Responsible mineral sourcing: documenting the review

A responsible-sourcing statement needs a defined scope. A business making one should be able to explain the source or transaction it covers, the work completed and the limitations of the information reviewed.

The OECD’s mineral guidance provides risk-based recommendations for supply-chain management, including human-rights and conflict-related risks. It is due diligence guidance, rather than a certificate issued for an individual shipment. ^[1]

Define the claim before making it

Decide what the business is saying about a source, a supplier or a transaction. Avoid statements that imply a whole operation has been independently assessed when only one document has been checked.

Use precise language. “Origin information requested” describes an action. “Source independently verified” describes a stronger conclusion requiring an appropriate basis. A policy should help staff distinguish the two.

Identify the parties and the route

Map the commercial participants and the physical movement of material as far as the available evidence allows. Record gaps instead of silently assuming a direct connection between the seller and the production site.

Consider what information is necessary to understand the source and relevant risks. Collect and share personal or commercially sensitive records proportionately, with access controls and an appropriate purpose.

Ask questions that affect the decision

A review should be capable of changing what happens next. If a concern is identified, define who investigates it, what further evidence is required and whether the transaction pauses.

Check whether the source is consistent across documents, how the counterparty establishes its authority and what action has been taken on reported concerns. The appropriate investigation depends on the transaction and its context.

Record investigations and decisions

Keep the concern, evidence, proposed response, decision-maker and outcome together. A signed policy is helpful, but it does not demonstrate what happened in an actual case.

Where improvement is possible and appropriate, specify the actions and review date. Where the evidence does not support proceeding, record that conclusion. Do not describe every unresolved concern as a minor administrative gap.

Treat third-party references accurately

A laboratory test, a title document, an inspection report and a sustainability assessment answer different questions. Do not combine them into a broad assurance claim that none of them supports.

Likewise, mentioning an international framework does not establish certification, membership or endorsement. Use the framework’s name only to explain its actual role in the process, and obtain specialist advice on claims that may have regulatory consequences.

Review a completed case

Ask someone outside the day-to-day transaction team to follow a completed case. Can they identify the initial concern, the evidence reviewed and the reason for the final decision? If not, improve the documentation or the process.

The reviewer should be able to identify who accepted the findings and why. Where the file does not support the recorded conclusion, reopen the issue and correct the decision record.

Keep the review current as counterparties, sources and transport arrangements change. Check the scope and date of a previous assessment before applying its findings to a later transaction. Refer matters outside the buying team’s competence to an appropriately qualified adviser.