The guidance, compiled by the Responsible Sourcing Network and Enough Project, has been produced ahead of the 31 May 2014 deadline that requires companies who source minerals from the Democratic Republic of Congo to submit their first conflict minerals disclosures to the US Securities and Exchange Commission (SEC).
Policies should articulate a commitment to ensuring sourcing practices do not support conflict, human rights abuses including forced labour, mass atrocities and crimes against humanity, the Expectations for Companies’ Conflict Minerals Reporting guidance stated.
It detailed how firms should commit to exercising supply chain due diligence and consider the implementation of a supply chain transparency system that allows for the identification of the smelters and/or refiners in its minerals supply chain.
The metals tin, tantalum, tungsten and gold – also known as 3TG – should only be sourced from conflict-free covered countries, while companies should only use 3TG minerals from smelters that have been audited and verified as conflict free by a credible programme such as the Conflict-Free Sourcing Initiative, the document states.
Other recommendations include developing a conflict minerals programme that incorporates a description of the steps that will be taken to identify, assess, mitigate and respond to risks.
At a minimum steps should include supply chain surveys, supplier training, supplier and smelter encouragement, and an obligation to participate in the Conflict Free Smelter programme or equivalent, provided such industry schemes adhere to international standards, audits and unannounced spot checks, the report stipulated.
Darren Fenwick, senior government affairs manager at the Enough Project and report co-author said advocates for a clean minerals trade were keen to understand how companies, who are connected to the Congo through mineral sourcing, are addressing their connection to the conflict that has resulted in millions of deaths.
“Companies whose reports show compliance benefit from positive public sentiment and increased brand recognition,” he said.
Fellow co-author Patricia Jurewicz, Responsible Sourcing Network director added: “Investors would like to see their companies establish baselines the first year and specify the steps they are taking so we can then measure improvements in transparency and accountability reporting over time. Our paper provides a set of specific indicators that can be tracked to allow for comparability between annual reports.”