An Overview of the Responsible Minerals Initiative (RMI) for Supply Chain and Compliance Professionals ADVANCED SUPPLY CHAIN COMPLIANCE SERIES

Transcription

1 An Overview of the Responsible Minerals Initiative (RMI) for Supply Chain and Compliance Professionals ADVANCED SUPPLY CHAIN COMPLIANCE SERIES January 11, 2018

2 1 About Michael Littenberg Michael Littenberg is a partner at Ropes & Gray. As part of his practice, for more than 25 years, Michael has been active in advising leading public and private companies on supply chain compliance, ESG and corporate social responsibility matters, including with respect to conflict minerals, and he is widely viewed as the leading practitioner in this emerging area. Michael advises clients on, among other things: Michael R. Littenberg Partner T F Michael.Littenberg@ropesgray.com Compliance with a wide range of enacted, pending and proposed regulatory requirements; soft law instruments; and industry and NGO codes of conduct, standards, frameworks and guidance Due diligence Risk and impact assessments Structuring and implementation of tailored compliance policies, procedures, programs and codes of conduct Public benefit corporations Training Benchmarking Regulatory and voluntary disclosures and other communications Stakeholder engagement Grievance mechanisms

3 An Overview of the Responsible Minerals Initiative (RMI) for Supply Chain and Compliance Professionals January 2018

4 RBA Structure Founded in 2004 the Responsible Business Alliance is the world s largest industry coalition dedicated to electronics supply chain responsibility.

5 RMI Mission Provide companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas. Responsible Minerals

6 RMI Multi-Industry Membership VDA, AIAG, USFIA, JEITA Assent Compliance, Gensuite, ipoint, Source Intelligence, SupplierSoft, Total Parts Plus Responsible Minerals

7 Natural Evolution 2007 Extractives Workgroup CFSI Electronics Industry NGO-driven Multi-industry Tin, Tantalum, Cobalt DFA, OECD-driven DRC 3TG Conflict Covered Countries New initiative Conflict DFA Compliance RMI Multi-industry DFA + EU OECD-aligned 3TG+ Global CAHRAs Global Raw Materials Due Diligence

8 Sensing and Prioritization 3TG + Development of RMI sensing & prioritization process: Supply Chain Indicators: Volume, Criticality, Availability of Recycled Material Key Risk Indicators: ASM Production, Child Labor and Forced Labor, Occupational Health & Safety, Armed Conflict, Weak Governance, Environmental, Chemical Processing

9 Sensing Research 3TG+ Joint research project: RMI, Drive Sustainability and the Dragonfly Initiative: Material Risk Matrix for 45 materials commonly used in automotive and electronics industry; Material Risk Profiles for priority 17 materials To be published by March 2018 Research on application of mica in RMI member industries; Engagement with stakeholders on responsible business and sourcing practices in mineral supply chains.

10 RMI Structure and Workgroups Steering Committee RMI General Membership - Plenary Body Mineral Reporting Templates Team Due Diligence Practices Team Smelter Engagement Team Assurance Standards Team Tin Working Group Cobalt Team Sensing and Prioritization Multi-Stakeholder Group Supply Chain Data Management Team Mica Exploratory Team Disposition Team Gold Team Cross-recognition Group - RMI, RJC, LBMA Responsible Minerals

11 RMI Audit Program Responsible Minerals Assurance Process (RMAP)

12 What is the Responsible Minerals Assurance Process? RMAP (formerly CFSP) Smelter and Refiner Audits help companies demonstrate reasonable due diligence, country of origin inquiry, identify/mitigate risks, meet legal requirements. Finished Products Companies Suppliers Downstream Due Diligence Supplier mapping (CMRT) Supplier audits (Downstream Audit Program) Risk Assessment (RRA) Public reporting Raw Materials RMAP Smelters & Refiners Mines Independent 3 rd Party Audit System in place to source responsibly Demonstrated with evidence OECD-aligned Upstream CoC/Due Diligence itsci, BSP, Just Gold Independent 3 rd Party Evaluations Responsible Minerals

13 Percentage of Global Smelter and Refiner Participation in Due Diligence Programs Tantalum smelter % participation Tin smelter % participation Tungsten smelter % participation Gold smelter % participation Responsible Minerals

14 OECD Alignment Assessment Scope EU Efficiency Alignment Five programs Required for RMI approval in the EU framework Audit program harmonization for smelters so they do not need additional audits to export to EU Aligns existing integrated programs (e.g. upstream assurance mechanisms with smelter audits)

15 Audit Standard Revisions: Sn/Ta, W, Au Aligned with OECD Guidance five step framework and ISO management systems requirements Expanded geographic scope from DFA covered counties to Global Inclusion of OECD Guidance Annex II Risks not only conflict risk Step 5 reporting and audit summary reports Consolidated document examples for high risk sources

16 RMI Tools and Resources

17 Public Smelter and Refiner Lists Updated multiple times/week Responsible Minerals

18 Responsible Minerals Assurance Program RCOI Data Under revision to be inclusive of Conflict-Affected and High- Risk Areas globally

19 Public Minerals Reporting Template General Minerals Reporting Template under discussion and development Responsible Minerals

20 RMI Smelter Database Responsible Minerals

21 Public RMI elearning Academy FREE! Course assignments and team libraries can be customized Add your own materials, create your own quizzes Contact us for an account

22 Courses and Resources Added in Risk Based Audit Program 2. Risk Readiness Assessment (RRA) Introduction 3. Downstream Audit Program Training 4. CFSP Auditor Training 5. Featured Topic 1: Introduction to the OECD 5-Steps 6. Featured Topic 2: Tools for Responsible Sourcing from High-Risk Areas 7. Featured Topic 3: Identifying Risks 8. Webinar 1: Overview of Revised Standard 9. Webinar 2: Practical Aspects of Implementation 10. Webinar 3: OECD Step Webinar 4: Introduction to Auditing Against the Revised Standard 12. Featured Topic 4: KYC and AML

23 Risk Readiness Assessment (RRA) A self-assessment and selfreporting tool to communicate and share risk management practices and performance using benchmarked industry norms. A tool to help companies obtain accurate and relevant information practices to inform sourcing policies. Currently includes downstream companies, 3TG and Cobalt smelters, refiners, and mining companies. Current Uptake 164 upstream companies 165 RRAs completed Cobalt processors added in October 60 Downstream Companies Upcoming Upgrades Translations (Japanese, Chinese, Bahasa) Connect to training resources in the platform Aggregated reports and analysis

24 Risk Readiness Assessment (RRA) Upstream users (smelters, refiners, mine sites): selfassessment and self-reporting of risk management practices and performance Downstream users: relevant information on risk management practices in the upstream supply chain

25 Issue Areas Governance 1. Legal Compliance, Engagement 2. Business Integrity 3. Stakeholder Engagement 4. Business Relationships Labor & Working Conditions 5. Child Labor 6. Forced Labor 7. Freedom of Association and Collective Bargaining 8. Discrimination 9. Gender Equality 10. Working Hours 11. Remuneration 12. Occupational Health and Safety Environment Community Business & Human Rights 13. Environmental Risk Management 14. Greenhouse Gas (GHG) Emissions 15. Energy Consumption 16. Fresh Water Management and Conservation 17. Waste Management 18. Tailings Management 19. Pollution 20. Biodiversity and Protected Areas 21. Mine Closure and Reclamation 22. Community Health and Safety 23. Community Development 24 Artisanal and Small Scale Mining 25. UN Guiding Principles on Business and Human Rights 26. Security and Human Rights 27. Indigenous Peoples Rights 28. Land acquisition and resettlement 29. Cultural Heritage 30. Conflict Minerals 31. Grievance Mechanism

26 Standards Comparison Recognizes existing standards commonly used in the materials value chain. The tool is based on the comparison of over 50+ standards across 31 risk areas.

27 Structure of the Self-Assessment

28 Risk Readiness Assessment

29 Grievance Mechanism Purpose Standardized incident receipt and response process Enhances risk mitigation Fosters continuous improvement Data points 17 grievances logged in grievances logged in 2017 (through Sept) Summary report provided to members Largest number of incidents Smelters and refiners Upstream programs Mining operations

30 RMI Latest Developments

31 Responsible Sourcing of Cobalt Cobalt working group launched early 2017: Materiality to RMI member industries; Salient risk in cobalt supply chains; Opportunity to leverage existing RMI tools & resources. Objective: Provide tools and resources to enable RMI members to exercise due diligence in accordance with OECD Due Diligence Guidance; Collaboration with cobalt stakeholders including: Responsible Cobalt Initiative; Global Battery Alliance; Cobalt Institute; Upstream mechanisms.

32 Cobalt Tools & Resources Supply chain mapping: Consolidation of supply chain mapping information; Definition of cobalt refiner ; Outreach to alleged cobalt refiners identified during the mapping; Addition of alleged and confirmed cobalt refiners to RMI Smelter Database; Development of Cobalt Smelter Reference List Development of cobalt refiner reporting tool. Risk Assessment: Addition of cobalt entities to RRA platform; Development of joint pilot audit program between RMI RCI for cobalt refiners

33 Indonesia Tin Working Group Stakeholder Engagement - Local stakeholders: TWG Associate and Local Advisory Committee - Int l stakeholders: RMI multi-stakeholder call, bilateral engagement Tools Pilot Projects 395,000 EPRM grant EPRM funding: Pilot projects on OHS Capacity Building and land reclamation TWG Members: Definition of supply chain expectations (focus on OHS and land reclamation) & sensing on risks and strategy for offshore mining

34 2017 Publications

35 Meet RMI Staff Leah Butler Vice President Michèle Brülhart Director of Innovations Hillary Amster Senior Program Manager Marianna Smirnova Project Manager Gavin Wu Program Associate

36 For further inquires: Responsible Minerals

37 QUESTIONS & ANSWERS