How are country risk levels determined?

Risk levels are assigned to a country based on the following criteria.

  • Level 1 Country:  Countries with known active ore production for minerals that are not identified as Level 2 or Level 3.
  • Level 2 Country: A country where minerals from conflict-affected and high-risk areas (CAHRA) are known to transit. This currently includes Kenya, Mozambique and South Africa.
  • Level 3 Country:  A country where minerals are mined in a CAHRA as defined by the mineral origin and/or supplier red flags of the OECD Due Diligence Guide:
    • The minerals originate from or have been transported via a CAHRA (as defined by the OECD).
    • The minerals are claimed to originate from a country that has limited known reserves, likely resources, or expected production levels of the mineral in question (i.e., the declared volumes of mineral from that country are out of keeping with its known reserves or expected production levels).
    • The minerals are claimed to originate from a country where materials from CAHRAs are known to transit, legally or illegally.
    • The company’s suppliers or other known upstream companies have shareholder or other interests in companies that supply minerals from or operate in one of the above-mentioned red flag locations of mineral origin and transit.
    • The company’s suppliers’ and/or other upstream companies are known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months.
  • Based on the definition provided in the Dodd-Frank Act, Level 3 countries also include: The Democratic Republic of the Congo (DRC) and its nine adjoining countries. These include Angola, Burundi, Central African Republic, DRC, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. These are also commonly referred to as "covered countries”.