Responsible mining practices and sourcing from conflict-affected areas.

Conflict Minerals

Responsible mining practices and sourcing from conflict-affected areas.

Conflict minerals have been a core specialization of ELL since we began working on coltan and diamonds in the Democratic Republic of Congo (DRC) and Sierra Leone in 2003. ELL understands clearly the difference between meeting legal obligations and achieving a law’s intent. Amid all the discussion of Dodd-Frank Act Section 1502, pending EU regulations, and other legislative developments, ELL is uniquely positioned to understand both the complex realities of miners, traders, and communities upstream and the compliance needs and limitations of companies downstream.

Our definition and approach to conflict minerals goes beyond the 3TG (tin, tantalum, tungsten, gold) sourced from DRC. We recognize that there are other geographies and minerals linked to conflict that need to be addressed. We engage with our clients to understand the root causes and consequences of conflict in a given area and examine options for mitigating risk and/or developing best practice systems and sourcing. We leverage industry initiatives, guidelines, standards and certifications where appropriate to build customised solutions. Whether you simply wish to comply with your legal obligations or deliver real development impact in conflict-affected mineral sectors, ELL can help.

We have helped design, improve and document the actual standards and systems intended to prevent tin, tantalum, tungsten, gold, and diamonds being used to finance armed groups and support conflict and human rights violations in conflict-affected and high-risk areas. We intimately understand the scope and applicability of each, as well as the differences between them, and so can advise on which responsible sourcing initiatives are best suited for your business and reporting obligations and support you in building them into your existing sourcing practices. We also offer off-the-shelf and customized training on conflict minerals to clients and their suppliers.
Our work includes advising on improvements to auditing and certification systems as well as assessing impact. Through research, analysis, and innovation, we have given strategic advice to (and on) the following initiatives:

  • Fairtrade Gold
  • Fairmined Gold
  • Better Gold Initiative
  • ¬†iTSCi
  • Conflict-free Smelter Program
  • Certified Trading Chains (previously BGR)
  • ICGLR’s Regional Certification Mechanism
  • OECD on the Due Diligence Guidance for Minerals from Conflict-affected and High-Risk Areas
  • Responsible Jewellery Council’s Code of Practices and Chain of Custody Standard
  • Kimberley Process

We have supported the above initiatives ensure alignment with the following systems:

  • Dodd-Frank Act, Section 1502
  • World Gold Council’s Conflict-free Gold Standard
  • the London Bullion Market Association’s Responsible Gold Guidance
  • the Dubai Multi Commodities Council’s Responsible Sourcing Guidance

For the downstream segment (jewellery, electronics, automotive) we help clients identify and prepare for issues, before they are commonly known, whilst driving for change towards more sustainable systems within their sphere of influence. For example, we support organisations in their due diligence of conflict minerals supply chains, either to ensure their compliance with the major conflict minerals guidance, standards and legislation (e.g. the OECD Due Diligence Guidance, Dodd-Frank Act) or to go beyond compliance to achieve broader sustainability and international development goals.

For the upstream segment (mining, trading, transport and refining) we provide risk assessment and due diligence services as well as design customized management systems. We also train staff, suppliers and service providers on implementation and design post-audit corrective action plans along the supply chain.

To learn more about our conflict minerals work with Bureau Veritas, please see the partners page.