Why Reasonable Country of Origin Inquiry Data is Invaluable to Responsible Minerals Programs

Why Reasonable Country of Origin Inquiry Data is Invaluable to Responsible Minerals Programs

One of the primary purposes of any responsible minerals program is to account for the origin of minerals of concern — including tantalum, tin, tungsten and gold (3TGs) — and to understand the associated human rights risks. However, because of opacity in the mining and smelting process, most companies have traditionally fallen short of this goal. Companies are only beginning to understand the importance of Reasonable Country of Origin Inquiry (RCOI) data and making a strong effort to collect it.

When concerns about mining conditions emerged as a topic of regulatory interest in the early 2000s, companies started to examine their mineral sources of origin and developed plans to avoid working with bad actors. Smelters were quickly identified as a pinch point where mineral origin information could be collected.

Those tasked with collecting supply chain data from smelters anticipated surveying a few suppliers about a handful of mines. In reality, most companies source from 40–50 smelters. Depending on the metal, these smelters could use as many as 20,000 sources annually, usually outside of the country where it is smelted.

The Original Validation Standard

As companies began to account for mineral sourcing, it became clear that most minerals originated in the Democratic Republic of the Congo (DRC). The sale of minerals from this region have been found to contribute to armed conflict and human rights violations, making it the focus for companies and agencies striving for change.

In response, the Responsible Minerals Initiative, the London Metal Exchange, the London Bullion Market Association and other groups created evaluation mechanisms. These mechanisms enable audits of smelters and refiners to ensure transparency with regard to where minerals were mined, supporting downstream companies in corporate responsibility goals. Under these requirements, due diligence must satisfy two levels of validation:

  1. Materials sources of origin.
  2. Chain of custody.

While these two points of validation are a step in the right direction, this type of validation captures a limited view of what happens on the ground. Under the first level, material sources of origin, mines are acceptable if the metal exists on site and there is no indication of forced labor. However, this does not identify whether profits from the mine support conflict, and it does not account for mines outside of the DRC, where injustices may still be prevalent.

The second level of validation, chain of custody, only reveals whether minerals do, in fact, come from the location smelters claim. It does not mitigate any additional risks or explore the deeper implications of sourcing from a particular region.

To learn more about souring minerals responsibly, download our eBook, The Conflict Mineral Handbook: Your Guide to Compliance in 2019.

Rethinking the Standard 

At the annual responsible minerals meeting in 2018, the Organisation for Economic Co-operation and Development (OECD) hosted discussions on the ability for companies to demonstrate transparency regarding RCOI data. In response, leaders in several industries have pushed their supply chains to provide more detailed information on source of origin, acknowledging significant gaps in their knowledge. These companies also recognize the need to expand their focus to mines outside of the DRC.

Other catalysts for change include the pending European Union Conflict Mineral Regulation and the list of Conflict-Affected and High-Risk Areas (CAHRAs) currently in development. Companies want to avoid sourcing from sanctioned countries that pose a risk to business continuity, and want to address environmental and labor concerns.

This shift is an indication that industries are finally understanding the importance of responsible mineral sourcing to businesses and the people working in mines.

How Strong Is Your RCOI Validation Process? 

Assent collects and uses RCOI data to help companies ensure they are following OECD guidelines for responsible minerals reporting. For more information on how Assent can help your organization reach its responsible minerals goal, contact us at info@assentcompliance.com.