Consumers & Conflict Minerals

Last updated: February 2016

Products Fuelling Conflict around the World 


One of the biggest campaigning issues in the electronics industry over the past five years has been ‘conflict minerals’. This is a term coined for the minerals – tin, tungsten, tantalum and gold – that originate from the Democratic Republic of Congo (DRC) and surrounding countries, which have generated income used to help fund wars and armed militia.

imagr of conflict minerals


The Responsible Sourcing Network

Since 2013, companies which are publicly listed in the US have to submit annual reports disclosing their use of conflict minerals.

The US-based Responsible Sourcing Network – a project of the nonprofit organisation As You Sow – analysed the conflict minerals filings of 155 companies. Their reports showed how many different industries are affected by the ruling – the electronics, textile, automobile, pharmaceutical, and the oil and gas markets to name a few.

The results showed that only a handful of companies were close to sourcing 100% conflict-free tantalum from the DRC, and that Intel was the sole company with a conflict-free product line. Philips along with Intel was rated as one of the best performing companies on the issue of conflict minerals.

One of their findings was that companies were willing to assess their supply chains but were less good at responding to risks which they had identified by building capacity with suppliers or with smelters or refiners (SORs). Ideally companies should support collective initiatives such as the ITRI Tin Supply Chain Initiative which was established to create traceability programmes for tin being mined in the DRC.



Coltan mine, North Kivu, Democratic Republic of Congo 



The Conflict-Free Smelter Program


The Conflict-Free Smelter Program (CFSP) is an initiative set up by the Conflict-Free Sourcing Initiative (CFSI) which was founded by members of the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) – a collaboration between Information and Communication Technology companies. The CFSI helps members address the issue of conflict minerals within their supply chains.

Smelters and refiners (referred to as SORs) have been identified as the choke point within the conflict minerals supply chain. As the Responsible Sourcing Network explains “a focus on SORs helps trace minerals to mine, and country of origin. This is almost impossible to do through the maze of suppliers, suppliers’ suppliers, and suppliers’ suppliers’ suppliers. The most realistic, effective approach to trace minerals to the mine is to have SOR facilities engage in robust due diligence. To verify this, the OECD guidance calls for third-party audits, including through a collaborative scheme like the CFSI, as well as capability building. SORs thus strengthen their position as ‘choke-points’ that ensure conflict-affected minerals do not enter the supply chain.”

The project has been very successful in certifying over 250 SORs, covering all four minerals, around the world as being conflict free.



The Tin Supply Chain Initiative

ITRI Tin Supply Chain Initiative (iTSCi) is an initiative of the International Tin Research Institute and was developed in 2010.

It aims to meet the needs of companies wishing to maintain trade with responsible supply-chain actors in the DRC and adjoining countries, as well as to meet due diligence expectations of the international community in terms of guidance from the UN, OECD and national laws such as the Dodd-Frank Act in the US.

Through its programme, it provides supply chain information and transparency that encourages continued sourcing by product manufacturers, continued access to international markets, and economic and social development for miners in developing regions. Minerals traded by members of iTSCi are received by smelters participating in the CFSP.

According to its website it operates around 1000 mine sites in Burundi, Rwanda and the DRC, working with over 80,000 miners. 

The iTSCi remains one of the only traceability and due diligence programmes operating regionally across central Africa, covering extensive numbers of mining areas, assisting vast numbers of individuals, and continually expanding that coverage as resources, security and other circumstances allow.

While resolving issues around the potential link between conflict and minerals is its primary focus, once the responsible supply chain has been established, it also plans to address wider issues of importance to society, development and governance.

Current associate members include Blackberry, Boeing, Motorola, Apple, Intel and Microsoft.



European Regulations Too?

In May 2015 the European Parliament voted to accept a proposal for ‘EU Supply-Chain Due Diligence standards’ which would force companies operating in Europe to address the issue of conflict minerals.

These standards are based on the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidelines recommendations, which are designed to help companies respect human rights and avoid contributing to conflict through their mineral purchases from conflict-affected and high-risk areas. The same guidelines have been used as the basis for the US reporting requirements on conflict minerals within the Dodd-Frank Act.

Encouragingly, the proposed EU regulations are not just to be restricted to the conflict-prone region of the DRC and the surrounding countries. The draft law defines “conflict-affected and high-risk areas” as those in a state of armed conflict, with widespread violence, the collapse of civil infrastructure, fragile post-conflict areas and areas of weak or non-existent governance and security, characterised by “widespread and systematic violations of human rights”.

The next steps will see the European Parliament enter into negotiations with the European Commission to come to an agreement on the final text of the law.

UK based not-for-profit organisation Global Witness is one of the leading campaign groups in this area. With its coalition partners it is calling for member states to support:

  • A strong and binding law that requires all companies bringing minerals into the EU – whether in their raw form or in products – to carry out checks on supply chains to identify and manage risks, and publicly report on those risks in line with international standards.
  • Other development and good governance measures that promote responsible sourcing from conflict-affected and high-risk areas, and address development challenges linked to implementation of the law, such as challenges faced by artisanal miners and their families.
  • A law that allows other natural resources linked to conflict and human rights abuses – such as diamonds, jade and coal – to be added in the future.



Protest calling on Apple to remove conflict minerals from its supply chain



What impact is all this having?

Since 2013, companies which are publicly listed in the US have to submit annual reports disclosing their use of conflict minerals.

Carly Oboth from Global Witness states:

“The Dodd-Frank Act has had a big impact in the way companies view their supply chains. However, there is still work to be done with the way in which companies address the issue as many have failed to publicly demonstrate how they have put proper checks in place to identify and mitigate risks along their supply chains, as required by the conflict minerals law”.

The law has also impacted on the minerals trade. According to campaign group Enough, as of June 2015 over half of the world’s smelters and 141 mines in eastern Congo were certified conflict-free.[2]


The issue in the DRC is complex and it was never imagined that transparency initiatives on their own would end the war. As Amnesty reported in 2015, “armed groups remained active in North Kivu, Katanga, South Kivu and Ituri, committing serious human rights abuses against civilians”[3] and some companies have used the law as an excuse to embargo sourcing minerals from the country.

Nevertheless, the Dodd-Frank Act has led to more scrutiny within the country which in turn has led to many companies returning to the area. 

Oboth states that for companies:

“This is an ongoing process of supply chain checks and it is about companies being transparent about the issues found within their supply chains and how they are addressing those risks.”


As the Dodd-Frank Act Section 1502 enters into its third year of reporting, other areas of the world are considering legislation on the issue. Not only has the EU started the process; but China, in December 2015 also launched guidelines for Chinese companies to identify and mitigate the risks of contributing to conflict, serious human rights abuses and misconduct around the world.[4]



The commodity crisis driving the 3T industry away from responsible production


In December 2015, an open letter by senior figures from the African Great Lakes Region, international associations and more than 200 companies called for greater financial support for traceability and due diligence programmes in the 3T metals (tantalum, tin, tungsten) industry.

Over the past year the price of 3T metals had fallen between 30-60%. The letter stated that “urgent financial assistance from donors” and manufacturing companies was required “to share the ‘conflict mineral’ related costs across the supply chain.” 

The ITRI said:

“The (3T) mineral sector in the Great Lakes Region, which through concerted international and national effort has made significant progress towards becoming ‘conflict free’ over the last five years, is at risk of reverting back towards informality due to the steep fall in metal prices throughout 2015 following on weakness in business resulting from Dodd-Frank and de facto embargo over several years”.

Abandoning due diligence in order to secure survival and to compete with production areas outside the region, which do not face the same traceability and due diligence costs, will leave the local mining industry more vulnerable to exploitation by armed groups and raise the likelihood of ‘conflict related minerals’ finding their way into the supply chain.

Speaking about the letter’s publication John Kanyoni, Vice President of the Chamber of Mines of the business federation of the DRC (FEC), said:

“The great lakes region, and particularly the DRC, is at a crossroads regarding initiatives for transparency in the 3Ts industry since all the effort made so far on traceability, due diligence and certification will be affected by the lack of funds. Upstream companies have financed the majority of these initiatives to date but the decrease in the price of metals on the international market no longer allows upstream companies to support those initiatives today. It is the right moment for manufacturing companies and donors to contribute more to those initiatives which can then continue to achieve vital change with the full technical support of the 3Ts industry.”



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