RMI and ITSCI engaged in a positive dialogue in the 1st week of December 2022, as they share the objective of responsible sourcing through the implementation of OECD due diligence for Conflict-affected areas and high-risk areas.OECD due diligence provides guidelines for companies to respect human rights and avoid contributing to any conflict through mineral purchasing decisions. Both these organizations will continue to hold this dialogue and communication with their members, auditees, and stakeholders.

So who is ITSCI

ITSCI is a private sector which aspires to establish responsible mineral supply chains that do not contribute to conflict, human right abuse and other risks. ITSCI currently focuses on monitoring tin, tantalum, and tungsten in the regions of Burundi, the Democratic Republic of Congo, Rwanda, and Uganda and collaborates with suppliers on the ground in high-risk areas and international supply chains. ITSCI has committed to OECD due diligence, for responsible business conduct and performs independent auditing of smelters/suppliers for companies who have affiliated themselves with the ITSCI programme.

Discussions between RMI and ITSCI centred around

● Recognition of ITSCI as an upstream system by RMI
● RMAP audit evidence requirements for smelters’ due diligence for conflict-affected and high-risk areas (CHARA) sourcing.
● ITSCI’s second alignment assessment

Reasons behind this discussion:

The Responsible Minerals Initiative (RMI) removed ITSCI from its approved program list by the end of October 2022 as their OCED’s Alignment assessment (AA) expired. RMI previously approved ITSCI in 2018 based on its OECD alignment assessment which was valid for a period of 3 years. This came as a surprise to ITSCI which could have very well contributed to the detailed discussion with RMI over the above-mentioned.

What this means for ITSCI (Independent auditor)

Smelters who have been approaching ITSCI to ensure that the minerals are conflict-free will now have to do additional due diligence to meet RMI standard requirements. ITSCI is concerned that this may also create a negative impact and companies may choose to extricate from their present 3TG initiative. ITSCI has continually insisted that its standards have not changed, and they have always been 100% aligned with OECD Due diligence and have been engaging with RMI over the last 2 years to discuss recognition and promptly responded to RMI regarding its invitation to reapply for recognition.

ITSCI has already initiated its second OCED alignment assessment and is committed to public reporting once the process is complete.

Lessons to learn

● Alignment assessment must be conducted at regular intervals by companies like ITSCI that choose to provide due diligence support to local smelters. Commitment to OECD due diligence does not mean that we would not be taken off RMI approved list.
● Those offering third-party due diligence services must often communicate regularly with institutions like RMI and their necessary stakeholders and auditees to bridge any understanding gap.