Kumi reappointed as EU Conflict Minerals Regulation Assessor

Kumi has been reappointed as EU Conflict Minerals Regulation Assessor by the European Commission to evaluate the alignment of supply chain due diligence schemes with the requirements outlined in Regulation (EU) 2017/821, commonly known as the “Conflict Minerals Regulation.”

Since 2019, Kumi has exclusively served as the assessor for this scheme, conducting over five assessments on behalf of the European Commission.

What does the Regulation cover?

The Conflict Minerals Regulation (EU) 2017/821 came into effect on January 1, 2021, and aims to address the issues associated with conflict minerals by establishing supply chain due diligence obligations for EU importers of tin, tantalum, tungsten, and gold (3TG). The extraction, transport and processing of these minerals are linked to severe human rights abuses and the funding of armed conflict in certain regions.

Under the Regulation, importers based in the EU are obligated to undertake due diligence processes aimed at identifying and mitigating risks associated with the sourcing of 3TG. To meet this obligation, companies must implement a management system that integrates the stipulations outlined in the “OECD minerals guidance.” This guidance forms the essential framework for fulfilling the requirements set forth by the Regulation.

In order to do this, companies can opt to join an aligned due diligence scheme. Schemes need to be verified for their suitability against the Regulation. Any schemes that want to be aligned and be part of the regulation will undergo assessments to ascertain their compatibility with the OECD “Minerals guidance”, thus aligning with the requirements of the Regulation. While our role as assessors is crucial in evaluating and guiding a scheme’s compliance with the Regulation, the onus lies on individual companies to proactively incorporate and execute the specified requirements of the schemes.

Experienced Alignment Assessors

Kumi has played a leading role in Alignment Assessments (AAs) for the past decade. Collaborating closely with the OECD, Kumi contributed significantly to the development of the Alignment Assessment methodology. This methodology underwent pilot testing during a two-year OECD project, concluding in 2018.

In addition to the development of the methodology and pilot project, Kumi has successfully conducted over 20 alignment assessments which have taken us all over the world including USA, China, South Africa and many others.

Compliance with Conflict Minerals Regulation

Kumi’s focus is on assessing schemes against the requirements set out in the Regulation. To deliver this work, the Kumi team will continue to:

  • Engage with schemes to assess the ‘Policies and Standards’ and ‘Implementation’ aspects of the standards undergoing recognition.
  • Conduct shadow audits to observe how compliance with the standards is implemented in practice.
  • Interview key stakeholders to gather additional views and information about the schemes and standards under evaluation.

Andrew Britton, Kumi’s CEO said, “I am delighted to announce that Kumi has been reappointed as the assessor for the Conflict Minerals Regulation, a testament to our expertise and commitment to ensuring effective risk management in supply chains. As we supported the development of the alignment assessment methodology, we are uniquely positioned to contribute invaluable insights to the ongoing success of this critical Regulation.

Our extensive experience as trusted advisors to both the European Commission and the OECD across various sectors and supply chains underscores our ability to navigate the complexities of assessing standards and regulations. The recognition of our expertise through a rigorous and competitive tender process reaffirms our commitment to excellence.

Beyond our policy experience, we work with companies globally to proactively establish responsible sourcing management systems. From conducting gap analyses on company management systems to engaging in hands-on fieldwork, our work gives us a deep understanding of the context in which these schemes operate and the risks they seek to manage. 

This practical and expansive experience across sectors informs our policy work and is reflected in the European Commission’s decision to reappoint us, acknowledging the substantial value we contribute to the role. Our continued work on this Regulation underscores our steadfast commitment to promoting positive change and ensuring effective due diligence in mineral supply chains.”