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European Commission: Study on the support system for SME supply chain due diligence

European Commission: Study on the support system for SME supply chain due diligence

In 2016, the European Commission (EC) contracted Levin Sources to design a comprehensive support system for Small and Medium-scale Enterprises (SMEs) in the European Union. 

The project was initiated alongside the new EU regulation on responsible mineral sourcing (full title: Regulation (EU) 2017/821 of the European Parliament and of the Council of 17 May 2017 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict affected and high risk areas’).

Recognising the significant contribution SMEs make in EU imports of tantalum, tin, tungsten, and gold (3TGs), the EC commissioned a support system to develop SMEs’ understanding of the concept and benefits of supply chain due diligence, and to build their capacity to empower them to perform it on their mineral supply chains in a way that limits administrative burden.

To facilitate the research phase, Levin Sources collaborated with specialist consultancy RINA Consulting. The work involved sector analysis of and engagement with EU SMEs importing 3TGs. This allowed Levin Sources to develop a firm understanding of the needs and specific contexts of EU SMEs and design an effective support system based on research findings.

The support system developed was split into:

  • A Due Diligence Briefing Document: a companion to the ‘OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas’ that focuses on SME-centric questions and recommendations, and includes a number of tools in the form of annexes, and;
  • An educational platform, consisting of plans and materials for in-person and web-based training sessions; a checklist tool for self-assessment; and advisory for the content and design of educational literature including an online platform, printed materials, presentations, and a 4-minute animation addressing topics related to the performance of supply chain due diligence.

Levin Sources also developed a bespoke communications strategy and implementation plan, including content, messages, and digital promotional assets.

It is hoped that the project will help SMEs better understand the issues and potential benefits of supply chain due diligence, and shift towards both compliance with the EU regulation (when necessary) and supply chain transparency.

The Levin Sources project team was Dr. Yolande Kyngdon-McKay, Dr. Fabiana Di Lorenzo, Virginie Bahon, Jack Cooper, Gisa Roesen, Victoria Gronwald, Olivia Lyster, and Kate MacLeod.

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