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Sustainability // iTSCi

Conflict Mineral Frameworks

iTSCi's development has been in tandem with those of other programmes and initiatives through mutual cooperation, and aims to avoid unnecessary duplication and overlap of project activities. Most initiatives target different areas of the same issue but iTSCi explicitly focuses on the practical implementation of a chain of custody system (traceability) from mine to smelter, and is designed for use by private sector operators, with specific roles for government agents and ITSCi programme actors.

 The initiatives with which iTSCi has a level of integration with are summarised below:

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ('OECD DDG') provides "management recommendations endorsed by governments for global responsible supply chains of minerals in order for companies to respect human rights and avoid contributing to conflict through their mineral or metal purchasing decisions and practices." (OECD 2011a: 52) The OECD DDG has been developed by a multi-stakeholder working group encompassing engagement from the eleven countries of the International Conference of the Great Lakes Region (ICGLR), the UN, civil society, industry and other country governments. Representatives from other initiatives, such as iTSCi, BGR's Certified Trading Chains Scheme (CTC), the CFS and the ICGLR's Regional Certification Mechanism (RCM) have also participated. "The Due Diligence Guidance may be used by any company (upstream and downstream) potentially sourcing minerals or metals from conflict-affected and high-risk areas, and is intended to cultivate transparent, conflict-free supply chains and sustainable corporate engagement in the minerals sector" (OECD 2011a: 52). iTCSi has been designed to allow companies to demonstrate conformance with the OECD DDG from mine to smelter. iTSCi is taking part in the OECD DDG trials in DRC which started in June 2011. http://www.oecd.org

The International Conference for the Great Lakes Region ('ICGLR') was created in 2002 re-establish peace in the African Great lakes Region through an inter-governmental process as this region had been devastated by conflict for more than a decade. The ICGLR recognises the issue of illegal mining and trading in the GLR in its Protocol on the Fight against the Illegal Exploitation of Natural Resources. The Protocol outlines the actions Member States have agreed to take and establishes a committee against the illegal exploitation of natural resources. The Protocol's central tool is the Regional Initiative against the Illegal Exploitation of Natural Resources (RINR). The establishment of a Regional Certification Mechanism ('RCM') for selected minerals (gold, columbite-tantalite, cassiterite and wolframite) forms the core element of the Initiative. The RCM is not yet currently implemented and is under development , but it will eventually be integrated into national law of its member states. ITRI - on behalf of iTSCi - holds an MoU with the ICGLR which states that "both initiatives are based on a common objective of limiting the ability for armed groups to source financing from the production and trade of minerals in the Great Lakes Region, and wish to take advantage of the synergies between the two initiatives to seek harmonisation and develop cooperation in activities relating to the traceability and certification of conflict minerals in the Great Lakes Region. The MoU further states, that the iTSCi scheme is recognized as a scheme for traceability that is suitable for the use within the framework of the RCM. Within Tthe RCM ICGLR burden of proof falls primarily on exporters, secondly on Governments, is designed for implementation by government as the primary actors, which contrasts with iTSCi's focus on supply chain operators with support of government agents. http://www.icglr.org

The Certified Trading Chains Initiative (CTC) is jointly piloted in Rwanda by the Rwanda Geology and Mines Authority (OGMR) and the German Federal Institute for Geosciences and Natural Resources (BGR) since March 2009 . The CTC approach aims to improve "supply chain due diligence and good governance in the ASM". (BGR 2011: 2) CTC comprises "twenty certification standards on mineral origin and traceability, mining conditions, and supply chain due diligence elements based on OECD and other integrity instruments, adapted to practical applicability within the central African ASM". (BGR 2011:1) CTC in Rwanda covers the minerals cassiterite, wolframite, and columbite-tantalite. In addition to the CTC, BGR has also developed "a combination of analytical evaluation methods to independently track the origin of tantalum (coltan) ore concentrates produced in Central Africa. BGR has obtained encouraging results in advancing the development of a similar [analytical fingerprint] AFP scheme for tin ore (cassiterite) concentrates, and is planning to further extend the method to tungsten ore concentrates". (BGR 2011: 2) The CTC system also requires independent audits. (BGR 2011: 1) In December 2010 and in June 2011 the iTSCi auditor was able to join the CTC audits in order to further develop iTSCi's audit guidelines and to assess how the different traceability aspects might fit together. In DRC, CTC is implemented by the DRC Ministry of Mines with the support of BGR . In DRC, CTC's focus lays mainly on artisanally mined tin, tungsten, tantalum, and gold as well as the trade of these minerals in eastern DRC. Within this cooperation, certification manuals for the above minerals have been developed that also include a tagging process. (DRC, Ministére of Mines 2011b) Next steps are to "perform baseline audits at pilot mines" (BGR 2011: 1) participating in the project, and, "in cooperation with iTSCi, introduce a mineral traceability and tracking system". (BGR 2011: 1) http://www.bgr.bund.de

The Conflict-Free Smelter Assessment Programme (CFS), developed by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) in 2009, aims to allow downstream users to determine if any tin, tantalum, tungsten and gold was bought from conflict areas and if so if due diligence is performed. The CFS "is a voluntary program in which an independent third party evaluates a smelter's procurement activities and determines if the smelter demonstrated that all the materials they processed originated from conflict-free sources." (EICC/ GeSI 2011f: 4) CFS audits have been conducted for tantalum; the audit guides for gold, tin and tungsten are still under development. iTSCi offers mineral chain of custody information with the objective of meeting the requirements of the CFS . The CFS may rely on the iTSCi audit of the chain of custody and the smelter for conformance with the OECD DDG as the 'entry' point for smelters into the CFS system. www.eicc.info  and  www.gesi.org

The Dodd-Frank Act: On July 21st 2010, US President, Barack Obama, signed the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act") into Law. The Dodd-Frank-Act requires companies to disclose whether the columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives in any product originated in the DRC or any adjoining country and, if so, to report on due diligence undertaken on the chain of custody and provide further details if the products are not 'DRC conflict free'. The US Securities and Exchange Comission (SEC) published rules on 22nd Aug 2012 which govern how the law is to be applied. The first disclosures will be required by May 2014. iTSCi (together with the CFS) will allow downstream companies to purchase with confidence as participating (iTSCi and CFS) smelters will have upstream supply chains that conform with the OECD  DDG, meaning that operators have adequate risk assessment, mitigation and management systems in place and the minerals they process have been subject to appropriate due diligence measures. http://www.sec.gov/

Click HERE to access reports, presentations, press releases, letters, and other documents related to the iTSCi project.

All iTSCi staff and project partners welcome feedback and constructive comment on how the system can be improved. However, due to the condensed timescales for project implementation arising from the Dodd Frank law we do not have official consultation periods for soliciting input. If you do have suggestions please send directly to This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Concerns regarding any aspect of the project operation, including activities of member companies, can be sent in confidence to the iTSCi risk assessors, Channel Research This e-mail address is being protected from spambots. You need JavaScript enabled to view it