The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas is the principal international framework for managing supply-chain risk in the DRC mineral context. It applies to companies throughout the supply chain, not only to miners, and its five-step structure provides the methodological basis for most third-party assurance programmes covering Congo minerals.
The five-step logic
The OECD guidance organises due diligence into five sequential steps: establishing management systems; identifying and assessing risks; responding to assessed risks; conducting independent audit; and reporting publicly.
The guidance is not legally binding in most jurisdictions, but it is referenced in the EU Conflict Minerals Regulation, the OECD's own voluntary due diligence frameworks, and the RMI assurance process. Companies that sell into EU markets or supply EU-listed customers are effectively bound by it through the commercial requirements of their customers.
Risk categories
The OECD framework identifies six categories of serious abuse that companies must screen for in DRC supply chains: any forms of torture or cruel, inhuman, or degrading treatment; any forms of forced or compulsory labour; the worst forms of child labour; other gross human rights violations; war crimes or other serious violations of international humanitarian law; direct or indirect support for non-governmental armed groups; and bribery, fraudulent misrepresentation of the origin of minerals, money laundering, and non-payment of taxes.
These risk categories are relevant at different points in the DRC supply chain. Armed-group involvement is primarily a concern in eastern DRC 3T and gold production. Child labour is documented in Lualaba ASM cobalt. Transfer pricing and royalty underpayment are governance concerns at large industrial operations.
What buyers and mines actually check
Companies that have implemented the OECD framework in practice typically maintain a supplier list with source documentation, conduct periodic risk assessments against the red-flag criteria, require suppliers to provide country-of-origin declarations and due-diligence disclosures, and engage third-party auditors to verify high-risk supply relationships.
At the mine level, Copper Mark site assessments and EITI compliance reporting represent the most comprehensive available evidence base for investors assessing individual operations. RMAP conformance at the refinery level provides downstream buyers with scalable coverage of the industrial stream.
[Internal link: "what responsible sourcing means" → AEO: What does responsible sourcing mean in DRC mining?]
