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Responsible Minerals Sourcing Policy (Step 1.A.2)
Has the company developed a due diligence policy for responsible minerals trade?
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About the data

In 2020, the Organisation for Economic Cooperation and Development (OECD) launched a project to develop a methodology to evaluate the extent to which companies embrace the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including how they align with its core elements, the 5-Step framework and the Annex II Model Policy. This metric belongs to that methodology.

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) was developed to provide recommendations to help companies respect human rights and avoid contributing to conflict through their mineral purchasing decisions and practices. The OECD Guidance is for use by any company potentially sourcing minerals or metals from conflict-affected and high-risk areas.
Look for a policy covering Responsible Minerals Sourcing. Such policies may be referred to using different terms including: responsible minerals sourcing, responsible minerals trading or due diligence policy for responsible minerals.

To receive a 'Yes' answer, the company policy must be focused on minerals sourcing and/or raw materials. A Conflict Minerals Report filed to the SEC, or a Code of Conduct document does not count as a responsible minerals sourcing policy. Some companies will include a link to their Conflict Minerals Policy in the Conflict Minerals Report, or include the entire policy in an annex to the Report and in those cases, the Conflict Minerals Policy counts as a 'Yes'.

Search for companies' Conflict Minerals Report filings (which may link to responsible sourcing policies) in the EDGAR company filings database. Find tips for navigating the database here.

For holding companies, if such a policy is referenced for one of its related entities that produce or distribute minerals, the policy may also count as the holding company's policy.