore will not be included in the definition of recycled metal. affected and high-risk areas to prevent or mitigate adverse
7. Outside the Supply Chain. A conflict mineral is impacts associated with their sourcing activities;
considered outside the supply chain after any columbite- e. ‘chain of custody or supply chain traceability system’
tantalite, cassiterite, and wolframite minerals, or their means a record of the sequence of economic operators
derivatives, have been smelted; any gold has been fully which have custody of minerals and metals as they move
refined; or any conflict mineral, or its derivatives, that through a supply chain;
have not been smelted or fully refined are located outside f. ‘conflict-affected and high-risk areas’ means areas in a
of the Democratic Republic of the Congo or an adjoining state of armed conflict or fragile post-conflict as well
country. as areas witnessing weak or non-existent governance
8. Nationally or internationally recognized due and security, such as failed states, and widespread and
diligence framework. The term “nationally or systematic violations of international law, including human
66
 rights abuses; and handling of minerals in and export of minerals from
g. ‘armed groups and security forces’ means groups referred conflict-affected and high-risk areas;
to in Annex II to the OECD Due Diligence Guidance; r. ‘risk management plan’ means the written response of a
h. ‘smelter and refiner’ means any natural or legal person Union importer to the identified supply chain risks based
performing forms of extractive metallurgy involving on Annex III to the OECD Due Diligence Guidance;
processing steps with the aim to produce a metal from a s. ‘recycled metals’ means reclaimed end-user or post-
mineral; consumer products, or scrap processed metals created
i. ‘global responsible smelters and refiners’ means smelters during product manufacturing, including excess, obsolete,
and refiners located inside or outside the Union that are defective, and scrap metal materials which contain refined
deemed to fulfil the requirements of this Regulation; or processed metals that are appropriate for recycling in
j. ‘upstream’ means the mineral supply chain from the the production of tin, tantalum, tungsten or gold. For the
extraction sites to the smelters and refiners, inclusive; purposes of this definition, minerals partially processed,
k. ‘downstream’ means the metal supply chain from the unprocessed or a by-product from another ore are not
stage following the smelters and refiners to the final considered to be recycled metals;
product; t. ‘by-product’ means a mineral or metal falling within the
l. ‘Union importer’ means any natural or legal person scope of this Regulation that has been obtained from
declaring minerals or metals for release for free circulation the processing of a mineral or metal falling outside the
within the meaning of Article 201 of Regulation (EU) No scope of this Regulation, and which would not have been
952/2013 of the European Parliament and of the Council obtained without the processing of the primary mineral
(7) or any natural or legal person on whose behalf such or metal falling outside the scope of this Regulation;
declaration is made, as indicated in data elements 3/15 u. ‘verifiable date’ means a date which can be verified by
and 3/16 in accordance with Annex B to Commission the inspection of physical date stamps on products or of
Delegated Regulation (EU) 2015/2446 (8); inventory lists.
m. ‘supply chain due diligence scheme’ or ‘due diligence
scheme’ means a combination of voluntary supply chain Key terms from the RMI’s CMRT
due diligence procedures, tools and mechanisms, including Link to CMRT: http://www.responsiblemineralsinitiative.org/
independent third-party audits, developed and overseen conflict-minerals-reporting-template/
by governments, industry associations or groupings of
interested organisations; Conflict Mineral: “As defined in 2010 United States
n. ‘Member State competent authorities’ means authorities legislation, Dodd-Frank Wall Street Reform and Consumer
designated by Member States in accordance with Article Protection Act, Section 1502(e)(4): CONFLICT MINERAL. —
10 with expertise as regards raw materials, industrial The term ‘‘conflict mineral’’ means—(A) columbite-tantalite
processes and auditing; (coltan), cassiterite, gold, wolframite, or their derivatives; or
o. ‘OECD Due Diligence Guidance’ means the OECD Due (B) any other mineral or its derivatives determined by the
Diligence Guidance for Responsible Supply Chains of Secretary of State to be financing conflict in the Democratic
Minerals from Conflict-Affected and High-Risk Areas Republic of the Congo or an adjoining country. (available at
(Second Edition, OECD 2013), including all its Annexes http://www.sec.gov/about/laws/wallstreetreform-cpa.pdf)”
and Supplements;
p. ‘grievance mechanism’ means an early-warning risk Covered Country(ies): Covered Country(ies) as defined
awareness mechanism allowing any interested party, by the United States Dodd-Frank Wall Street Reform and
including whistle-blowers, to voice concerns regarding Consumer Protection Act of 2010. These countries include
the circumstances of extraction, trade and handling of the Democratic Republic of the Congo and the nine countries
minerals in and export of minerals from conflict-affected with which it shares an internationally recognized border:
and high-risk areas; Angola, Burundi, Central African Republic, Republic of the
q. ‘model supply chain policy’ means a supply chain policy Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia.
that conforms to Annex II to the OECD Due Diligence
Guidance outlining the risks of significant adverse impacts Declaration Scope or Class: For the purposes of
which may be associated with the extraction, trade, this template, ‘scope’ describes the applicability of the
67
 information provided by the reporting company. The scope determining whether a conflict mineral is ‘‘necessary to
may encompass the entirety of a company’s services and/ the functionality or production’’ of a product. This is true
or products, or at a company’s discretion, the template may regardless of who intentionally added the conflict mineral
be used to report on a specific product (or products), or, be to the product so long as it is contained in the product.
‘User defined’. The ‘User defined’ scope selection or class [D]etermining whether a conflict mineral is considered
may be used to describe any subset of a company’s operation ‘‘necessary’’ to a product should not depend on whether
or product portfolio. the conflict mineral is added directly to the product by the
issuer or whether it is added to a component of the product
Dodd-Frank: 2010 United States legislation, Dodd-Frank that the issuer receives from a third party. Instead, the issuer
Wall Street Reform and Consumer Protection Act, Section should ‘report on the totality of the product and work
1502 (‘The Dodd-Frank Act’: http://www.sec.gov/about/laws/ with suppliers to comply with the requirements.’ Therefore,
wallstreetreform-cpa.pdf) in determining whether a conflict mineral is ‘‘necessary’’
to a product, an issuer must consider any conflict mineral
DRC: Democratic Republic of Congo contained in its product, even if that conflict mineral is only in
the product because it was included as part of a component
DRC conflict-free: Products that do not contain minerals of the product that was manufactured originally by a third
that directly or indirectly finance or benefit armed groups party.”
in the Democratic Republic of the Congo or an adjoining *(56296 Federal Register / Vol. 77, No. 177 / Wednesday,
country. Source: 2010 United States legislation, Dodd-Frank September 12, 2012 / Rules and Regulations)
Wall Street Reform and Consumer Protection Act, Section
1502 (http://www.sec.gov/about/laws/wallstreetreform-cpa. Necessary for the Functionality of a Product: “The SEC
pdf) does not provide a formal definition of this phrase in the final
rule*, however it provides some guidance: A conflict mineral
Gold (Au) refiner (smelter): A gold refiner is a metallurgical will be considered to be necessary to its functionality of a
operation that produces fine gold with a concentration of product if it meets the following: 1) is intentionally added
99.5% or higher from gold and gold-bearing materials with to the product or any component of the product and is
lower concentrations. Refer to the RMAP audit protocol not a naturally-occurring byproduct; 2) is necessary to the
for this metal for a complete description: http://www. product’s generally expected function, use or purpose; and 3)
responsiblemineralsinitiative.org/smelter-introduction/. is incorporated for the purpose of ornamentation, decoration,
or embellishment, whether the primary purpose of the
Independent Third-Party Audit Firm: With respect to product is ornamentation or decoration.”
smelter audits, an ‘Independent Third-Party Audit Firm’ is
a private sector organization competent in evaluating the NOTE: The conflict mineral must be contained in the product
smelter or refiner’s materials traceability against the standards to be applicable.
of the RMAP or equivalent audit protocols. To maintain
neutrality and impartiality, such organization and its audit team *(56296 Federal Register / Vol. 77, No. 177 / Wednesday,
members must have no conflicts of interest with the auditee. September 12, 2012 / Rules and Regulations)”

Intentionally added: “Intentionally added is commonly Necessary for the Production of a Product: “The SEC
known as the deliberate use of a substance, or in this case does not provide a formal definition of this phrase in the final
metal, in the formulation of a product where continued rule*; however, it provides some guidance: A conflict mineral
presence is desired to provide a specific characteristic, will be considered to be necessary to the production of a
appearance or quality. product when: 1) it is intentionally included in the product’s
production process, other than if it is included in a tool,
While the SEC does not define the phrase “intentionally machine, or equipment used to produce the product (such
added” in the final rule*, the rule’s preamble states: “[W] as computers or power lines); 2) it is included in the product
e agree that being intentionally added, rather than being (MUST be contained in the product to be applicable); and 3) it
a naturally-occurring by-product, is a significant factor in is necessary to the product.”
68
*(56296 Federal Register / Vol. 77, No. 177 / Wednesday, RMAP Conformant Smelter List: The Responsible Minerals
September 12, 2012 / Rules and Regulations) Assurance Process (RMAP) Conformant Smelter List is a
published list of smelters and refiners that have undergone
OECD: Organisation for Economic Co-operation and assessment through the RMAP, a program of the Responsible
Development Minerals Initiative (RMI) or industry equivalent program (such
as Responsible Jewellery Council or London Bullion Market
Product: A company’s Product or Finished good is a material Association) and have been validated to be in conformance
or item which has completed the final stage of manufacturing with the protocols. If a smelter or refiner is not on the list,
and/or processing and is available for distribution or sale to it has either not completed a RMAP assessment or is not in
customers. conformance with the RMAP protocol.

RBA: Responsible Business Alliance (www.responsiblebusiness. A list of smelters and refiners which have been validated
org) to be conformant to the RMAP can be found at www.
responsiblemineralsinitiative.org.
Recycled or Scrap Sources: Recycled or scrap sources are
recycled metals, that are reclaimed end-user or post-consumer SEC: U.S. Securities and Exchange Commission (www.sec.gov)
products, or scrap processed metals created during product
manufacturing. Recycled metal includes excess, obsolete, Smelter: A smelter or refiner is a company that procures and
defective, and scrap metal materials that contain refined processes mineral ore, slag and/or materials from recycled
or processed metals that are appropriate to recycle in the or scrap sources into refined metal or metal containing
production of tin, tantalum, tungsten and/or gold. Minerals intermediate products. The output can be pure (99.5% or
partially processed, unprocessed or byproducts from other greater) metals, powders, ingots, bars, grains, oxides or salts.
ores are not included in the definition of recycled metal. The terms “smelter” and “refiner” are used interchangeably
throughout various publications.
Responsible Minerals Assurance Process (RMAP):
The Responsible Minerals Assurance Process (RMAP) is Smelter Identification Number: A unique identification
a process developed by the RMI to enhance company number the RMI assigns to companies that have been
capability to verify the responsible sourcing of metals. reported by members of the supply chain as smelters or
Further details of the RMAP can be found here: http:// refiners, whether or not they have been verified to meet the
www.responsiblemineralsinitiative.org/responsible-minerals- characteristics of smelters or refiners as defined in the RMAP
assurance-process/. audit protocols.

Responsible Minerals Initiative: Founded in 2008 by Tantalum (Ta) smelter: A tantalum smelter (also known as a
members of the Responsible Business Alliance (RBA), the processor) is defined as a company that converts Ta-containing
Responsible Minerals Initiative (RMI) has grown into one of ores, concentrates, slags or secondary materials into tantalum
the most utilized and respected resources for companies intermediate products or other tantalum containing products
addressing conflict minerals issues in their supply chains. Over for direct sales or further processing into Ta-containing
360 companies from ten industries participate in the RMI products, such as Ta powders, Ta components, Ta oxides,
today, contributing to a range of tools and resources including alloys, wires, sintered bars, etc. Refer to the RMAP audit
the Responsible Minerals Assurance Process, the Conflict protocol for this metal for a complete description at: http://
Minerals Reporting Template, Reasonable Country of Origin www.responsiblemineralsinitiative.org/smelter-introduction/.
Inquiry data and a range of guidance documents on conflict
minerals sourcing. The RMI also runs regular workshops on
conflict minerals issues and contributes to policy development
and debates with leading civil society organizations and
governments. Additional information is available at www.
responsiblemineralsinitiative.org.
69
 Tin (Sn) smelter: Primary [tin] smelters are companies with
one or more facilities treating tin containing ore concentrates
in order to produce tin metal. Secondary [tin] smelters are
companies with one or more facilities that treat secondary
materials by reduction for the production of crude or higher
grade tin or tin product such as solder. A smelter as referred
to within this audit protocol may operate as either one or
both types of business operation. Refer to the RMAP audit
protocol for this metal for a complete description: http://
www.responsiblemineralsinitiative.org/smelter-introduction/.

Tungsten (W) smelter: A company with one or more

facilities that converts W-containing ores (such as wolframite
and scheelite), W concentrates, or W-bearing scrap
(secondary material) into tungsten containing intermediates
such as Ammonium Para-Tungstate (APT), Ammonium Meta-
Tungstate (AMT), ferrotungsten, and tungsten oxides for direct
sales or further processed into W-containing products (such
as W powder or W-carbide powder). Refer to the RMAP
audit protocol for this metal for a complete description: http://
www.responsiblemineralsinitiative.org/smelter-introduction/.

70
Appendix C: Current state of reporting

This appendix provides a summary of publications and studies Kim and Davis’ 2016 article Challenges for Global Supply
that have evaluated quality of reporting done by entities in the Chain Sustainability: Evidence from Conflict Minerals Reports
mineral value chain. investigates the challenges of declaring products conflict-
free in SEC disclosures. In an analysis of over 1,000 conflict
Downstream companies: The Responsible Sourcing minerals reports submitted between 2014 and 2016, Kim and
Network’s (RSN) 2018 report, Mining the Disclosures, Davis found that only 1% of companies were able to declare
analysed a sample of 206 companies on their Standardized products as conflict-free beyond reasonable doubt, 19%
Disclosure documents filed in accordance with the Dodd- declared that there was no reason to believe that products
Frank Act, Section 1502. The scores were based on 21 KPIs contained DRC conflict minerals, and 80% stated that they
categorized as Human Rights Impact, Risk Management, were unable to determine the origin of their raw materials.
and Reporting. In the fifth year of reporting to the SEC, the After analysing a variety of factors, the authors found that
RSN found that the quality of companies’ disclosures had companies that were most unable to declare themselves
weakened compared to previous years. While disclosure conflict-free were more likely to be global enterprises with
quality remained stable compared to 2017, there has been a complex structures and dispersed supply chains.124, 125
decrease in reporting on due diligence processes (for example,
reporting on products that fall within the scope of due Mineral exporters: Some organizations have also assessed
diligence). However, according to RSN, leaders in due diligence the quality of reporting of among upstream actors. Global
work on conflict minerals continue to report on high quality Witness, for example, published a study in 2017 called
due diligence processes, participation in multi-stakeholder Time to Dig Deeper, in which it assessed the due diligence
initiatives, and engagement in innovative and proactive actions reports of 65 mineral exporters from eastern DRC, Rwanda,
designed to identify and mitigate risks in their supply chains. 122
and Uganda. They found that only 29 out of 65 companies
that export 3TG from eastern DRC, Rwanda, and Uganda
The Enough Project’s 2017 study Demand the Supply published due diligence reports, with the largest percentage
evaluated 20 companies on four criteria related to sourcing of reports coming from Rwanda. In the Eastern DRC, only 5
conflict minerals: Conducting Conflict Minerals Sourcing Due of 7 companies reported from North Kivu and only 8 of 15
Diligence and Reporting, Developing a Conflict-Free Minerals companies in South Kivu published reports. Only one gold
Trade and Sourcing Conflict-Free Minerals from Congo exporter – located in the Congo – produced a due diligence
(Particularly Gold), Supporting and Improving Livelihoods for report though gold is the mineral that employs the most
Artisanal Mining Communities in Eastern Congo, and Conflict- miners in the artisanal mining sector. According to Global
Free Minerals Advocacy. The study took an interest to gold Witness, overall, mineral exporters were more likely to publish
given the difficulties in tracing the metal. The Enough Project reports that could be called “responsible sourcing plans”
found that companies had made improvements in some areas. rather than a due diligence report. Detail of information was
For example, according to their reporting, companies were low and inaccurate information was common.126
more discerning about sourcing conflict-free mineral and
metals rather than eliminating the DRC from their supply Smelters and refiners: A report published by Development
chain completely. Still, the Enough Project also sees room for International in 2018, called 3TG+C Smelter and Refiner
improvement in the way companies report, advising them to Disclosure Conformance with Leading Due Diligence and
make disclosure procedures clearer and align with the OECD Assurance Standards, evaluated the due diligence practices
Due Diligence when possible. 123
and reporting of smelters or refiners (SORs). The report
assessed 370 SORs on their alignment with the OECD’s five
steps and other assurance standards with which the SOR

122  https://static1.squarespace.com/static/594cbfa3440243aef3dfa1c4/t/5c12abf80ebbe819f9a2936f/1544727561702/MtD18-full_web_2.pdf
123  https://enoughproject.org/wp-content/uploads/2017/11/DemandTheSupply_EnoughProject_2017Rankings_final.pdf
124  https://hbr.org/2017/01/80-of-companies-dont-know-if-their-products-contain-conflict-minerals
125  http://amj.aom.org/content/59/6/1896
126 https://www.globalwitness.org/documents/19232/Time_to_Dig_Deeper_vb7AX58.pdf
71
 may be associated (e.g. RMAP, RJC, LBMA). Development
International found that 62% of the assessed SORs had either
a supply chain due diligence policy, conflict minerals policy, or
procurement policy and those that belonged to an assurance
program performed better on average. Further, the analysis
demonstrated that a large part of the due diligence efforts
was driven by reporting according to U.S. legal requirements.
At the same time, public reporting needs improvement due to
“substantial gaps with respect to the degree to which SORs
have fulfilled their public reporting obligations on due diligence
efforts.”127 The majority of SORs were found to be using
“formulaic standard language” that did connote transparency.
As Development International notes, lack of public disclosure
on due diligence processes can raise into question the validity
and effectiveness of a due diligence program.128

Small and mid-tier mining companies: The Responsible

Mining Foundation’s Mine-site ESG disclosure by small and
mid-tier mining companies presents an overview of current
reporting by small and mid-tier mining companies based
on criteria covered by 15 ESG topics (e.g., community
engagement, workers’ safety, environmental impact
assessments, and water quality). The research concluded that
disclosures practices are weak among these mining companies
and site-disaggregated data is rare. The study also found
that external requirements, such as mandatory reporting
mechanisms set by governments, produce higher quality public
reporting.129

127 https://docs.wixstatic.com/ugd/f0f801_762796a852e84325bb126a824300999c.pdf
128 https://docs.wixstatic.com/ugd/f0f801_762796a852e84325bb126a824300999c.pdf
129 https://responsibleminingindex.org/en/foundation/our-work/mine-site-study-2019
72
About GRI About the RMI

GRI helps businesses and governments worldwide Founded in 2008 by members of the Responsible
understand and communicate their impact on critical Business Alliance and the Global e-Sustainability Initiative,
sustainability issues such as climate change, human rights, the Responsible Minerals Initiative has grown into one of
governance and social well-being. This enables real action the most utilized and respected resources for companies
to create social, environmental and economic benefits from a range of industries addressing responsible mineral
for everyone. The GRI Sustainability Reporting Standards sourcing issues in their supply chains.
are developed with true multi-stakeholder contributions
and rooted in the public interest. The RMI’s flagship Responsible Minerals Assurance
Process offers companies and their suppliers an
The GRI Sustainability Reporting Standards (GRI independent, third-party audit that identifies smelters
Standards) are most widely adopted global standards and refiners that have systems in place to responsibly
for sustainability reporting. As of 2017, 93 percent of source minerals in line with current global standards.
the world’s largest 250 corporations report on their The RMI operates within the internationally recognized
sustainability performance. frameworks of the OECD Guidelines for Multinational
Enterprises, the OECD Due Diligence Guidance
The practice of disclosing sustainability information for Responsible Supply Chains, and the UN Guiding
inspires accountability, helps identify and manage risks, Principles on Business and Human Rights.
and enables organizations to seize new opportunities.
Reporting with the GRI Standards supports companies, The RMI helps companies conduct due diligence in
public and private, large and small, protect the accordance with these frameworks, to ensure such
environment and improve society, while thriving efforts are accepted and recognized by all stakeholders.
economically by improving governance and stakeholder In practice, the RMI creates the enabling conditions
relations, enhancing reputations and building trust. for companies to exercise due diligence on minerals,
through reporting and data tools such as the Conflict
GRI works with the largest companies in the world as Minerals Reporting Template, Cobalt Reporting
a force for positive change. As a result, the impact of Template, Reasonable Country of Origin Inquiry data,
our work on social well-being, through better jobs, less Risk Readiness Assessment, and best practice guidance
environmental damage, access to clean water, less child documents on meeting regulatory requirements.
and forced labor, and gender equality has enormous
scale.

73
 Acknowledgments
This publication is the result of a collective effort. Participants of the GRI-RMI Corporate Leadership
GRI and the RMI would like to thank the numerous Group (CLG) on reporting on responsible minerals
organizations that contributed to the corporate sourcing
engagement phase of the project and the wide array Assent Compliance
of expert stakeholders from a variety of constituencies Atea Sverige AB
including investment institutions, industry organizations, Baker McKenzie
civil society organizations (CSOs) and mineral and metal BMW
exporters, who participated in scoping interviews, Boeing
participated as guest speakers in the Corporate H.C. Starck Tantalum and Niobium GmbH
Leadership Group lab meetings, or offered guidance and Micron
input throughout the project. You can learn more about Microsoft
GRI Corporate Leadership Groups here. Groupe Renault
Siemens
The RMI’s project team: Leah Butler (lead) STMicroelectronics

GRI project team: Katja Kriege (lead), Dasha Mihailova, Topic experts consulted – stakeholder
Faryaal Zaman, Alba León, Mariona Isnard. organizations and companies from different steps in
the value chain
Better Chain
Boston Common Asset Management
Consensas
Cronimet
Development International
Elm Sustainability Partners LLC
Enough Project
Global Witness
H.C. Starck Tantalum and Niobium GmbH
Halcyon Inc
Hermes EOS
Intel Corporation
International Tin Association
London Bullion Market Association
Noviva
Organisation for Economic Co-operation and
Development (OECD)
Principles for Responsible Investment
Resource Watch
Responsible Jewellery Council
Responsible Sourcing Network
Wolfram Bergbau und Hütten AG

74
Development of this resource

Since January 2018, GRI and RMI have worked together

to improve current reporting on due diligence and
reporting on the impacts of mineral sourcing. In the first
stage of the project, the two organizations carried out
extensive baseline research on the current reporting
landscape, as well as an internal review of sustainability
reports from 50 companies reporting on mineral
sourcing across multiple industries and regions. There
was also engagement with key stakeholders and experts
from a variety of constituencies including government,
civil society, industry associations, and investors to gain
a spectrum of perspectives on corporate sustainability
reporting related to mineral sourcing.

A Corporate Leadership Group (CLG) brought together

11 organizations from industries including but not
limited to automotive, aerospace, electronics, and
consumer goods. GRI and RMI jointly hosted four CLG
Labs where CLG members could discuss the research
findings from the baseline research, develop a common
understanding of how existing tools and frameworks
serve companies, share and evaluate best practices,
and discuss how identified gaps can be addressed with
additional reporting resources. The discussions of the
CLG included:

\\ Due diligence reporting in accordance with ‘Step 5’ of

the OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-Affected and
High-Risk Areas, and relevant GRI Standards
\\ Involvement and communication between actors
along the entire mineral value chain
\\ Reporting on impacts of mineral sourcing and trade
\\ Reporting on performance progress

The result of the baseline research and subsequent

discussions during the CLG meetings led to the
production of this toolkit.

75