Responsible Minerals Due Diligence and Supply Chain Management Guidance｜Startrust

From supplier questionnaires to risk-based due diligence, establishing traceable and improveable mineral supply chain management

Responsible mineral management does not end when the CMRT or EMRT is sent out every year and the response rates are compiled. Companies need to first confirm which minerals, suppliers and procurement projects used in products have higher risks, then identify smelters, refineries or processing facilities along the supply chain, assess origin, human rights, conflict, corruption and other major risks, and take reasonable and traceable improvement measures for gaps.

For supply chains related to electronics, automobiles, aerospace, machinery, batteries, energy and metals, customers often request 3TG, cobalt, natural mica, lithium, nickel, natural graphite, copper or other priority mineral materials. If a company only relies on spreadsheets and manual collections, it is prone to problems such as wrong versions, duplicate facilities, unrecognizable names, inconsistent scopes, and untraceable results over the years.

Startrust assists companies to use the OECD mineral supply chain five-step due diligence framework as the main axis, integrate RMI’s current official CMRT, EMRT and AMRT templates to establish policies, organizational responsibilities, supplier classification, investigation, data verification, risk assessment, corrective actions, management reporting and open communication processes.

Confirm product, material, mineral and supplier investigation scope
Establish CMRT, EMRT, AMRT versions and reply quality management
Clean and identify smelting, refining and processing facility information
Assess risks based on sources, facilities, suppliers and governance capabilities
Establish high-risk response, improvement tracking, escalation and notification mechanisms
Transform the annual questionnaire into a sustainable due diligence system

Reservation consultation

Why do companies need responsible mineral due diligence?

Customer requirements have extended from 3TG to more critical minerals

Traditional conflict mineral investigations mostly focus on tin, tantalum, tungsten and gold, also known as 3TG. As battery, energy transition, critical raw material and human rights due diligence requirements evolve, companies may also be required to collect cobalt, lithium, nickel, natural graphite, natural mica, copper or other mineral data.

Mineral supply chains may involve severe negative shocks

Mineral mining, transport, trading and processing can involve financing of armed groups, serious human rights abuses, forced labour, child labour, bribery, money laundering, environmental damage and community conflict. Enterprises need to conduct risk-based due diligence to identify and deal with the negative impacts that may be caused, contributed to or directly linked to their own procurement.

Regulations and market requirements do not only apply to mining sites

The OECD guidance applies to companies at different points in the mineral supply chain. Even if downstream manufacturers do not purchase directly from mines, they may still face customer contracts, industry regulations, listing disclosures, product regulations or group policy requirements.

Questionnaire responses need to be converted into usable risk information

The fact that the supplier returns the form does not mean that the information is correct. Companies still need to confirm the declaration scope, version, mineral applicability, facility name, identification code, country and response logic to determine whether there are unknown sources, unidentified facilities or high-risk warnings.

Failure to establish a process will result in annual rework

If the supplier list, contact window, product scope, facility master file and improvement records over the years are scattered in personal files, they need to be reorganized every year, and it is difficult to explain the investigation boundaries, tracking methods and risk treatment results to customers.

What is Responsible Minerals Due Diligence?

Responsible Minerals Due Diligence is an ongoing, proactive and risk-based management process. Enterprises need to establish policies and management systems, identify supply chain risks, design and implement risk responses, use appropriate independent assessment information, and explain due diligence methods and results to the outside world.

“Conflict-free” does not mean complete responsible procurement

Only confirming that minerals do not come from a specific country or region may ignore other conflict-affected and high-risk areas, and may also ignore risks such as forced labor, serious human rights violations, corruption and financial crimes. Enterprises should confirm the scope of application based on products, markets, minerals and supply chain locations.

Due diligence is not a one-time supplier screening

Sources, facilities, regional risks, suppliers and product mix continue to change. Enterprises need to regularly update information, re-evaluate new warning signals, and keep records of decisions, improvements, and upgrades.

Risk orientation does not mean requiring all suppliers to answer all minerals

By first confirming which products or materials may contain specific minerals, and then grading them based on purchase amount, product importance, origin, supply chain complexity and information gaps, resources can be concentrated on high-risk suppliers and unnecessary burden of questionnaires can be avoided.

How to implement the five steps of OECD mineral supply chain?

Step 1: Establish a complete enterprise management system

Formulate a responsible mineral policy, clearly define minerals, supply chain and risk scope, and establish high-level responsibilities, cross-departmental division of labor, supplier terms, appeal channels, document retention and internal supervision mechanisms.

Step 2: Identify and assess supply chain risks

Inventory minerals in products and materials, identify facilities and possible sources through supplier information and mineral report templates, and then assess risks based on conflict-affected and high-risk areas, facility status, data integrity, and supplier management capabilities.

Step 3: Design and implement a risk response strategy

In cases of high risk or insufficient information, we may decide to continue cooperation and improve, suspend transactions, or terminate the relationship after reasonable efforts are ineffective. Risk responses need to consider the company’s influence, severity of impact, and possible consequences of responsible exit.

Step 4: Leverage independent assessments of key supply chain nodes

Downstream companies can often use trusted industry assessment programs and publicly available facility information to understand the due diligence status of a smelting, refining or processing facility. However, using program information will not replace the company’s own scoping, data verification, and risk decisions.

Step 5: Publicly report supply chain due diligence

Describe policies, scope, methods, identified risks, handling measures and continuous improvement in accordance with applicable regulations, customer and stakeholder needs. Reporting should avoid revealing trade secrets or creating risks, but still provide sufficient transparency.

What are the differences between CMRT, EMRT and AMRT?

Template	Main mineral range	Common uses
CMRT	Tin, Tantalum, Tungsten, Gold (3TG)	Collect source country and smelting/refining facility information to support conflict mineral regulations and customer requirements
EMRT	Cobalt, copper, natural graphite, lithium, natural mica, nickel	Collect sources, processing facilities and due diligence information of extended minerals
AMRT	User-selected priority minerals not covered by CMRT or EMRT	Conduct risk-based supply chain surveys of other minerals

RMI will update the template, facility reference list and filling instructions. Enterprises should confirm the current official version, mineral scope and transfer arrangements at the start of each investigation cycle. It is not appropriate to use files with unknown origins or that have been modified.

The template is an information exchange tool, not the entirety of due diligence.

CMRT, EMRT and AMRT can improve the efficiency of supply chain data exchange, but they cannot replace the company’s mineral suitability determination, supplier risk classification, anomaly verification, facility assessment, corrective actions and public reporting.

Company-level and product-level declarations need to be clearly distinguished

Customers may request company-level, product-level, or custom scope responses. Companies need to confirm which products, material numbers, locations, periods and suppliers are covered by the questionnaire to avoid mistaking the company-wide list for specific product answers.

Which companies are suitable for establishing systems first?

Electronics, semiconductors, information communications and electrical equipment supply chain
Automotive, aerospace, machinery, metal and industrial equipment manufacturers
Battery, energy storage, renewable energy and new energy vehicle related companies
Suppliers of jewellery, precious metals, materials, chemicals and components
Companies required by international clients to submit CMRT, EMRT or other mineral surveys
Companies whose products contain multiple metals but lack comparative information on materials and minerals
Enterprises with many levels of suppliers, cross-border procurement or insufficient source transparency
Enterprises that need to integrate the survey results of groups, factories or multiple business units

Small and medium-sized enterprises can first establish the first round of processes based on major customer requirements and high-risk product lines, and then gradually expand the scope of other minerals and suppliers.

What information do I need to prepare?

Product, material and mineral applicability

Include product list, bill of materials, material specifications, metal or chemical composition, supplier part number and mineral use. This information is used to determine which suppliers should be included in which template.

Suppliers and purchasing information

Including supplier master file, contact window, purchase category, amount, country, manufacturing location, customer correspondence and replies over the years. Supplier names and codes need to be unified to avoid repeated collections and tracking breaks.

Mineral Report Template

Includes CMRT, EMRT, AMRT, declaration, facility list and supplementary evidence submitted by the supplier. The version, receipt date, declaration scope, validity period and verification results need to be retained.

Facility and source information

Includes smelter, refinery or processing facility name, identification number, country, mineral, status and origin information. Names need to be standardized and compared, and cannot be judged solely based on text similarity.

Risk and Improvement Record

Includes risk rules, alerts, supplier communications, improvement requirements, deadlines, substantiation, escalation decisions and closure approvals to illustrate how the company takes action on data gaps and high risks.

Common responsible mineral management issues in enterprises

Only pursues response rate, without checking content

Vendors may have responded, but they may have used the wrong version, filled in the wrong scope, were missing required fields, listed unidentified facilities, or had inconsistent answers. Without quality control, response rates cannot represent data availability.

Send the same questionnaire to all suppliers

Failure to first confirm whether a product contains relevant minerals will not only increase the burden on suppliers, but will also generate a large number of “not applicable” and low-quality responses, diluting the real risks that need to be managed.

Having a facility on the list equates to low risk

The fact that a facility is identified, has an identifier, or appears on a reference list does not necessarily mean that a specific assessment has been completed. Companies need to confirm official status, validity period, minerals and assessment scope.

Data is scattered and lacks version management

Business, procurement, quality assurance, and sustainability teams store customer and supplier forms separately, making it easy to use different versions, respond repeatedly, or provide inconsistent results to the same customer.

No action taken on unknown or high-risk items

“Unknown”, unidentified facilities or high-risk sources in the questionnaire were not turned into improvement cases, and the same gaps continued to appear again the next year.

Directly require suppliers to exit high-risk areas

Responsible mining due diligence does not involve a blanket withdrawal from high-risk areas. Enterprises should take proportionate measures based on the severity of the risk, the possibility of improvement, and their own influence to avoid other negative impacts caused by irresponsible exit.

There is no common ground between customer responses and internal data.

Different business windows use different investigation periods, product scopes and facility lists, resulting in conflicting customer responses and increasing the risk of claims.

How does Startrust help companies establish responsible mineral systems?

1. Applicable requirements and scope inventory

Confirm customer, regulatory, product, mineral, site and reporting needs, establish company and product level ranges, and identify priority supply chains.

2. Policy, governance and responsibility design

Establish responsible minerals policies, cross-department RACI, supplier requirements, grievances and notifications, document retention and management oversight methods.

3. Compare products, materials and suppliers

Associate products, material numbers, materials, minerals and suppliers, and set investigation objects and templates based on applicability, risk and importance.

4. Questionnaire sending and quality inspection

Design investigation batches, response deadlines, collections, version control and automatic verification rules, and identify gaps, contradictions, unofficial files and reporting scope issues.

5. Facility Cleanup and Risk Assessment

Standardized facility names and identification information are compared with official current data and graded based on origin, facility status, data completeness and supplier capabilities.

6. Improvement, upgrade and decision-making

Establish corrective actions for high-risk, unknown and low-quality responses and track supplier replacement parts, alternative sources, management escalations and necessary purchasing decisions.

7. Customer responses and public reporting

Produce customer forms, policy statements, management summaries and due diligence instructions based on the approved scope to ensure that the same data base is used.

8. Annual update and capability transfer

Establish template updates, supplier changes, new products, risk information and management review cycles, and enable the team to maintain their own operations through education and training.

Coaching content and deliverables

The actual delivery project is confirmed based on the number of minerals, products, suppliers, data maturity and customer requirements. Common results include:

Analysis of applicability of responsible minerals, customer requirements and system gaps
OECD five-step comparison, governance structure and implementation roadmap
Responsible mineral policies, supplier guidelines and contract clause recommendations
Product, material, mineral and supplier range comparison table
Supplier classification, investigation batches, collection and upgrade rules
CMRT/EMRT/AMRT Version and Reply Quality Checklist
Facility name cleaning, identification, status and exception inventory
Source, facility, supplier and data quality risk scoring methods
Corrective actions and tracking records for high risks and data gaps
Customer responses, management reports and public disclosure drafts
Annual operating procedures, RACI responsibility matrix and document retention rules
Cross-department and supplier education and training materials
System fields, data processes and management dashboard requirements

This service assists enterprises in establishing due diligence and information management capabilities; customer acceptance, regulatory determination, industrial plan evaluation and facility approval results are still determined by the corresponding customer, the competent authority or the planning unit in accordance with the current rules.

What can companies get after importing?

Switch from manual reminder to risk-oriented management

Companies can allocate survey and improvement resources based on product, mineral and supplier risk, rather than just tracking total response rates.

Convert from distributed files to a single data base

Suppliers, versions, facilities, minerals, customer scope and historical records are centrally managed to reduce duplication and inconsistency.

From unknown projects to trackable improvements

Each unknown source, unidentified facility and high-risk project has a responsible person, deadline, communication and decision-making record.

Move from passive responses to proactive due diligence

Companies can explain their policies, methods, risks and actions to improve their readiness for customer audits, assessments and public disclosures.

Convert from annual project to ongoing system

New products, new suppliers, template updates and external risk changes can be entered into a fixed process to avoid starting over every year.

Why choose Startrust?

Understand due diligence and information operations at the same time

We not only explain the OECD structure, but also help companies deal with actual products, suppliers, templates, facilities and improvement information.

Tandem procurement, quality assurance, business and sustainability

Responsible mining involves multiple sectors. We help define common scope, responsibilities, audits and customer response lines.

Focus on risk rather than form volume

Through applicability and risk classification, we can reduce ineffective investigations and focus resources on major supply chains and warnings.

Establish traceable versions and evidence

From the supplier’s original response to facility determination, risk score and improvement case closure, source and approval records are kept.

Can connect suppliers and responsible minerals system

When the number of suppliers and forms increases, the burden of manual compilation can be further reduced through the responsible mineral management module and supplier management module.

FAQ

Do CMRT, EMRT and AMRT need to be issued to all suppliers?

unnecessary. Enterprises should first determine whether the products or materials provided by suppliers may contain relevant minerals, and then select templates based on customer, regulatory and risk requirements. Sending all questionnaires to all suppliers often increases the burden and reduces the quality of responses.

Does a supplier’s response of “unknown” mean that it is unqualified?

Not necessarily, but unknown representatives need to understand the causes and risks. Enterprises can require suppliers to submit investigation plans, estimated completion time and alternative evidence, and determine follow-up measures based on product importance, source and improvement progress.

Does obtaining 100% supplier response mean due diligence is completed?

no. Questionnaire scope, version, completeness, logic, facilities and source information still need to be checked and action taken on high risks or data gaps. Response rate is just one process indicator.

Is it enough to use only RMAP-assessed facilities?

Using trusted assessment information can help reduce risks, but companies still need to confirm product and supply chain scope, data quality, facility assessment status and their own risk responses. Industrial solutions cannot replace a company’s due diligence responsibilities.

Can I start without a bill of materials or material composition information?

You can first establish a preliminary comparison from the main products, procurement categories, material specifications and customer requirements, mark items with insufficient information, and then gradually strengthen it with R&D, quality assurance, procurement and suppliers.

Does Responsible Minerals only process 3TG from the Democratic Republic of the Congo and neighboring countries?

no. Specific regulations may have clear geographical and mineral scope, but OECD risk-oriented due diligence covers global conflict-affected and high-risk areas and various mineral supply chains. Companies should identify regulatory, customer and voluntary commitments separately.

Do all high-risk suppliers need to be terminated immediately?

uncertain. Enterprises should design responses proportionate to the nature and severity of risks, suppliers’ ability to improve, and their own influence. Serious risks may require suspension or termination of the relationship, but responsible exit and stakeholder impacts should also be assessed.

Do I need to update the questionnaire every year?

The frequency of investigations should be set based on customers, projects, supplier changes and risks. The RMI template and facility information will be updated. Enterprises should confirm the current official version before starting the investigation cycle, and strengthen updates for major changes and high-risk suppliers.

If a business is facing a customer mineral investigation, confusing supplier responses, or high-risk facility improvement needs, Startrust can assist in taking stock of scope and establishing a first-round due diligence baseline.