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.
Three lines of work
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.
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.
Can artisanal mining be made safer and cleaner?
Incentives for artisanal gold miners and traders in Côte d’Ivoire, and the terminal evaluation of planetGOLD, the global programme reducing mercury in artisanal gold mining.
The record
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. Awaiting release. Tool
planetGOLD: terminal evaluation for UNEP
Reducing mercury in artisanal and small-scale gold mining; fieldwork in the Philippines. Under way. Evaluation
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
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
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
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. Benchmark
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
Worst forms of child labour in the DRC: cobalt refiner due diligence reporting
Refiners’ disclosures against the OECD and CCCMC guidance. Benchmark
3TG and cobalt smelter and refiner disclosure conformance
370 smelters and refiners against leading assurance standards and Step 5 of the OECD Guidance. Benchmark
Filing status, reporting year 2017
A 16.8% drop in conflict minerals disclosures between reporting years 2013 and 2017. Benchmark
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
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
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
Cost model of Dodd-Frank Section 1502 compliance
Submitted to the SEC during the rulemaking and largely reflected in its Final Rule. DI associates
Scorecards for individual companies are available on our industry page.
Where the research took place
Research partners in the region include the Université Catholique de Bukavu and ESPC Kinshasa.
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.