Critical Minerals Supply Chain Due Diligence Guide

This guide provides a practical approach to critical minerals supply chain due diligence based on the OECD five-step framework.

Step 1: Establish Management Systems

Adopt a supply chain policy for responsible mineral sourcing. Establish a due diligence team with clear responsibilities. Implement a supplier code of conduct covering human rights, labour rights, environmental practices, and anti-corruption. Set up a grievance mechanism for supply chain concerns.

Step 2: Identify and Assess Risks

Map your supply chain to identify the minerals you use and their sources. Assess risks at each stage of the supply chain using the OECD risk categories: serious abuses associated with extraction, trade, handling, or export of minerals; direct or indirect support to non-state armed groups; bribery and fraudulent misrepresentation; money laundering; and non-payment of taxes, fees, and royalties.

Step 3: Design and Implement a Risk Response Strategy

For identified risks, design and implement a risk response strategy: continue sourcing while implementing measurable risk mitigation; temporarily suspend or discontinue sourcing while pursuing ongoing risk mitigation; and disengage from suppliers if risks are too severe or mitigation is not feasible.