The RMI encourages responsible sourcing from conflict affected and high risk areas (CAHRAs). The RMI does not provide lists of countries that may be conflict-free or conflict-affected. The nature of conflict is ever-changing, while some conflicts may be country-wide, many conflict-related and high-risk incidents are concentrated on a regional or local level, or involve individual sites, entities, and actors. Once companies idenitify which conflict-affected and high-risk areas their are sourcing from, both country-level risk assessments and individual supplier due diligence are critical to ensure responsible sourcing of minerals from CAHRAs. In alignment with the OECD Due Diligence Guidance, the RMI provides tools and resources to enable companies to conduct individual and collective due diligence within supply chains to source minerals responsibly.
OECD definition of conflict-affected and high-risk areas: Conflict-affected and high-risk areas are identified by the presence of armed conflict, widespread violence or other risks of harm to people. Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies, civil wars, etc. High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence. Such areas are often characterised by widespread human rights abuses and violations of national or international law.
EU definition of conflict-affected and high-risk areas: Areas in a state of armed conflict, fragile post-conflict areas, as well as areas witnessing weak or non-existing governance and security, such as failed states, and widespread and systematic violations of international law, including human rights abuses.
CAHRAs Procedure Guidance
To support companies' development of their CAHRAs procedures, the RMI created Example Procedures to Identify CAHRAs for companies. This document covers the requirements defined in the Responsible Minerals Assurance Process (RMAP) and is grounded in the OECD Due Diligence Guidance and EU Conflict Minerals Regulation. When developing the CAHRAs procedure, companies can take into account size and complexity of their operations. Companies may find a combination of the publicly available resources referenced below and other resources (such as custom-tailored tools such as the RMI’s Country Risk Assessment Tool available to RMI members and RMAP auditees), may work best for their company’s operations. Once a company designs their procedure, the next step is to review countries of origin and transit of their materials, and country where company is operating against the procedure to identify if any would qualify as CAHRAs.
According to the RMI RMAP Standard, the CAHRAs shall include, at a minimum, countries identified as high-risk by relevant conflict minerals regulation, such as: The Democratic Republic of the Congo (DRC) and its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act, namely Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia; and, the indicative and non-exhaustive list of CAHRAs provided by the European Commission pursuant to Article 14.2 of the European Union Regulation 2017/821 (once available and adopted by RMI).
- Commission Recommendation (EU) 2018/1149 – The European Commission has published their non-binding guidelines for the identification of conflict-affected and high-risk areas and other supply chain risks under Regulation (EU) 2017/821 of the European Parliament and of the Council: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018H1149
- Heidelberg Conflict Barometer – presence of armed conflict: https://hiik.de/conflict-barometer/current-version/?lang=en
- Control Risk Worldmap – security and political risks: https://riskmap.controlrisks.com/-/media/43291d62ec9e4964beb6eb3e3a54a080.ashx
- INFORM worldmap – humanitarian crisis (not limited to conflict or security issues): www.inform-index.org/Countries/Country-Profile-Map
EU CAHRA Guidance: 4.2 - List of open information sources
Source: Commission Recommendation (EU) 2018/1149 of 10 August 2018 on non-binding guidelines for the identification of conflict-affected and high-risk areas and other supply chain risks under Regulation (EU) 2017/821 of the European Parliament and of the Council, https://eur-lex.europa.eu/eli/reco/2018/1149/oj.
OECD and EU Guidance
The OECD Due Diligence Guidance provides detailed recommendations to help companies respect human rights and avoid contributing to conflict through their mineral purchasing decisions and practices. This Guidance is for use by any company potentially sourcing minerals or metals from conflict-affected and high-risk areas.
Sanctions Lists - to identify sanctioned companies / individuals
US OFAC Sanctions
United States Department of Treasury Office of Foreign Assets Control administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.
Consolidated United Nations Security Council Sanctions List.
Comprehensive list of sanctions imposed by the European Union.
Country Rankings and Indices - to assist with Risk Assessment
Global Peace Index
The world’s leading measure of national peacefulness, the GPI measures peace according to 23 qualitative and quantitative indicators
Heidelberg Conflict Barometer
The Conflict Barometer published annually since 1992 analyses the global conflict events. It includes non-violent and violent crises, wars, coup d'etats as well as peace negotiations.
Know Your Country
Country by country reports of money laundering and sanction information
Interactive tool for human development data from around the world. Data presented was used in preparation of the 2016 UNDP Human Development Report. The Human Development Report Office releases five indices each year: the Human Development Index (HDI), the Inequality-Adjusted Human Development Index (IHDI), the Gender Development Index (GDI), the Gender Inequality Index (GII), and the Multidimensional Poverty Index (MPI).
US Department of State country reports on Human Rights
TI Country Corruption Reports
2018 List of Goods Produced by Child Labor or Forced Labor
The World Bank’s Worldwide Governance Indicators
The indicators are used to analyze economic outcomes and identify what reforms of business regulation have worked, where and why.
WJP Rule of Law Index, the world’s leading source for original, independent data on the rule of law.
OHCHR has country pages linking to more specific sub-reports for human rights related topics:
- Example: OHCHR report for DRC
Resources in other languages and/or region-specific
- China’s Overseas Security Risks Blue Book (2018) by National Security Research Department of Renmin University, China Overseas Security Research Institute and China National Petroleum Corporation. This publication focuses on the geopolitical elements. The publication is available in book stores/e-commerce platforms in China. The Paper's press release (in Chinese) on the book's publication is available at http://www.cssn.cn/zx/bwyc/201802/t20180202_3838395.shtml.
- The 2018 Country-risk Rating of Overseas Investment from China report by the Chinese Academy of Social Sciences (CASS). The report is updated annually and its broad range of indicators include e.g. internal conflict, external conflict, government stability, military intervention in politic, etc. The report is available at http://en.iwep.org.cn/papers/papers_papers/201801/W020180130339272647312.pdf.
- CASS and China Bond Rating Co., Ltd. work together and published the Blue Book of Outbound Investment and Risks, which includes dedicated sessions on armed conflict, geopolitical context and political stability. The link to the summary of its key findings (in Chinese) is available at https://www.ssap.com.cn/c/2017-04-12/1053144.shtml.
Risk Assessment Tools
Risk Assessment in Raw Materials Supply Chains assessing social and environmental risks in raw material extraction and processing, and industry’s ability to appropriately manage such risks, remains a challenge for downstream companies due to the size and complexity of international supply chains.
Responsible Sourcing Council Risk Assessment tool for actors across the supply chain.
Developed for Good Delivery Refiners to assess Risk level of the business relationship based on supply chain information and sourcing practices evaluation.
Databases and Risk Data Sources
Global risk indices, analytics and risk management solutions. Country risk monitoring, customizable risk calculators, dashboards and solutions for assessing and mitigating risk from market entry to project development, operation and closure.
Risk intelligence that serves the Know Your Customer (KYC) and third party risk management of highly regulated industries. For organizations concerned with business relationship risk and financial crime compliance, World-Check helps powers a variety of identity verification, AML/CFT/PEP screening and KYC due diligence processes.
Compliance - anti-corruption and third-party due diligence, sanctions resources. Extensive company data, corporate structures and adverse data that delivers fast insight on your customers and business partners, and the individuals behind them for governance, risk management and compliance.
Europe’s leading independent research and consultancy organization working for a sustainable future. Provides information on environmental and legal compliance through reports and publicly available research.
Tools for risk assessment, mitigation, remediation, and reporting.
Other potential Risk Data Sources: