Risk Assessment (Conflict Minerals)

Risk assessment in conflict minerals due diligence refers to the systematic process of identifying and evaluating whether the supply chain is contributing to or at risk of contributing to armed conflict, human rights abuses, money laundering, or other OECD Annex II risks. Risk assessment is Step 2 of the OECD five-step framework. It involves evaluating smelter-level data (country of origin, RMAP status), supplier-level data (CMRT responses, response rates), and geographic-level data (CAHRA proximity) to prioritize risk mitigation efforts.

OECD Due Diligence Guidance, Third Edition (2016), Step 2 and Annex II; Regulation (EU) 2017/821, Articles 5–6.

Risk assessment outputs a prioritized list of supply chain concerns: non-conformant smelters, smelters in high-risk sourcing regions, suppliers who did not respond to CMRT requests, and smelters whose audit status has lapsed. This list drives Step 3 — risk mitigation — which typically involves engaging non-conformant smelters to pursue RMAP certification or removing them from the supply chain. Document the risk assessment methodology and findings for inclusion in the Conflict Minerals Report.

After collecting CMRT data, a manufacturer’s risk assessment identifies: 3 non-conformant tin smelters, 12 smelters with ‘active’ (in-process audit) status, 2 smelters from which origin data is missing. The risk assessment rates the non-conformant smelters as high priority for engagement, active smelters as acceptable, and missing-data smelters as medium priority requiring follow-up.