Downstream Audit Program

The supply chain due diligence scheme concerning downstream actors, including metals importers selling into the EU that may be subject to the EU Conflict Minerals Regulation (EU). The RMI has been approached by multiple companies within the tin, tantalum, tungsten and gold supply chains who seek validation of their sourcing practices yet are not eligible to participate in the Responsible Minerals Assurance Process (RMAP) as they do not meet the definition of a smelter/refiner. These companies are increasingly requested by their customers to demonstrate their responsible sourcing practices are aligned with the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas, and to provide validated information about their due diligence activities. To address this emerging request, the RMI worked with a multi-stakeholder team of RMI members, smelters, and downstream processing facilities, to design and launch a pilot program that provides an independent validation of companies’ sourcing practices outside of the RMAP audit process. The program was launched in April 2016 with six companies that chose to voluntarily participate in the assessment process.

The RMI hosted a webinar providing an overview of the downstream program. You may access a recording of the webinar hereThe presentation slides are also available here.

Downstream Program Participants

Who is Eligible?

Companies that fall within the following categories are eligible for participating in this program:

  • Manufacturer: A manufacturer refers to a company that makes products and where the metal is added into a product and/or a product containing metals is further processed or assembled.

  • Materials Treatment Specialist: Company or facility solely processing materials sent for external treatment are not within the scope of this assessment. This external treatment must not include smelting or refining processes. For example, a materials treatment specialist might receive materials from the smelter to remove hazardous contaminants (e.g., arsenic, radioactivity) as a service, and then return the treated materials to the smelter. Such materials, if continually owned by the smelter, do not require additional origin information on their return from such a company.

  • Recycler/Handler/Material Recovery Company: A company or facility with one or more facilities with the ability to mechanically process secondary materials using means such as shearing, cutting, sawing, shredding, briquetting/compacting, shot/sand blasting (wheel abrade and pneumatic) and machining.

  • Trader: An individual or company that buys and sells mineral containing substances or products without altering their physical or chemical state. This may include mineral, metal or product importers or exporters.

  • Union Importer: Any natural or legal person declaring minerals or metals for release for free circulation within the meaning of Article 201 of Regulation (EU) No 952/2013 of the European Parliament and of the Council (1) or any natural or legal person on whose behalf such declaration is made, as indicated in data elements 3/15 and 3/16 in accordance with Annex B to Commission Delegated Regulation (EU) 2015/2446 (2).

Note: Any smelter site belonging to a company that owns a primary smelter is also considered to be a primary smelter and therefore is not eligible for the Downstream Audit Program.

Cost

The auditee is responsible for the cost of the audit, which is dependent on the size of the facility, the complexity of the operations and location, among other factors. The RMI charges a management fee in addition to the auditor firm’s quoted cost.

Objective

Provide a mechanism for downstream companies to obtain independent validation of responsible sourcing practices, including that:

  • The company’s due diligence system is designed and implemented in accordance with the OECD Due Diligence Guidance;

  • All sources of 3TG are identified and confirmed to be:

    • Scrap or recycled material; and/or

    • Responsible Minerals Assurance Process (RMAP) conformant smelters and refiners, or equivalent validated companies.

The extent to which each process is reviewed is tailored according to the type of company.

Process Reviewed Mineral Processors Traders Manufacturing/Assembly
Determination of Scope   x x
Supplier Management x x  
Supply Chain Transparency x x x
Due Diligence x x x
CMRT x x x

What is Assessed?

The audit is carried out against the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas. The audit follows the ISO19011:2011 standard for management systems audits to assess a company’s processes to:

  • Determine the products and suppliers included in the effort to identify smelters and refineries in the supply chain to confirm that the scope is correctly defined

  • Select, approve and monitor suppliers of 3TG or products containing 3TG

  • Monitor transactions of 3TG received and to maintain adequate documentation to confirm the origin of 3TG or 3TG containing product

  • Identify, assess, and manage risks in the 3TG supply chain in line with the OECD Due Diligence Guidance

  • Develop and review reporting tools, including the Conflict Minerals Reporting Template (CMRT)

What are the benefits of participating?

  • Consolidates reporting requirements within the downstream by making the auditing and reporting process more streamlined.

  • External review of supply chain due diligence program, which provides an assessment of:

    • The scope of the program;

    • The design and effectiveness of due diligence activities;

    • The accuracy of reporting to customers;

  • Full Audit Report, including all information pertaining to the audit;

  • Audit Summary Report that can be shared with interested customers or made public (confidential information redacted);

  • Public listing via an online and publicly accessible RMI registry, which lists companies that have passed the audit;

  • Relevance for companies importing 3TG-containing products into the EU in light of the new EU Directive on Conflict Minerals, which requires mandatory due diligence for importers of minerals and metals of 3TG.

  • Demonstrate year on year improvement of due diligence for your company

Who Conducts the Audtis

The Downstream Audit Program is a third-party audit.  RMI works with the auditors on our approved audit firm list to conduct the Downstream Audit Program Assessments.

Program Documents

  • Audit Agenda Template (ENG | CHI) to provide a generic layout of audit activities
  • Audit Guidance (ENG | CHIprovides detailed information for companies wishing to undergo an audit and should be used for audit preparation
  • Pre-Audit Questionnaire (ENG | CHI) to gather basic information to determine the scope of the audit and identify the correct location for the auditor to visit.
  • Audit Questionnaire [ Manufacturers (ENG | CHI) | Processors (ENG | CHI) ] to ensure the consistent implementation of the audit process.
  • Audit Report ( Manufacturers | Processors | Traders ) containing full results and details of audit, designed for internal use
  • Audit Summary Report ( Manufacturers | Processors | Traders ) summarizing the audit process and results, confidential information removed, designed to be shared publically or with customers
  • Corrective Action Plan based on a standardized scoring matrix defining risk levels, type of non-compliances, timeframes for corrective actions as well as basic corrective actions to be taken.

How do I Learn More?

For more information about the program or to apply, please contact Hillary Amster at hamster@responsiblebusiness.org.