The document provides guidance on reporting requirements under Step 5 of the OECD Due Diligence Guidance for responsible mineral supply chains. It outlines the key sections that should be included in public reports by companies at different points in the supply chain, including introductions, management systems, risk assessments, risk management, and annexes with supporting documents. Some sensitive commercial information can be kept confidential but must be shared with third party mechanisms. The gold supplement includes additional reporting expectations for risk identification, mapping of red flag operations, and monitoring of risk mitigation efforts. Examples of reports published by different companies are also listed.

1. Step 5 Reporting
in the Due Diligence
Guidance
7th Multi-stakeholder forum on
responsible mineral supply chains
27 May 2014 - Paris, France

2. Reporting in the Guidance
Step 5 of the OECD Due Diligence Guidance says:
Companies should publicly report on their supply chain due
diligence policies and practices
They may do so by integrating into their sustainability, corporate
social responsibility or annual reports to cover additional
information on mineral supply chain due diligence
 More detail on reporting expectations for upstream,
refiners/smelters and downstream in the 3T and Gold
supplements
 Slight differences in reporting expectations between the 3T
and Gold supplements
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3. Confidentiality and competitive
concerns
Annual public reporting is a clear expectation under Step 5
But concerns around confidentiality and competition between commercial entities mean
that not all information must be made public:
 3T: Price information and supplier relationships
 Gold: Price information; supplier identities and relationships (however the
identity of the refiner and the local exporter located in red flag locations should
always be disclosed except in cases of disengagement); transportation routes; and
the identity of information sources and whistle-blowers located in conflict-
affected and high-risk areas, where revealing the identity of such sources would
threaten their safety.
But all information should be disclosed to a third party, described as “any
institutionalised mechanism, regional or global, once in place with the mandate to collect
and process information on minerals from conflict-affected and high-risk areas”
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4. Upstream reporting

5. Report section 1
Introduction: The Company
This section should serve as an introduction to the company and its
activities so that the reader can understand the context of the following
sections on the company’s supply chain due diligence activities.
Suggested components of this section:
 Name of company that is being reported on, registration number, contact
details of due diligence manager
 Brief overview of company structure: sub-entities, joint ventures, holding
companies etc.
 Company’s activities, such as:
 location of operation (countries, provinces, areas)
 type of operation and licences/permits (mining company, mineral
trader, treatment unit, local exporter etc.)
 Reporting period and the scope of the report
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6. Report section 2:
Company management systems
Components of this section:
The below wording stems from the Due Diligence Guidance Supplement on Tin, Tantalum and
Tungsten, Step 5: Report Annually on Supply chain Due Diligence, Section A1:
 Set out your company’s supply chain due diligence policy
 Explain the management structure responsible for due diligence,
including who is directly responsible
 Describe your company’s control systems over the supply chain, how
the system operates and what data/information it has yielded
 Describe your company’s record keeping system and methods of
disclosing suppliers down to the mine of origin to downstream
actors
 Disclose information on payments made to governments in line with
EITI criteria and principles
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7. Report section 3:
Risk Assessment
Components of this section:
The below wording stems from the Due Diligence Guidance Supplement on Tin,
Tantalum and Tungsten, Step 5: Report Annually on Supply chain Due Diligence,
Section A1:
 Publish the risk assessment (with due regard to business
confidentiality and competitive concerns).
 Outline the methodology, practices and information yielded by the
on-the-ground assessment.
 Outline the methodology of your company’s supply chain risk
assessment
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8. Report section 4:
Risk management
Suggested components of this section:
The below wording stems from the Due Diligence Guidance Supplement on Tin,
Tantalum and Tungsten, Step 5: Report Annually on Supply chain Due Diligence,
Section A1:
 Describe the steps taken to manage risks, including a summary
report on the strategy for risk mitigation in the risk management
plan, capability training and – if any – involvement of affected
stakeholders.
 Describe your company’s efforts to monitor and track performance
of supply chain risk management.
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9. Report section 5:
Annex or Appendix
If the company wishes to provide supporting evidence or examples of key
policies, templates or risk assessments, it may wish to do so in an annex or
appendix to the main report.
Example section 5: Annex
Super Export company wishes to draw attention to a number of annexes to this
annual report on our supply chain due diligence policies and activities:
• Annex A: Conflict minerals policy (full text in French)
• Annex B: Supplier agreement, including due diligence requirement and
reference to conflict minerals policy.
• Annex C: Supplier Inspection template
• Annex D: Examples of supplier inspections carried out during the
reporting period: Site A, Site B, Site D and Site M
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10. Gold supplement ‘additions’ (1/2)
The following components are specific to the Gold Supplement:
Company management systems
 Describe your company’s record keeping system and methods of identifying all
suppliers down to the mine of origin and the methods for sharing information about
DD throughout the supply chain.
Risk Assessment
 Explain how your company identified red flag operations or red flags in their supply
chains, including the verification of supplier representations proportional to risk.
 Describe the red flags identified in the gold supply chain.
 Describe the steps taken to map the factual circumstances of those red flag operations
and red flagged supply chains.
 Outline the methodology, practices and information yielded by the on-the-ground
assessment team, including whether and how your company collaborated with other
upstream companies and how your company ensured that all joint work duly takes
into consideration circumstances specific to your individual company.
 Disclose the actual and potential risks identified; companies should not report risks
identified for potential suppliers with whom they have not done any business. 10

11. Gold supplement ‘additions’ (2/2)
Risk management
 Describe how your company’s internal control systems (such as chain of custody or
traceability systems) have been strengthened to collect and maintain reliable up-to-
date information on red flagged gold supply chains.
 Describe your company’s efforts to monitor and track performance of supply chain
risk management, including all instances and results of follow-up after 6 months to
evaluate significant and measurable improvement.
 Disclose the number of instances where the company has decided to disengage with
suppliers and/or supply chains, consistent with Annex II.
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12. Refiners / Smelters

13. Smelter and Refiner Reporting in the
Due Diligence Guidance
In addition to the upstream reporting requirements, smelters / refiners should:
3T Supplement (Step 5, Section A2):
Publish the audit reports of smelters/refiners with due regard taken of
business confidentiality and other competitive concerns.
Gold Supplement (Step 5, Section A2):
Publish the summary audit reports of refiners with due regard taken of
business confidentiality and other competitive or security concerns. The
summary audit report should include:
a) Refiner details and the date of the audit
b) The audit activities and methodology, as defined in Step 4(A)(4), where an
Industry Programme or Institutionalised Mechanism in conformance with
this Guidance and as defined in Step 4(B)(2) has not published these details
c) The audit conclusions, as defined in Step 4(A)(4), as they relate to each step
in this Guidance
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14. Downstream

15. Downstream Reporting in the Due
Diligence Guidance
Company management systems:
• Set out your company’s supply chain DD policy.
• Explain the management structure responsible for DD, including who is
directly responsible.
Risk assessment and management:
• Describe the steps taken by your company to identify smelters/refiners in
the supply chain and to assess their DD practices, including the published
list of qualified smelters/refiners through industry validation schemes
conforming to DD processes in this Guidance.
• Describe steps taken to manage risks.
Audit:
• Publish audit reports of their DD practices with due regard to business
confidentiality and other competitive concerns and responses to identified
risks.
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16. Gold supplement ‘additions’
The following components are specific to the Gold Supplement:
Management systems:
 Describe your company’s control systems over the gold supply chain, explaining how
this operates and how it has strengthened your company’s DD efforts in the reporting
period
 Describe your company’s database and record keeping system.
Risk assessment:
 Describe the assessment of their [refiners?] DD practices.
 Explain the methodology of your supply chain risk assessments.
 Disclose the actual or potential risks identified.
Risk management:
 Describe your company’s efforts to monitor and track performance of supply chain
risk management, including all instances and results of follow-up after 6 months to
evaluate significant and measurable improvement.
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17. Example reports*
Metachem Sprl
African Barrick
AngloGold Ashanti
Barrick
Gold Fields
IAMGOLD
Kinross
New Gold
Primero
Argor-Hereaus
New Boliden
Krastsvetmet
Hewlett Packard
Intel
GE
* The OECD makes no claims to the quality of the reports suggested above. These reports are
included only to give companies illustrations of their peers activities and approaches to reporting
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