RMI Annual Conference 209

Upstream Assurance Mechanisms

The Responsible Minerals Initiative (RMI) may recognize Upstream Assurance Mechanisms at two levels. The following criteria are required for Upstream Assurance Mechanisms to be recognized for each level:

Level 1: Full Recognition – Standard and Implementation

Full alignment with the OECD Due Diligence Guidance, demonstrated through an OECD Alignment Assessment conducted by an independent third-party using the OECD’s Alignment Assessment Methodology and Alignment Assessment Tool for:

  • Standard
  • Implementation
  • Governance

Level 2: Partial Recognition – Standard Only

Full alignment of the programs’ Standards with the OECD Due Diligence Guidance, demonstrated through an OECD Alignment Assessment conducted by an independent third-party using the OECD’s Alignment Assessment Methodology and Alignment Assessment Tool for:

  • Standard

Verification of Implementation of the Standard at a programmatic level will be required on-site

  • Implementation to be assessed as part of the RMAP smelter/refiner assessment

For more information on the RMI Recognition requirement, please visit the webpage here and review the recognition policy here.

RMI Upstream Due Diligence

As part of its collaborative efforts, and ongoing review of RMI-recognized upstream assurance mechanisms, the RMI engages upstream partners, including assurance mechanisms. In support of implementing, monitoring and tracking performance of upstream risk mitigation, the RMI conducts due diligence reviews of the upstream mechanisms incident processes. In 2016, the RMI conducted a first review of iTSCi incidents and in 2017 the RMI added the review of BSP incidents. The RMI shares opportunities for improvement observed with both programs. For more information, please click HERE.

In 2018 the RMI conducted on-site visits of mine sites for upstream assurance schemes in the DRC and Rwanda and conducted meetings with industry representatives, civil society, other key stakeholders and governments. In 2019 the RMI continued the efforts including an in-region visit to Indonesia for the Tin Working Group (TWG) project, and two planned in-region visits; one to the DRC for a cobalt stakeholder meeting organized by the OECD, and the other with the Public Private Alliance for Responsible Minerals Trade (PPA) delegation to 3Ts and gold sites in the DRC and Rwanda.

The RMI has created an upstream smelter due diligence fund to provide smelters and refiners a financial incentive to responsibly source from conflict-affected and high-risk areas (CAHRAs), offsetting the costs of mine-level assessments where no upstream assurance mechanism currently exists. The fund is an opportunity to encourage responsible sourcing from CAHRAs, while cultivating on-the-ground capacity and transparency in a manner that is not cost-prohibitive. The fund is housed within the RBA Foundation. Companies can contribute to the fund at their voluntary discretion, and receive acknowledgement. To be eligible for use of the funds, smelters must first meet the RMAP eligibility requirements.

Some key complementary programs to the RMI include:

Better Sourcing Program

The Better Sourcing Program has worked in collaboration with operators across the minerals supply chain to offer a scalable solution for responsible sourcing assurance and validation of upstream procurement, to support conformance of the receiving smelter with the RMI’s Responsible Minerals Assurance Process. It is designed primarily to encourage a flexible, comprehensive and transparent approach to responsible mineral sourcing, including from artisanal and small-scale mine sites.

Better Sourcing works with exporters not only in countries covered by Section 1502 of the United States’ Dodd Frank Act, but also exporters and importers likely to fall under the global scope of the EU Regulation on responsibly sourced minerals, to obtain or regain access to responsibly sourcing markets by demonstrating an improvement of supply chain conditions.

Better Sourcing compliance with the Responsible Minerals Assurance Process is based on strict, third-party audited application of principles from the OECD Due Diligence Guidance. It relies on the implementation of robust management systems (policies, procedures, traceability, transparency, monitoring, consultation, reporting) from mine to smelter, as well as ongoing risk evaluation and mitigation accounting for the specific circumstances of each supply chain, while minimizing costs to operators.

ITSCI

The Mines to Markets initiative is focused on responsible sourcing, including further reinforcing the systems that enable companies to responsibly source minerals, working with leading corporations to reduce child labor in mining in the DRC, and improving health and safety in the countries where Pact works. Pact implements the ITSCI due diligence and traceability system and develops/implements social programs to address issues such as occupational safety and health, formalization of the artisanal mining sector, and rights and opportunities for women in mining. 

New Programs the RMI is Reviewing for Upstream Recognition:

CRAFT

RESOLVE and the Alliance for Responsible Mining (ARM) have partnered to develop the Code of Risk mitigation for Artisanal and small scale mining engaged in Formal Trade (CRAFT), a new code of practice that helps miners and their buyers to assess critical social and environmental risks in artisanal supply chains – such as child labor, illicit trade, and uncontrolled use of chemicals – and to track progress in mitigating these and other risks. The code aims to help miners to understand and demonstrate conformity with the requirements of global markets, therefore improving their access to legal supply chains and better trading conditions. At the same time, companies will benefit from expanded, responsible minerals supply and governments will receive increased revenues as the formal market grows.

The RMI participated in the CRAFT Standard Committee and Advisory Group and is working to link the RMAP assessment program with CRAFT (as it has done with other upstream standards and assurance mechanisms such as ICGLR, IRMA, ITSCI and BSP) to help smelters and refiners demonstrate due diligence in sourcing from the upstream.