Development International e.V.

Minerals and metals

From the mine site to the filing

Tin, tantalum, tungsten and gold from conflict-affected regions; cobalt from the Congo; gold from artisanal mines across three continents. Since 2014 we have measured what the rules for responsible mineral sourcing require, whether companies meet them, and what changes at the mine.

Terrain: South Kivu, Democratic Republic of the Congo

Is due diligence effective?

Minerals that fund armed groups or organised crime bring extortion, forced and child labour and sexual violence with them. The OECD Due Diligence Guidance for Responsible Mineral Supply Chains (2011) is the international standard for keeping them out of products, and Dodd-Frank Section 1502 made that due diligence mandatory for US-listed companies. The EU Conflict Minerals Regulation followed in 2021, and from 18 August 2027 the EU Battery Regulation extends due diligence to cobalt, lithium, nickel and natural graphite.

We have followed that question through every stage: modelling what the US rule would cost before it was adopted, benchmarking every issuer’s filing once it was, designing the framework for monitoring the Guidance, and evaluating, at mine-site level, whether a decade of due diligence reduced violence. The Impact section of our homepage shows the cycle in one case.

Impact evaluation · For the OECD · 2023–25

A decade of the OECD Due Diligence Guidance in tin, tantalum and tungsten supply chains

Ten years after the Guidance was adopted, did it reduce conflict at mine sites? We combined difference-in-differences analysis of mine-level data with nine case studies, under independent peer review.

About the evaluation

61%
fewer violent incidents (estimated) at mine sites enrolled in the iTSCi due diligence programme
Commissioner
OECD
Team
9 researchers, international
Design
Quasi-experimental, mixed methods

Two due diligence programmes at the mine level

A company far down the supply chain cannot inspect a mine in South Kivu. In the Great Lakes region, two industry programmes do that work for tin, tantalum and tungsten: they monitor mine sites, trace minerals to the smelter or refiner, and report what goes wrong. Our evaluation for the OECD studied the first of them.

Independent non-profit, founded by industry · since 2010 · artisanal and small-scale mining

iTSCi

The International Tin Supply Chain Initiative is the largest due diligence programme for 3T minerals in the region. It works through four interventions.

  1. Continuous monitoring and traceabilityOngoing monitoring of mine sites; bagging and tagging of minerals from the mine to the smelter or refiner.
  2. Incident reportingA system for recording and following up on incidents, with a whistleblowing mechanism promoted in mining communities.
  3. Multi-stakeholder committeesLocal and provincial committees of cooperatives, miners, authorities, security forces and civil society, which review incidents and agree corrective action.
  4. Joint risk mitigationMitigation strategies carried jointly by mining operators, government, security forces and civil society.

What sets it apart Scale and local governance: government agents tag the minerals, and the committees are chaired by local authorities.

Our evaluation estimates the effect of the four together: an estimated 61% fewer violent incidents at enrolled mine sites. It cannot say which of the four drives the result. About the evaluation

Operated by SLR Consulting, formerly RCS Global · since 2018 · artisanal and industrial mining

Better Mining

Formerly the Better Sourcing Program, Better Mining covers 3T minerals and gold as well as cobalt and copper. Its cycle has four main elements.

  1. Daily data collection by smartphoneLocally recruited agents are deployed to the mine sites every day and record incidents and risks in a smartphone application.
  2. Digital traceabilityTags are scanned at each step from the pit to the smelter or refiner; each record is checked by an algorithm and reviewed by analysts.
  3. Risk analysisAnalysts turn single incidents into rated risks, by severity and likelihood, and share the data with smelters, refiners and buyers.
  4. Corrective action plansCorrective actions are assigned to cooperatives, authorities and security services on site; the programme monitors and reports their progress.

What sets it apart Technology-assisted data collection: site data arrives digitally each day, and the programme assigns corrective actions without carrying them out itself.

The programme reports 7,862 incidents registered and 1,795 corrective actions assigned, of which 1,421 are implemented or in progress. The impact estimate in our evaluation covers iTSCi only.

Sources: iTSCi theory of change (2023); Better Mining Impact Report 2022; SLR Consulting, Better Mining programme page (figures as published in October 2026).

Two standards for mining operations

A programme watches a supply chain; a standard describes what a responsible mine looks like. It gives a mining operation a ladder to climb, step by step, and a documented check of how far it has come. Buyers can then point to that result as evidence of their own due diligence and responsible procurement. Two standards set the reference, one for each scale of mining.

Industrial-scale mining · since 2018

IRMA

The Standard for Responsible Mining of the Initiative for Responsible Mining Assurance. Six sectors hold equal seats on its board: mining companies, purchasers, NGOs, affected communities, organised labour and investors.

Covers
Business integrity, social responsibility, environmental responsibility and planning for positive legacies
Check
Independent third-party audit of the mine site, with the audit report published
Ladder
Achievement levels from IRMA Transparency through IRMA 50 and 75 to IRMA 100

We are studying the impact of the IRMA Standard: what changes at mine sites that are audited against it. Under way, together with Mainlevel Consulting.

Artisanal and small-scale mining · since 2018

CRAFT

The Code of Risk-mitigation for artisanal and small-scale mining engaging in Formal Trade, an open-source code developed by the Alliance for Responsible Mining with RESOLVE. It covers gold, 3T minerals, cobalt and coloured gemstones.

Covers
A management system, the legitimacy of the operation and the risks named in Annex II of the OECD Guidance, then wider high risks
Check
CRAFT Reports verified by the producer group and its buyers; CRAFT is not a certification scheme, though schemes can build on it
Ladder
Five modules: pass or fail on the most serious risks first, measured progress on the others

We assessed ten CRAFT and OECD practices with gold cooperatives and buyers in Côte d’Ivoire. About the study

Sources: IRMA Standard for Responsible Mining, version 1.0 (2018); CRAFT Code, version 2.1 (2024).

Three lines of work

Governance · Responsible sourcing

Do companies do what the rules require?

Whole-market benchmarks of conflict minerals disclosure under Dodd-Frank and the OECD Guidance, from issuers down to smelters and refiners, and the uptake of the Guidance among 1,178 downstream companies.

Social · Child and forced labour

What happens to people at the mine?

Cobalt refiners’ due diligence on the worst forms of child labour, and the conflict, incident and case-study evidence behind the OECD impact evaluation.

Environment · Mining standards

Can mining be made safer and cleaner?

Incentives for artisanal gold miners and traders in Côte d’Ivoire, the terminal evaluation of planetGOLD, the global programme reducing mercury in artisanal gold mining, and the impact of the IRMA Standard at industrial mines.

The record

2026

DRC 3T due diligence impact evaluation: mine-level evidence dashboard

Interactive evidence from the OECD evaluation, from production trends to case studies of mine-site demilitarisation. Not yet released: publication awaits the OECD’s permission. Tool

2026

Impact of the IRMA Standard for Responsible Mining

What changes at industrial mine sites that are audited against the standard. With Mainlevel Consulting; under way. Evaluation

2026

planetGOLD: terminal evaluation for UNEP

Reducing mercury in artisanal and small-scale gold mining; fieldwork in the Philippines. Under way. Evaluation

2023–25

A decade of the OECD Due Diligence Guidance in 3T supply chains

Impact evaluation for the OECD: difference-in-differences on mine-level data and nine case studies. Enrolment in iTSCi was associated with an estimated 61% fewer violent incidents. Evaluation

2024–25

Incentive framework for artisanal gold miners and traders, Dabakala

Ten CRAFT and OECD practices assessed with gold cooperatives and buyers in Côte d’Ivoire, for Solidaridad. Evaluation

2024

Conflict minerals due diligence in the telecommunications industry

Twelve US issuers: five had ever filed a Form SD, two met SEC requirements and aligned with the OECD standard. Study

2023

Influence of the OECD Due Diligence Guidance in minerals supply chains

1,178 downstream companies in eight countries; 82.8% make no reference to conflict minerals. Study

2021

Monitoring and evaluation framework for the OECD minerals Guidance

Authored with the Canadian NGO IMPACT for the OECD Centre for Responsible Business Conduct; the basis of the impact evaluation. Framework

2019

Worst forms of child labour in the DRC: cobalt refiner due diligence reporting

Refiners’ disclosures against the OECD and CCCMC guidance. Benchmark

2018

3TG and cobalt smelter and refiner disclosure conformance

370 smelters and refiners against leading assurance standards and Step 5 of the OECD Guidance. Benchmark

2018

Filing status, reporting year 2017

A 16.8% drop in conflict minerals disclosures between reporting years 2013 and 2017. Benchmark

2017

Letter to the Acting Chairman of the SEC

DI’s response to the SEC’s request for comments on the conflict minerals rule. Evidence to a regulator

2014–16

Dodd-Frank Section 1502 filing evaluations

Every US-listed issuer’s conflict minerals filing for three reporting years, 1,153 to 1,271 companies a year, with raw data and scorecards published. Benchmark

2014–15

Issuer and supply chain surveys

The actual cost of Section 1502 to issuers, and how conflict minerals programmes are implemented along 3TG supply chains. Survey

2011

Cost model of Dodd-Frank Section 1502 compliance

Submitted to the SEC during the rulemaking and largely reflected in its Final Rule. DI associates

Companies that filed a conflict minerals disclosure for reporting years 2014 to 2016 can order their individual scorecard.

Where the research took place

Democratic Republic of the Congo3T mine sites, South Kivu and beyond; cobalt refiners
Côte d’IvoireArtisanal gold, Dabakala
PhilippinesplanetGOLD field research
United States and eight downstream marketsIssuer filings and company disclosures

Research partners in the region include the Université Catholique de Bukavu and ESPC Kinshasa.

Photograph of an artisanal open-pit mine in North Kivu, DRC, with miners working the terraces

Working on minerals?

Whether you set the rules, run a programme at the mine, or source the metal, we can tell you what the evidence shows and design the study that answers your question.

Partners Contact us