RMI Annual Conference 209

Downstream Assessment Program

In 2016 the RMI launched its Downstream Assessment Program to meet the growing demand for validation of sourcing practices of companies in the tin, tantalum, tungsten and gold (3TG) industries that are not eligible for the Responsible Minerals Assurance Process (RMAP) because they do not meet the definition of a smelter or refiner.

Facilities participating in the Downstream Assessment Program have often been asked by their customers to demonstrate that 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.

The table below includes all facilities that have successfully completed a downstream assessment:

Who is Eligible?

Companies that fall within the following categories are eligible to participate in this program:

  • 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 eligible for the RMAP and not eligible for the Downstream Assessment Program.
  • Manufacturing/Assembly: 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.
  • Processor: The company procures tantalum, tin, tungsten, gold or cobalt metal products to transform, process or otherwise treat the material. Processors do not have the capability to perform smelting or refining processes, and do not meet the definition of a “smelter” or “refiner” according to the applicable RMAP Standard.
  • Trader: An individual or company that buys and sells mineral-containing substances or products without altering their physical or chemical states. This may include mineral, metal or product importers or exporters.

Program Documents

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

To request a downstream assessment or learn more, please contact Catherine Tyson.

What is Assessed?

The assessment is based on the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas.

The assessment follows the ISO19011:2011 standard for management systems assessments to assess a company’s processes to:

  • Determine the products and suppliers included in the effort to identify smelters and refiners 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 RMI’s Conflict Minerals Reporting Template (CMRT)

What are the benefits of participating?

  • 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
  • Consolidates reporting requirements within the downstream by streamlining the assessment and reporting processes
  • External review of the 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 Assessment Report, including all information pertaining to the assessment
  • Assessment 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 assessment
  • Demonstrate year-over-year improvement of due diligence for your company