OECD Due Diligence Guidance

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016) is the primary international framework for conflict minerals supply chain due diligence. It provides a five-step due diligence process applicable to all companies in the mineral supply chain. It includes a general guidance chapter applicable to all minerals and metal-specific supplements for gold (Supplement on Gold), tin, tantalum, and tungsten (Supplement on Tin, Tantalum and Tungsten). Both the U.S. Dodd-Frank/SEC rule and EU Regulation (EU) 2017/821 are aligned with this guidance.

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 3rd Edition (2016); OECD Council Recommendation (May 2011).

The OECD Guidance is the global benchmark for conflict minerals compliance. Its five-step framework provides the operational structure for both Dodd-Frank CMR preparation and EU Regulation compliance. Annex II of the Guidance defines specific supply chain risks including: providing financial or material support to armed groups, money laundering, bribery, and serious human rights abuses. Any company conducting and reporting conflict minerals due diligence should document explicit alignment with the OECD Guidance steps and Annex II risk categories.

A European gold importer designs its due diligence program explicitly against the five-step OECD framework. Its internal policy references Annex II risk categories. Its annual public report maps each OECD step to its specific activities (CMRT collection, RMAP verification, risk mitigation engagement) demonstrating structured alignment with the international standard.