ALEXANDRIA, Va., February 24, 2025 - The RMI is deeply concerned about the volatile situation in eastern DRC, use of violence, and loss of life and other severe impacts that continued escalation is having on civilians and communities. We are also concerned about the impact on local actors including business, government, and civil society partners who have supported responsible sourcing for two decades.
Given the M23/Alliance Fleuve Congo armed groups’ takeover of the mining regions of North and South Kivu, including mines and essential mineral trade routes in these provinces, and the credible reports of cross-border smuggling and fraud, it has become extremely challenging to responsibly source tin, tantalum, tungsten and gold (3TG) from eastern DRC and neighboring countries including Rwanda. The M23 as well as armed groups like the Wazalendo have been reported by the UN Group of Experts and others to be active in mineral areas and committing serious human rights abuses including sexual violence and other crimes.
The situation requires more vigilance than ever from buyers, downstream actors, the RMI and other due diligence systems. Our primary focus continues to be to oversee our robust assurance system for mineral processors (smelters, refiners), via the RMI’s Responsible Minerals Assurance Process (RMAP). Any processor sourcing from a high-risk area, including the African Great Lakes Region, must demonstrate to independent assessors they have met the RMAP standards, aligned with international standards of responsible sourcing management systems. Specifically, processors sourcing from high-risk areas must provide documentation and evidence of enhanced due diligence, including full chain of custody, know-your-counterparty information, and on-the-ground due diligence. Per RMAP requirements, smelters must not source any minerals that finance armed groups or perpetrators of serious human rights abuses.
There are parts of DRC unaffected by the conflict, with many livelihoods and communities still dependent on mining. Supply chain actors must seek detailed and specific information on their sources to monitor and address risks; disengagement should be based on due diligence as described in OECD Guidance on Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. However, given the extremely high risk of fraud and cross-border smuggling in eastern DRC and Rwanda, processors seeking to meet RMAP standards are required to obtain clear and convincing evidence to triangulate any claims on origin and trade. Among other sources, companies may wish to refer to the DRC Government’s recent alerts about illegal “red” mine sites (arrêté and list of sites) impacted by conflict, and frequently monitor for updates.
The RMI continues to monitor the situation and supply chain risks, in consultation with government, industry, and civil society experts, and we will update technical guidance to RMAP smelters and assessors, based on our standards and known risks. We also appreciate the ongoing work by local actors to monitor and alert the international responsible sourcing community about risks in this dynamic context.
To support our ongoing work to identify and address risks in our own work and programs, the RMI has a grievance mechanism. We invite any party with any specific information of concern about one of the following to submit a grievance:
- Facility participating in the RMAP program (as seen on the active and/or conformant list);
- Third-party assessor or audit firm that conducted an RMAP assessment;
- Cross-listed facility (as seen on the active and/or conformant list); or
- The Responsible Minerals Initiative organization (including operations, standards, tools, etc.)
For more information, please see the RMI grievance mechanism overview and submission form and grievance mechanism policy.
Background:
The RMI plays a key role in supporting companies’ due diligence and responsible sourcing of minerals by overseeing a robust assurance system for mineral processors (smelters, refiners) sourcing from high-risk areas, via the Responsible Minerals Assurance Process (RMAP). The RMI also offers tools to help companies identify sourcing risks and provides other supporting due diligence information on processors in their supply chain.
Many companies use the RMI’s conformant list as a baseline for due diligence. Individual companies also consider multiple factors and may have additional supplier requirements that are not in scope of an RMAP assessment. For additional guidance on leveraging RMI due diligence information, please see How to use RMI tools to support your due diligence: a guide for downstream companies.
The RMI monitors the ever-changing situations on the ground in mining regions and regularly updates guidance and measures within our own program and for members to prevent and mitigate risks of conflict financing and human rights abuses. These tools and guidance remain grounded in the RMI’s OECD Guidance-aligned standards, while being responsive to new risk information and the complex realities of global mineral supply chains.
As we shared last year when the conflict in eastern DRC escalated once again, the RMI has taken a multi-pronged approach to prevent and mitigate risks of conflict financing, illicit trade and human rights abuses. Our primary focus continues to be on overseeing a robust assurance system for mineral processors (smelters, refiners) sourcing from high-risk areas, via the Responsible Minerals Assurance Process (RMAP). In this respect, ongoing monitoring is crucial, as these assessments by nature are periodic, retrospective, and seek to assure conformance of a processor’s due diligence management systems rather than material certification.
In the last nine months, the RMI has led capacity building and technical assistance to improve processors’ risk management systems; issued specialized guidance and alerts to RMI members, processors, and RMAP’s third-party assessors; and contracted independent, third-party research and engaged experts in the region to obtain better on-the-ground insights. The results from our research and local engagement inform and reinforce ongoing and effective risk management measures, amidst significant uncertainty and volatility.
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