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Sustainability // iTSCi

iTSCi members’ public due diligence reports enable Global Witness review

Thursday, 12 October 2017

Global Witness recently released 'Time to Dig Deeper' in which they reviewed progress of annual company public reporting as recommended in Step 5 of the OECD Due Diligence Guidance here We were pleased to note that this referenced and relied on many public reports of 3T companies who are iTSCi members therefore highlighting the positive impact of an effective joint industry programme to support company due diligence - all except one report was on 3T minerals rather than gold, all 3T reports were from iTSCi members, and contrary to other established iTSCi countries, there were no reports on 3T from Uganda where iTSCi was not at the time implemented.

iTSCi was happy to cooperate with GW during their research, however, differences of opinion remain. These points are addressed in detail in the attached comments( here in english / ici en francais ) and our position on specific recommendations made by GW to iTSCi are as follows;

1. We do not accept that GW identified any significant examples of removal by iTSCi staff of non-sensitive information from any company reports published on our website. Of the numerous reports available, one example noted by GW surrounded non-conflict risks (in any case previously published a year earlier), and a document revised by a company at a later date than the original submission to us.

2. We do already follow-up on poor quality risk reporting by companies via a number of mechanisms that are more effective than considering public reports, this includes by evaluation of applicant companies, continual on-the-ground monitoring, and site audits. Reliance on annual public reports, which are issued some time after risks may have occurred, and containing information which is not independently verified, would be significantly less credible or effective.

3. Our membership process does highlight the involvement of politically exposed persons (PEPs) within any company's ownership or senior management as a higher risk in relation to OECD Annex II risks. However, they are not named, and we will not expand our evaluation to other issues that may arise from PEPs since those are not within the scope of the OECD guidance.

4. Member companies with legitimate business relationships may request information regarding company ownership and potential conflicts of interest but providing a widely accessible searchable database such as recommended by GW would not be appropriate for such personally and commercially sensitive information.

Throughout the report GW suggest that companies should publicly report specific risks in their supply chain, however, the OECD guidance for 3T minerals does not recommend publication of specific risks but methods, general risk assessments, and practices, and recognises that information identifying relationships between suppliers are confidential. Through participation in the iTSCi programme, companies are made aware of risks in much more detail and at an earlier date than could ever be achieved through evaluating unverified annual reports. Since iTSCi incident summaries are also made public, the parties responsible for risk mitigation and their performance can also be evaluated through public scrutiny without the need for repetitive inclusion in numerous company reports. We continue to believe that this is the most effective and efficient approach.