Artisanal and Small-Scale Mining (ASM)

Artisanal and Small-Scale Mining (ASM) refers to informal or semi-formal mining activities conducted by individuals or small groups with limited mechanization, often operating in developing countries. ASM is a significant source of 3TG minerals, particularly gold, tin, tantalum, and tungsten in the DRC and adjoining countries. ASM operations are associated with higher conflict mineral risk because they frequently operate in conflict-affected areas and may be subject to control or taxation by armed groups.

OECD Due Diligence Guidance, Third Edition (2016), Glossary; Regulation (EU) 2017/821, Recitals 4–6.

ASM is inherently higher risk for conflict minerals compliance because of limited traceability, informal record-keeping, and geographic overlap with conflict areas. Companies whose smelters source from ASM operations must ensure those smelters have robust upstream due diligence programs. The EU Conflict Minerals Regulation specifically acknowledges the importance of supporting ASM communities through accompanying measures while managing compliance risk.

A gold refiner in its supply chain sources partially from ASM operations in eastern DRC. The refiner must demonstrate through its RMAP audit that it has implemented chain-of-custody controls at the ASM mining site level, including support for regional certification schemes such as the ITSCI programme.