Due Diligence (Conflict Minerals)

Due diligence in the context of conflict minerals refers to the ongoing process of risk identification, assessment, and management that companies must apply to their mineral supply chains to ensure minerals do not originate from sources that fund armed conflict or contribute to human rights violations. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016) is the internationally recognized framework aligned with both Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821.

OECD Due Diligence Guidance, Third Edition (2016); Dodd-Frank Act Section 1502; Regulation (EU) 2017/821, Articles 4–7.

Due diligence is not a one-time exercise — it must be conducted annually and updated when supply chain changes occur. The five-step OECD framework provides the structure: (1) establish strong company management systems; (2) identify and assess risks in the supply chain; (3) design and implement a strategy to respond to identified risks; (4) carry out independent third-party audit of supply chain due diligence at identified checkpoints; (5) report annually on supply chain due diligence. Steps 1–3 and 5 apply to all companies; Step 4 audit is focused at the smelter/refiner level.

An EU importer of gold metals implements annual conflict minerals due diligence: maintains a supplier policy requiring RMAP audit participation, collects CMRT data from all gold refiners annually, assesses country-of-origin risk, flags refiners with unresolved sourcing concerns, and reports findings in its annual sustainability report.