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BGR: Mineral Supply Chain Due Diligence Audits and Risk Assessments in the Great Lakes Region

BGR: Mineral Supply Chain Due Diligence Audits and Risk Assessments in the Great Lakes Region

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Client: Bundesanstalt für Geowissenschaften und Rohstoffe (BGR)

Collaboration: International Conference on the Great Lakes Region (ICGLR) Audit Committee


Bundesanstalt für Geowissenschaften und Rohstoffe (BGR) commissioned Levin Sources to help the International Conference on the Great Lakes Region (ICGLR) Audit Committee determine opportunities for alignment of the Regional Certification Mechanism (RCM) with other systems over the short and long term and to have the foundations for developing their audit methodology and template. The ICGLR the Great Lakes Region) Audit Committee coordinates and monitors the RCM’S third party exporter audits to ensure the export of conflict-free minerals from the region.

Levin Sources undertook fieldwork in Rwanda and the Democratic Republic of the Congo (DRC). The team interviewed individuals managing the relevant conflict minerals initiatives and liaised with the Audit Committee advisory group. This work included a comparison of the audit schemes of the various conflict minerals initiatives with the RCM. It considered the core systems driving responsible sourcing systems for ‘conflict minerals’ (as defined by the OECD Due Diligence Guidance, the Dodd-Frank Act) and analysed the audit components of nine upstream conflict minerals systems which support 3TG supply chain due diligence in the GLR. Lastly, it considered the needs of downstream conflict minerals systems that require adequate assurance of upstream due diligence activities. The work was explored with the Audit Committee in a 3-day consultation workshop facilitated by ELL.

As a result of this work, there is a clear foundation and starting point for the design of a draft audit methodology for the RCM’s third party exporter audit. This ‘audit template’ will ensure consistency of approach by ICGLR third party auditors and will be used for data compilation during audit preparation and fieldwork and as a basis for drawing audit conclusions with regards to the RCM compliance of the auditee. The process has also opened up discussions with non-ICGLR stakeholders regarding system alignment opportunities.

Click here for the analytical report and audit template

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