Armed Groups

Under the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 'armed groups' are defined as groups distinct from government or state military forces that use violence to pursue political or economic goals, including seizure or taxation of mineral extraction, transport, or trade. Identifying and avoiding the financing of armed groups is a core objective of both the U.S. Dodd-Frank Section 1502 and EU Conflict Minerals Regulation (EU) 2017/821.

OECD Due Diligence Guidance, Third Edition (2016), Annex II; Regulation (EU) 2017/821, Recital 3; Dodd-Frank Act Section 1502.

Companies conducting conflict minerals due diligence must assess whether any smelter or refiner in their supply chain knowingly sources from or benefits armed groups in conflict-affected areas. This is a key risk indicator evaluated during RMAP audits. If a smelter is found to benefit armed groups, it will not receive or retain conformant status under RMAP, and its minerals cannot be declared DRC conflict-free.

An RMAP audit of a tin smelter in the DRC region finds evidence that the smelter purchases ore from an artisanal mining site controlled by an armed militia. The smelter fails the audit and is placed on the non-conformant list. Downstream manufacturers using this smelter cannot claim their products are DRC conflict-free.