The Responsible Minerals Initiative (RMI) may recognize Upstream Mechanisms at two levels. The following criteria are required for Upstream Mechanisms to be recognized for each level:
Level 1: Recognition - Standard and Implementation
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:
- Implementation - with specific terms of recognition: refer to RMI Terms of Recognition Tables participating mechanisms need to complete here.
- KYC for upstream actors in high-risk supply chains (for 3T and EM limited to suppliers and in-country exporters; for cobalt, gold and precious metals - all main upstream actors)
- Supply chain risk assessment and mitigation
- Incidents and Alerts
- On-the-ground site assessments
- Mine site validation/base line assessment
- Mine-site Monitoring
- Traceability / Chain of Custody
- Traceability or chain of custody from mine to exporter or smelter in high-risk areas
- Due Diligence verification
Level 2: Standard Only Recognition
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 ONLY
Where the upstream assurance mechanism does not meet the RMI’s full recognition requirements but is granted partial recognition, the implementation at a programmatic level shall be assessed as part of the RMI’s RMAP smelter/refiner assessment.
Currently the RMI Recognizes:
- Upstream Mechanisms
- RCS Global / Better Mining – Independent third-party assessment against the OECD Due Diligence Guidance utilizing the OECD Alignment Assessment Tool and Methodology
- CRAFT Code (Standard Only) - Independent Third-Party OECD Alignment Assessment Report for CRAFT 2.0
RMI RECOGNITION PROCESS
For more information about the RMI Recognition requirements, please visit the RMI Recognition page here, review the RMI Recognition Process here and Upstream Mechanism Terms of Recognition Tables here.
FAQ ON UPSTREAM DUE DILIGENCE AND USE OF UPSTREAM MECHANISMS
To better understand the overarching expectations for upstream due diligence and use of upstream mechanisms, to support RMAP auditees’ continued responsible CAHRA sourcing and continuous improvement in due diligence, please review the Frequently Asked Questions (FAQ) here.
RMI Upstream Due Diligence
As part of its collaborative efforts, and ongoing review of RMI-recognized upstream mechanisms, the RMI engages upstream partners, including upstream programs and 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. 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 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 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:
RCS Global Group’s Better Mining is a fully OECD aligned and RMI Level 1 accredited Upstream Mechanism. In 2020, Better Mining covered 38 ASM mines sites. Better Mining enables conformance of the receiving smelter or refiner (SOR) with the RMI’s Responsible Minerals Assurance Process (RMAP) mineral agnostically. Better Mining enables mining companies and mineral exporters obtain access to international markets by demonstrating continuous improvement of supply chain conditions in countries covered by Section 1502 of the United States’ Dodd Frank Act, the EU Conflict Minerals Regulation and forthcoming EU Regulation on Batteries and Waste Batteries.
Better Mining operates a strict, third-party audited application of principles from the OECD Due Diligence Guidance. It builds 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.
On June 2, 2020 RCS Global has been granted recognition by the RMI for Better Mining demonstrating that it meets the requirements for a recognized Upstream Mechanism (Level 1: Full Recognition – Standard and Implementation), as outlined in the RMI Recognition Process document.
May 2023 Update: RCS Global Better Mining program OECD Alignment re-assessment is in progress for the purposes of on-going recognition by the RMI, with final Alignment Assessment report expected by October 2023. After this latest alignment assessment is concluded, if the RMI continues to recognize Better Mining, the scope and applicability of this upstream mechanism, as it relates to the specific requirements of RMAP, will be communincated through applicability table at the time of recognition.
CRAFT: Open-Source Standard for ASM Applicable to All Minerals
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, and Better Mining) to help smelters and refiners demonstrate due diligence in sourcing from the upstream.
RMI Recognition of CRAFT Code (Standard Only) OECD Alignment Assessment Results
The scope of the third-party OECD alignment assessment of CRAFT conducted November 2021 - February 2022 was limited to the written CRAFT Code standard and not the implementation.
Because CRAFT was developed as a tool for artisanal miners, its scope does not include all supply chain actors who would need to be part of an upstream assurance mechanism (Section A and C of the OECD Alignment Assessment Tool), so only OECD Section B of the tool was in scope.
The assessor evaluated CRAFT from a Standard Only perspective as it relates to Artisanal and Small-Scale Mining (ASM) Mineral Producers (AMP) and noted gaps that would need to be addressed to more closely reflect the full responsibilities of an upstream assurance mechanism.
For the purposes of RMI recognition, the evaluation determined that the CRAFT Code for AMPs meets the minimum 70% alignment required by the RMI Recognition Process for Level 2 Partial Recognition of Upstream Schemes in the context of Section B1 of the OECD Alignment Assessment tool, which is required to grant partial RMI recognition to the CRAFT standard. As per the RMI recognition process, CRAFT Code would have 1 year to reach at least 90% alignment to the OECD for the RMI to continue recognizing CRAFT.
The assessment also determined that Guidance for CRAFT Schemes does not meet the threshold for alignment as an upstream mechanism, which was assessed for Sections A, B and C of the OECD alignment Tool. For CRAFT Guidance for Schemes to be recognized by the RMI, in addition to Partial Recognition of CRAFT Code, CRAFT will need to address partially aligned and not aligned elements as defined in the report to reach minimum 70% required for all sections in scope.
Any amendments to the CRAFT Code require coordination with Alliance for Responsible Mining (ARM), the maintaining organization for the CRAFT Code. The RMI has engaged ARM on this.
March 2023 Update: ARM and Resolve are working with the RMI to bring CRAFT into further alignment with the OECD guidance based on the findings identified during the initial OECD alignment assessment completed in 2022. Proposed updates to the CRAFT code will be made available on the CRAFT website.