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Keeping you in-the-know on environmental, social and governance developments

Yesterday, the Responsible Minerals Initiative issued a notice that it will no longer recognize ITSCI as an acceptable upstream conflict minerals due diligence mechanism. In making this notice, RMI explained:

“RMAP [the Responsible Minerals Assurance Process] previously recognized ITSCI as an upstream mechanism that can support in part the RMAP auditee enhanced due diligence requirements in the African Great Lakes Region, where ITSCI operates. RMI based this recognition on a 2018 OECD alignment assessment of the ITSCI system, with a validity period of three years and a courtesy extension. Per the timeline in RMI’s draft upstream recognition process shared with ITSCI prior to publication, subsequently published and available on RMI’s website, and bilateral RMI-ITSCI communications since 2019, the initial recognition period for ITSCI has passed, without ITSCI’s affirmative response to the RMI’s invitations to reapply…

The RMI will provide RMAP auditees utilizing ITSCI a transition period to update their approach to meet RMAP enhanced due diligence requirements.

To support auditees’ continued responsible CAHRA sourcing and continuous improvement in due diligence through the ITSCI recognition status change, the RMI is offering a transitional approach.”

What This Means

This change won’t impact conflict minerals reporting for calendar year 2022 (which is to be filed May 31, 2023). RMI clarified that

“ITSCI’s status change will take effect for RMAP auditees utilizing ITSCI starting on January 1, 2023, with a six-month continual improvement grace period, per established RMAP process for programmatic changes… From July 1, 2023, if there is no change to ITSCI’s RMAP recognition status, auditees which use ITSCI and do not provide direct evidence of enhanced due diligence on the above four areas to an RMAP auditor will be cited as non-conformant, in line with RMAP standard requirements.”

Given there are only two months left in 2022, it doesn’t seem likely the status of ITSCI will be resolved prior to January 1, 2023, meaning that RMAP-audited smelters/refiners will face a choice of either allowing RMAP auditors access to their upstream due diligence processes and documentation, or change to an RMAP-recognized system (currently Better Mining and CRAFT). This also means that RMAP auditors may need additional training to better understand upstream due diligence processes and correction actions – which are many times complicated or don’t have a clear end-point.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile