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Andrew Britton

CEO

Alex Graf

Senior Consultant

Kumi Newsletter – September 2024

As I write this, I am in central Africa with one of our mining sector clients. We are helping them prepare for accreditation against a well-known responsible mining standard. In the mining and metals sector, it feels like the demands on companies to up their game on social and environmental performance continue to grow, driven by both customer demand and regulatory compliance obligations for responsible sourcing.

I have no doubt that responsible sourcing topics will be front of mind for many who are descending on London next week for LME Week. Members of the Kumi team will be at various events during the week; if you’re in town and would like to meet up do get in touch.

A hot topic issue for many is how to comply with the due diligence requirements of the EU Batteries Regulation. At Kumi we are privileged to have a unique vantage point on this through our work developing due diligence guidance for the Regulation on behalf of the European Commission.

This project is really taking shape now. It is great to see the ever-increasing interest and we appreciate all the support we received from the many stakeholders we’ve been engaging with in the course of our work. We are also getting a lot of enquiries, so James Lewry and Alex Graf have put together answers to the common questions we are being asked which you can read about within the insights section below.

We are close to finishing the draft deliverables for both the implementation guidelines for due diligence and the recognition of due diligence schemes. We are conducting closed consultations and we expect to submit our draft guidance to the Commission in October. Stay tuned, very soon there will be more to share!

If you haven’t yet taken our free, responsible business health check, now’s a good time! It only takes 5 minutes and you’ll get a free PDF download of your results. Our clients have found this a helpful way to grab a quick snapshot of the maturity of their due diligence processes. If you’d like to do the same, take it now.

Andrew Britton
CEO and Founder

The key developments this month:
1. The European Commission has published a comprehensive FAQ document on CSDDD
This covers the new rules, addressing common misconceptions and explaining the impact of the Directive on individuals and businesses.
2. Nike shareholders vote against proposal on workers’ rights
Shareholders have voted against a proposal to consider joining binding agreements with supply chain workers to better address human rights issues in high-risk countries at its annual meeting…
3. Amazon Launches Free Climate Solutions Platform to Help Decarbonize Supply Chain
Amazon announced the launch of the Sustainability Exchange, a new platform offering free access to sustainability tools and resources used by the company to decarbonize its operations…
Everything, everywhere, all at once? Preparing for the EU Batteries Regulation

Everything, everywhere, all at once? Preparing for the EU Batteries Regulation

n Kumi’s work developing the implementation guidelines for the EU Batteries Regulation (EUBR) on behalf of the European Commission, we have found that many businesses have questions about compliance in anticipation of the August 2025 deadline. As with other due diligence regulations, one of the most common questions businesses ask is, “Do we have to do everything, everywhere, all at once?” No, you don’t.

Why training is not enough to effectively implement the Voluntary Principles on Security and Human Rights (VPs)

“We were protesting peacefully when the shooting began. They didn’t even give us a chance…”[1]

In August 2012, a labour strike over pay and living conditions at the Marikana platinum mine in South Africa resulted in a tragic escalation, as police opened fire on the protesting miners, killing 34 and injuring at least 70 others…

Why training is not enough to effectively implement the Voluntary Principles on Security and Human Rights (VPs)

Mining company benchmarked against Copper Mark Criterion 10

Kumi was commissioned by a copper mining company with assets in Peru, to undertake a gap analysis of its existing management system against Criterion 10 (responsible supply chains) of the Copper Mark standard. Criterion 10 requires sites to conduct due diligence on their direct and indirect business partners (part 1) and mineral supply chains (part 2).

As the company had no mineral suppliers, our gap analysis focused on all services and goods purchased by the company…

Join us on Thursday 14 November, for a webinar on the EU Battery Regulations due diligence requirements with our technology partner, Circulor. The webinar will focus on what companies must do right now to be ready for the August 2025 deadline. It will be a practical session featuring our expert team, who have been supporting the European Commission on the implementation guidelines for the EUBR. Registration details will be coming soon!