RMI Annual Conference 209

Can smelters use upstream assurance mechanisms for sourcing from CAHRAs?

Yes, smelters may continue to use upstream assurance mechanisms to assist in conducting due diligence over high-risk sources. When using upstream assurance mechanisms, smelters must, at a minimum:

  • Understand the scope of activities of the upstream assurance mechanism and understand any gaps between the scope of the mechanism’s activities and the requirements of the OECD Guidance.
  • Ensure that all information generated by the upstream assurance mechanism, and which is expected to be shared with the auditee, is received in a timely manner and records are maintained for at least five (5) years and made available to the auditor.
  • Have sufficient understanding of the context of CAHRAs to be able to review and understand the information generated by the upstream assurance mechanism and to assess their ability to exercise influence over actors in high-risk supply chains who can most effectively prevent or mitigate identified risks.
  • Where possible, actively participate in the upstream assurance mechanism to mitigate identified risks in its supply chains.