Five-Step OECD Framework

The five-step OECD framework is the internationally recognized due diligence process for responsible mineral sourcing from conflict-affected and high-risk areas, established in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016). The five steps are: (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.

OECD Due Diligence Guidance, Third Edition (2016), Chapter II; Regulation (EU) 2017/821, Articles 4–7; SEC Conflict Minerals Rule (2012).

The five-step framework is referenced in virtually every conflict minerals compliance program globally. Steps 1–3 and 5 apply directly to downstream manufacturers and importers. Step 4 (independent audit) is conducted at the smelter/refiner level through programs like RMAP rather than by each downstream company individually. For EU importers of metals, Step 4 is satisfied by using smelters/refiners with existing RMAP audit reports. The framework is also the basis for the EU Conflict Minerals Regulation’s due diligence structure.

Step 1: A manufacturer publishes a conflict minerals policy. Step 2: It collects CMRTs from 500 suppliers and assesses smelter origin data. Step 3: It identifies 12 non-conformant smelters and develops an engagement plan. Step 4: It verifies that 93% of smelters have current RMAP conformant status. Step 5: It publishes its annual conflict minerals report on its website and files Form SD with the SEC.