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Λογότυπος της Ευρωπαϊκής Επιτροπής
Internal Market, Industry, Entrepreneurship and SMEs

The CMRT form for downstream companies

If you are a downstream company you can use the conflict mineral reporting template (CMRT) developed by the Responsible Minerals Initiative. This is a tool used by a large number of downstream companies to identify all smelters and refiners in their supply chains. You can learn how to use this tool by visiting the RMI's CMRT training page.

The inclusion of a service provider or industry initiative is neither an endorsement nor a recommendation. The onus is on SMEs to thoroughly research which service provider or industry initiative is the right option for them, and that may ultimately be an entity not listed below.

While the authors have taken all reasonable steps to include as many existing service providers (within the EU) as possible, there will be unintentional omissions. If you would like to recommend the inclusion of a service provider in a future iteration of this toolbox, please contact us.

OECD due diligence guidance: SME self-assessment for Step 1

This self-assessment will help you assess your gaps against step 1 of the OECD due diligence guidance: 'establish strong management system'.

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Interactive version of the OECD due diligence guidance

This website provides a user-friendly and interactive version of the OECD due diligence guidance, explaining how to implement the different steps.

The 3Ps checklist: Establish strong company management systems (OECD Step 1) through people, policies and procedures

This tool details the ‘3Ps’ that can help you with a successful implementation of step 1 of the OECD DDG: 'people, policies and procedures'. The 3Ps is not a tool recommended by the OECD DDG, but it can be a helpful starting point for step 1. It details the ‘what’, ‘why’ and ‘how’ that companies need to understand and successfully implement each step in the framework.

Step 1 of the OECD DDG sets out that companies should do the following

A. Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas (CAHRAs). This policy should incorporate the standards against which due diligence is to be conducted, consistent with the standards set forth in the model supply chain policy in annex II.

B. Structure internal management to support supply chain due diligence.

C. Establish a system of controls and transparency over the mineral supply chain. This includes a chain of custody or a traceability system or the identification of upstream actors in the supply chain. This may be implemented through participation in industry-driven programmes.

D. Strengthen company engagement with suppliers. A supply chain policy should be incorporated into contracts and/or agreements with suppliers. Where possible, assist suppliers in building capacities with a view to improving due diligence performance.

E. Establish a company-level, or industry-wide, grievance mechanism as an early-warning risk-awareness system.

Step 1 is vital for ensuring a company’s due diligence processes are supported by a strong foundation: without a successful step 1, steps 2 to 5 of the OECD DDG will be extremely difficult, if not impossible, for a company to implement.

The 3Ps framework is general in nature and can be modified by companies to meet the needs of their business.

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Letter template to suppliers

This letter can be used by companies who must or want to comply with the EU regulation 2017/821 of the European Parliament and of the Council laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas

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General preparation for an audit

This section provides a set of good practice activities, which will help you prepare for an audit. You can download and print it and use it to support you in the preparation phase.

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Checklist for annual report

This checklist is in line with step 5 of the OECD DDG. You can use this checklist to make sure your annual report covers all that is required. Make sure you pay due regard to confidentiality and other competitive or security concerns.

This document only covers reporting for downstream and mid-upstream companies. Upstream companies are not covered by this document, as few companies in the EU are involved in, for example, the extraction of tin, tantalum, tungsten and gold (3TG).

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Risk assessment tools and initiatives

This section provides a snapshot of some of the various risk management tools, guidelines and initiatives that companies can use to help manage or complement their supply chain due diligence activities.

Download the file (181 kB)

Please see the disclaimer under 'self-assessment' below and contact us if necessary.

IT solutions for due diligence

This section details some of the IT solutions available to companies seeking to manage risk in their supply chain. It also highlights some opportunities for alignment, to reduce costs and bring efficiency to supply chain due diligence. The price for the services that these companies supply will vary depending on factors including the size of company, complexity of supply chain, number of suppliers and the level of support that the service provider is asked for. It is not possible to generalise about the cost of each provider and companies should reach out for a quote find out the price based on their size and needs.

Download the file (216 kB)

Please see the disclaimer under 'self-assessment' below and contact us if necessary.

Self-assessment on social and environmental risks in raw material extraction and processing

This is a self-assessment tool developed by the Responsible Minerals Initiative (RMI) for minerals and metals producers and processors to assess and communicate their risk management practices and performance using benchmarked norms.

See the RMI's Risk Readiness Assessment for more.

Indicative, non-exhaustive list of conflict-affected and high-risk areas (CAHRA)

The current indicative, non-exhaustive list of conflict-affected and high-risk areas under Regulation (EU) 2017/821 can be visualised on the page, alongside further information and individual reports for each CAHRA.

EPRM due diligence hub

Companies can access guidance to implement the five steps, case studies, examples of European Partnership for Responsible Minerals (EPRM) projects, a resource library, and a self-assessment tool (see EPRM due diligence check, described below).

EPRM due diligence check

This tool, designed for SMEs working in supply chain for 3TG minerals, guides companies through a questionnaire tailored to their characteristics. Companies then receive general recommendations for improvement.

Disclaimer: The inclusion of a service provider or industry initiative is neither an endorsement nor a recommendation. The onus is on SMEs to thoroughly research which service provider or industry initiative is the right option for them, and that may ultimately be an entity not listed below.

While the authors have taken all reasonable steps to include as many existing service providers (within the EU) as possible, there will be unintentional omissions. If you would like to recommend the inclusion of a service provider in a future iteration of this toolbox, please contact us.