The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD DDG) is the definitive international framework for responsible mineral sourcing from regions including the DRC. It is referenced in the EU Conflict Minerals Regulation, the LBMA Responsible Gold Guidance, the DMCC Precious Metals Protocol, and the US Dodd-Frank Section 1502.
The Five-Step OECD DDG Framework - Applied to DRC
Step 1 - Establish Strong Company Management Systems
Companies must adopt a supply chain policy consistent with the OECD DDG, communicate it to suppliers, and establish a grievance mechanism. For DRC sourcing, this means a publicly stated conflict-minerals policy, supplier code of conduct, and a documented traceability system down to the mine or washing station level.
Step 2 - Identify and Assess Risks in the Supply Chain
Risk identification in DRC requires understanding the red flag indicators: geographic proximity to armed groups, use of illegal taxation, underage labour in ASM, and involvement of DRC armed forces. Hasnihl's in-country team conducts site-level risk assessments using IPIS mapping data cross-referenced with Ministry of Mines production records.
Step 3 - Design and Implement Risk Mitigation Strategies
Mitigation strategies for DRC minerals typically involve third-party chain-of-custody certification (iTSCi for 3TG, CRAFT Code for ASM gold), bagging and tagging at source, GPS-tracked transport, and smelter/refinery engagement through the RMAP (Responsible Minerals Assurance Process).
Key Takeaways
- OECD DDG compliance for DRC minerals is achievable with systematic implementation
- iTSCi and CRAFT Code are the primary chain-of-custody tools for 3TG and gold respectively
- RMAP smelter certification is the downstream anchor that validates upstream due diligence
- Hasnihl designs and audits compliant sourcing programs from mine to refinery
- EU Battery Regulation expanding DDG requirements to battery minerals from 2027