What are the OECD Annex II Risks?
There are risks of significant adverse impacts that may be associated with extracting, trading, handling and exporting minerals globally, and especially from conflict-affected and high-risk areas. The RMI prioritizes, in its standards and programming, risks highlighted in the OECD Due Diligence Guidance Annex II, commonly referred to as Annex II Risks, including risk of conflict, severe human rights abuses, money laundering and mineral fraud as described below. The RMI also recognizes a broader set of environmental, social and governance (ESG) risks and issues and is leading new efforts to address those risks. Read about the emerging risk areas the RMI is working on. Further information on the Annex II Risks can be found on the OECD website, in the OECD Due Diligence Guidance and in the additional simplified guide.
OECD Annex 2 Risks
| Risks can be broken down into three overarching criteria: Human Rights, Conflict, and Good Governance |
| Serious abuses associated with the extraction, transport or trade of minerals |
| Direct or indirect support to non-state armed groups |
| Public or private security forces |
| Bribery and fraudulent misrepresentation of the origin of minerals |
| Money laundering |
| Payment of taxes, fees and royalties due to governments |
5 Step Framework for Risk-Based Due Diligence
The OECD Due Diligence Guidance Third Edition (OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas) provides a globally accepted standard for supply chain due diligence. The Guidance recommends 5 steps for developing an effective internal management system to track and manage risks in your minerals supply chain. The RMI enables companies at every stage to identify risks in their supply chain and to implement this due diligence process with the tools we make freely available.
Please view this guide for an overview of how downstream companies can use the RMI's tools to conduct due diligence following the OECD 5 step process.
| OECD | Action Step | RMI Tools and Resources |
| STEP 1 | Establish Strong Company Management Systems | Due Diligence Guidance Documents Sample Policies (OECD DDG Annex II Model Policy) RMI Grievance Mechanism & Minerals Grievance Platform Letters of Commitment |
| STEP 2 | Identify and Assess Risks in the Supply Chain | Public confirmed smelters list (3TG & Cobalt) Data provision: Country of Origin and Risk Information Plausible Mineral Production Data (Available for RMI Members) Public Active/Conformant Smelter List |
| STEP 3 | Respond to and Manage Risks | Sample Supplier Letters (Available for RMI Members) Guidance on Risk Mitigation for Downstream: OFAC Guidance, Country-specific risk profiles Funding mechanism for on-the-ground projects (PPA, EPRM) Funding mechanism for upstream due diligence Single-Point-of-Contact Resources and Training (Available for RMI Members) |
| STEP 4 | Audit of Smelter and Refiner Due Diligence Practices | Responsible Minerals Assurance Process (3TG + Cobalt) Smelter Engagement Activities / Outreach Technical Assistance |
| STEP 5 | Publicly Report on Due Diligence Actions | Five Practical Steps for Conflict Minerals Due Diligence and SEC Disclosure Public Reporting Guidance: Partnership with GRI on Due Diligence Reporting Guidance RMAP Due Diligence Report Guidance Peer review of public reports Links to smelter & refiner public due diligence reports – sample reports |
