Progressive Improvement in Due Diligence: Moving from Self-Assessment to Independent Third-Party Assurance in the Cobalt Supply Chain
Webinar on Tuesday 23 June 2020 at 16.00 CET
The Cobalt Institute (CI) and the Responsible Minerals Initiative (RMI) organized a webinar – initially meant to be an in-person side event during the OECD Forum on Responsible Mineral Supply Chains – on 23 June 2020.
The purpose of the webinar was to:
- Show real examples of how companies assess their current performance in managing sustainability risks in cobalt supply chains, work to close gaps, and monitor improvement over time.
- Demonstrate how companies can leverage currently available industry tools to enter a progressive pathway from initial self-assessments to full independent third-party assurance, in line with the OECD Due Diligence Guidance.
- Raise awareness and understanding of CIRAF and RMI requirements and explain how these tools can help companies meet market expectations, such as LME requirements.
- Share common challenges in implementation of cobalt due diligence and practical actions companies can take to address these issues.
The webinar kicked off with two technical presentations. The first one introduced the CIRAF, its adoption, and the progressive pathway from self-assurance to third party certification in cobalt due diligence. The second technical presentation delved into the Cobalt RMAP process, requirements, tools, and uptake among cobalt refiners. Subsequently, two presentations followed from a mining and a refining company in the cobalt supply chain. The companies shared their practical experiences on conducting cobalt due diligence. The webinar ended with a round of Q&A and the facilitator’s summation.
Key Discussion Points
- The CI’s CIRAF and RMI’s Responsible Minerals Assurance Process (RMAP) are promoting responsible cobalt sourcing and production and helping companies in conducting due diligence from self-assessment to third party assurance: As a good practice management and reporting framework, the CIRAF enables companies to identify and respond to nine cobalt supply chain risks and demonstrate good sourcing practices. The RMI supports cobalt crude and fine refiners and the cobalt value-chain at large through its independent third-party assessment program, the Responsible Minerals Assurance Process (RMAP), and the Cobalt Refiner Supply Chain Due Diligence Standard, which are increasingly being adopted by companies worldwide. Both sets of tools are based the OECD Due Diligence Guidance yet remain conformant with other industry standards and applicable to companies’ in-house risk management systems. Both CI and RMI encourage companies to start with risk-assessment tools and transition to independent third-party assurance, which is increasingly being required by customers, downstream brands, and market expectations.
- Use and benefits of industry programs and resources for companies in conducting cobalt due diligence: The two presenting companies both used the OECD Due Diligence Guidance to develop their own risk management systems. In addition, the mining company adopted numerous international good practice standards to inform its policies and created a governance structure to support their implementation including oversight by the Board of Directors. The refiner also listed several tools it uses to complete the 5 steps of the OECD Due Diligence Guidance, namely the RMI Risk Readiness Assessment, supplier assessments, RMAP independent third-party assessment, and Corrective Action Plans. Among other benefits, the refiner witnessed a decrease in customer-managed second-party audits required by customers and improved acceptance from its suppliers, due to the high industry recognition of RMAP. The refining company is a strong supporter of cross-industry and global collaboration and engagement, and encourages stakeholders to participate in responsible supply chain trainings, supplier capacity-building activities, and awareness raising events organised and supported by the Responsible Cobalt initiative (RCI) and OECD. The mining company, which has piloted the CIRAF program as early as 2018 is now discussing transitioning towards independent third-party assurance.
- Importance of active local stakeholder engagement and risk mitigation:The RMI and both companies discussed their local engagement in the DRC. The RMI highlighted two ongoing opportunities for downstream companies to support cobalt refiners and mineral producers, via the RMI Assessment and Upstream Due Diligence Fund which offsets the cost of refiner audits and provides $10k USD grants to refiners for their mine-level due diligence; and the RMI-Better Mining Partnership, which provides independent mine-site monitoring and CAP management services to ASM operators. The mining company, whose operations are directly affected by ASM-related risks, developed a human rights program and introduced a product stewardship management system to handle confiscated ore from illegal ASM. The company also funds community programs to support health, education, and economic development. The refining company supports field investigations and trainings in the DRC via collaboration with the RCI.
- Future perspectives: The two companies voiced their support for collective industry action. The refiner highlighted current challenges for companies – the lack of cross-recognition of industry programs and the need to improve engagement between downstream and upstream companies – called out to its peers, refiners and treatment units, to engage in industry programs such as RMAP. The mining company welcomed the CIRAF’s addition of new standards to meet external stakeholders’ expectations. It also stressed on the opportunity technology may offer on tracking and tracing products. The company discussed how digitizing chain of custody could benefit its customers that were themselves being audited.The CIRAF will continue to support companies in adopting and implementing its framework while encouraging them to transition to independent third-party assurance.
The CIRAF will also keep on engaging with stakeholders to further promote the development of responsible sourcing standard. To facilitate this process, a website called responsiblecobalt.org was launched in June 2020. It serves as an information hub for CIRAF and cobalt responsible sourcing and will feature examples of member projects and practices. In 2019, RMAP was expanded to include both cobalt fine refiners and treatment units, and will include options for broader ESG assurance in alignment with the LME expectations over the coming year. The RMI will continue to update tools to help companies with their cobalt due diligence, including the Cobalt Reporting Template, Risk Readiness Assessment, Cobalt training Materials, and public reporting tools. The RCI and RMI are working together to co-issue a revised Cobalt Refiner Supply Chain Due Diligence Standard, estimated in Q3 2020.