Monitoring and Evaluation Framework

OECD DUE DILIGENCE GUIDANCE

FOR RESPONSIBLE SUPPLY CHAINS OF MINERALS
FROM CONFLICT-AFFECTED AND HIGH-RISK AREAS

2022 EDITION
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Monitoring and Evaluation Framework

OECD Due Diligence Guidance for Responsible Supply Chains

of Minerals from Conflict-Affected and High-Risk Areas

2022 edition

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PUBE
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Please cite as: OECD (2022), Monitoring and Evaluation Framework for the OECD Due Diligence Guidance
for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 2022.

© OECD 2022
The opinions expressed and arguments employed herein do not necessarily reflect the official views of
the OECD or of the governments of its member countries or those of the European Union.
This document and any map included herein are without prejudice to the status or sovereignty over any
territory, to the delimitation of international frontiers and boundaries and to the name of any territory,
city, or area.
Photo credit: © Luca Maiotti

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Note on the development of the

Monitoring and Evaluation
Framework

The development of this Monitoring and Evaluation Framework (M&E Framework) is premised on the
OECD’s terms of reference on measuring the results of the implementation of the OECD Due Diligence
Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas, which
had involved extensive prior stakeholder input over a period of 18 months. Further input and guidance
was received by the OECD’s Secretariat at each step of the M&E Framework’s development. The M&E
Framework was critiqued by an Informal Advisory Group of academic and civil society representatives.
Leading theory was applied to the problem at hand, including systems theory, game theory, and
literature specific to the problematic of minerals associated with conflict and adverse impacts. A section
on in-scoping Conflict-Affected and High-Risk Areas (CAHRAs) was added in July 2022
The basic characteristics of minerals markets were considered, as well as precedents involving the
measurement of policy implementation. Upon being operationalised, the guiding specifications and
parameters in the form of particular research methods and indicators were tested through example case
studies, providing a perspective of how this M&E Framework is to be applied. For this reason, several
examples spanning indicators and data sources were drawn from experience implementing the
Minerals DDG in the Democratic Republic of the Congo. These should be considered indicative as
specific national and sub-national data sources will be considered for the deployment of the M&E
Framework in selected countries.
This 2022 edition of the M&E Framework includes an additional chapter (Chapter 6) that provides
direction to practitioners on how to select and prioritise geographic areas and mineral commodities most
relevant to study using the M&E Framework. This edition also includes minor additions to Chapters 7,
8 and 9 to help practitioners use the M&E Framework and for purposes of consistency.
This document was produced with the financial assistance of the European Union. The views expressed
herein can in no way be taken to reflect the official opinion of the European Union.”

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Acknowledgements
This M&E Framework was prepared by Dr. Chris N. Bayer and Gerard van der Burg, representing
Development International e.V. (DI) and IMPACT, respectively, under the direction of Luca Maiotti,
Benjamin Katz, Hannah Koep-Andrieu and Tyler Gillard (OECD Centre for Responsible Business
Conduct). Design and communications support were provided by Roxana Glavanov and Ariane Rota.
On behalf of DI, the Framework was critiqued by Dr. Derrill Watson (Tarleton State University), Dr.
William Bertrand (Tulane University), Lawrence Heim (CCRcorp), Bryanna Frazier (DI), Jesse Hudson
(DI), Juan Ignacio Ibañez (DI), and Eliana Gonzalez Torres (DI). For IMPACT, Joanne Lebert and Kady
Seguin served as expert contributors, Carmen Teichgraber as the project manager, with contributions
also made by Dr. Anthony Goerzen and Luke Fiske of Queen’s University.
The design of this M&E Framework was further critiqued by the ad-hoc Informal Advisory Group (IAG),
comprising the following individuals: Catherine Anderson (OECD), Steven van Bockstael (University of
Gent), Darin Christensen (University of California, Los Angeles), Dr. Jose Diemel (Raw Resource
Solutions), Perla Ibarlucea (OECD), Benjamin Krause (University of California, Berkeley), Jocelyn Kelly
(Harvard University), Ken Matthysen (International Peace Information Service), Ben Miller (CDA
Collaborative), Nene Morisho (Pole Institute), Josaphat Musamba (Center for Human Security Bukavu),
Delphin Ntanyoma (Erasmus University), Dr. Dominic Parker (University of Wisconsin-Madison), Dr.
Ben Radley (University of Bath), Dr. Martin Schleper (University of Sussex), Michal Shinwell (OECD),
Dr. Nik Stoop (University of Antwerp), Dr. Marijke Verpoorten (University of Antwerp), Dr. Christoph
Vogel (University of Zurich), and Michelle Westermann-Behaylo (University of Amsterdam).
Further, the authors wish to thank the Multi-stakeholder Steering Group of the OECD Responsible
Minerals Implementation Programme (MSG) as well as constituent organisations of MSG members,
and in particular Olivier Bovet (State Secretariat of Economic Affairs of Switzerland), Leah Butler
(Responsible Minerals Initiative), Olivier Demierre (MKS PAMP GROUP), Guus Houttuin (European
External Action Service), Natalia Uribe (Alliance for Responsible Mining) and Annie Signorelli (Apple
Inc.) for their substantive feedback on the Framework draft.

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Table of contents
Overview 11
1. Objectives and Development of the M&E Framework 13
M&E Framework Objectives 13
M&E Framework Development 13

2. OECD Due Diligence Guidance 15

The five steps of due diligence 15

3. Typology of peacebuilding interventions 19

Withdrawal of the resources for war 20
Economic action 21
Culture of peace 22

4. Theory of change 25
Assumptions 25
Framework 28
Hypotheses 34

5. The impact blueprint 39

Dimensions of Impact 39
Results Framework 40

6. Selecting geographic areas and commodities to study using the M&E

Framework 41
Identifying geographic areas 41
Identifying relevant minerals 44
Identifying links to Annex II adverse impacts 45
Combination of Scoping Factors 47

7. M&E Framework 48
Monitoring vs. Evaluation 48
M&E Periodicity 52
Primary vs. Secondary Data, Levels of Rigour 52
Attribution vs. Contribution 53
Identification of Data and Methodological Gaps 55

8. Evaluation plan 57
Methods 57
Key Questions 57
Types of Data Consulted 58
Evaluation Sections 60
Evaluation Report 84

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9. Monitoring plan 89
Methods 89
Key Questions 89
Monitoring Reports 93

References 97
Glossary 101

Tables
Table 2.1. Classification of metals and relevant Supplements 17
Table 3.1. Peacebuilding in settings of conflict and fragility – common theories of change 19
Table 5.1. Results dimensions and descriptions 40
Table 5.2. Results framework 40
Table 6.1 Annex II adverse impacts 46
Table 6.2 Scoping matrix 47
Table 7.1. Monitoring vs. Evaluation, attribution vs. contribution 49
Table 7.2. Primary vs. secondary data sources 52
Table 7.3. Type of evaluation 56
Table 7.4. Ultimate outcome dimensions treated by evaluation 56
Table 7.5. Evaluation process indicators 56
Table 8.1. Evaluation, key questions 57
Table 8.2. Annex II Adverse Impact indicators 62
Table 8.3. SEC indicators 66
Table 8.4. Minerals trade indicators 67
Table 8.5. DDP indicators 69
Table 8.6. Incidents detected vs followed-up vs mitigated through each in-scope DDP 70
Table 8.7. Downstream Step 5 indicators 73
Table 8.8. Downstream supply chain actor classification 75
Table 8.9. Upstream Step 5 indicators 78
Table 8.10. Upstream supply chain actor classification 80
Table 8.11. Global Minerals DDG context indicators 82
Table 8.12. In-scope context profile domains 83
Table 8.13. Quantitative measures of DDP quality and scale 84
Table 8.14. Qualitative measures of DDP quality and scale 85
Table 8.15. Assessment related to hypothesis clusters 85
Table 8.16. Evaluation, further key questions 85
Table 8.17. Evaluation, longitudinal questions 86
Table 8.18. Evaluation Framework 87
Table 9.1. Key Monitoring questions 89
Table 9.2. Summary monitoring-indicators 89
Table 9.3. Monitoring indicators for Annex II Adverse Impact risks 90
Table 9.4. Monitoring indicators for Socio-Economic Conditions 92
Table 9.5. Monitoring indicators for in-scope CAHRA Contexts 93
Table 9.6. Monitoring Framework 95
Table 9.7. Due Diligence Programme (DDP) criteria for M&E Framework studies 102

Figures
Figure 1.1. Thematic scope of M&E Framework 11
Figure 4.1. Theory of change 28
Figure 4.2. Due diligence decision tree (ToC) 29
Figure 4.3. Immediate level outcomes (ToC) 31
Figure 4.4. Intermediate level outcomes (ToC) 33
Figure 4.5. Ultimate level outcomes (ToC) 33

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Figure 4.6. DDP ultimate outcomes 34

Figure 5.1. Theory of Change linked to the results framework and to the hypotheses 39
Figure 6.1 Conflict barometer categories 42
Figure 6.2. CAHRA measurement and scope for M&E Framework 44
Figure 7.1. Monitoring vs. evaluation 51
Figure 7.2. Attribution or contribution between levels of action 54
Figure 8.1. Assessment sections as related to the Theory of Change 60
Figure 8.2. Units of analysis 62
Figure 8.3. Due Diligence Programmes and relevant impacts 69
Figure 8.4. Company due diligence and purchasing modes 75
Figure 8.5. Company DD and purchasing modes 80

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Acronyms and Abbreviations

3T Tin, Tungsten, Tantalum
3TG Tin, Tungsten, Tantalum and Gold
ACLED Armed Conflict Location & Event Data Project
AO Areas of Operation
ARM Alliance for Responsible Mining
ASM Artisanal and Small-scale Mining
CAHRAs Conflict-Affected and High-Risk Areas
CCA Causal Contribution Analysis
CFSP Common Foreign and Security Policy
CMRT Conflict Minerals Reporting Template (RMI)
COO Country of Origin
CRAFT Code of Risk-Mitigation for Artisanal and Small-Scale Mining Engaging in
Formal Trade
CSO Civil Society Organisation
DAC Responsible Business Conduct
DALY Disability-Adjusted Life Year
DD Due Diligence
Minerals OECD Due Diligence Guidance on Responsible Supply Chains of Minerals
DDG from Conflict-Affected and High-Risk Areas
DDM Due Diligence Minerals
DDP Due Diligence Programme
DI Development International e.V.
DMCC Dubai Multi Commodities Centre
EITI Extractive Industries Transparency Initiative
FCPA Foreign Corrupt Practices Act (U.S.)
GAO Government Accountability Office (U.S.)
GEM General Elimination Methodology
GDP Gross Domestic Product
GNI Gross National Income
HHI Harvard Humanitarian Initiative
HIIK Heidelberg Institute for International Conflict Research
HRW Human Rights Watch
IAG Informal Advisory Group
ICF Inner City Fund
IEP Institute for Economics & Peace

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ILO International Labour Organization

IPIS International Peace Information Service
KST Kivu Security Tracker
KYC Know Your Counterparty
LBMA London Bullion Market Association
LME London Metal Exchange
LSM Medium and Large-scale Mining
M&E Monitoring and Evaluation
MONUSCO United Nations Organization Stabilization Mission (in the DRC)
NCPs National Contact Points (OECD)
n.d. not dated
NGO Non-Governmental Organisation
non-DDM non-Due Diligence Minerals
NONIE The Network of Networks on Impact Evaluation
OECD Organisation for Economic Co-operation and Development
OEM Original Equipment Manufacturer
OFAC Office of Foreign Asset Control (U.S.)
OHS Occupational Health & Safety
RBC Responsible Business Conduct
RCOI Reasonable Country of Origin Inquiry
RCT Randomised Control Trial
RJC Responsible Jewellery Council
RMI Responsible Minerals Initiative
SC Supply Chain
SD Specialised Disclosure
SEC Socio-Economic Conditions
SIC Standard Industrial Classification
SOR Smelter or Refiner
S&P Standard & Poor's
TOC Theory of Change
TOR Terms of Reference
UN United Nations
UNDP United Nations Development Programme
UNICEF United Nations Children's Fund
UNITAR United Nations Institute for Training and Research
WGC World Gold Council
WGI Worldwide Governance Indicators

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Overview
The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected
and High-Risk Areas (Minerals DDG) recognises the private sector as a critical force and change agent
that can influence the well-being of societies, and as bearing a particular responsibility when operating
in or sourcing from conflict-affected and high-risk areas (CAHRAs). By conducting due diligence and
making informed purchasing decisions, the private sector can avoid contributing to serious human rights
abuses, curtail revenue to armed groups and organised crime, and avoid links with financial crime. It
can also help countries and communities benefit from their natural resources.
As due diligence matures and grows to cover mineral supply chains across the globe, policymakers,
stakeholders, and industry are looking for data to inform their decision-making. The application of this
Monitoring and Evaluation Framework (M&E Framework) will improve understanding of how due
diligence is being implemented and if it is helping to achieve the aims of the Minerals DDG —
and, if not, why. Like most policy interventions, to date the results of due diligence in mineral supply
chains appear mixed, with progress, shortcomings and ambiguous outcomes spread across multiple
dimensions. This is where the real value of the M&E Framework lies; to make sense of the mechanisms
by which the policy environment and uptake of due diligence bring about impacts, particularly in mineral
producing countries and communities. The aim, in turn, is to generate actionable data that can help
stakeholders scale up what’s working and address what isn’t.

How does the M&E approach work?

The M&E Framework uses a theory of change to articulate the process through which corporate
uptake of the Minerals DDG affects the market for responsibly sourced minerals and, in turn,
influences the prevalence of adverse impacts and socio-economic conditions in mining
communities. The theory of change also includes contextual factors that may drive, hinder or otherwise
influence the implementation of due diligence.

Figure 1.1. Thematic scope of M&E Framework

Annex II Adverse Impacts

Market Dynamics &
Degree of Corporate DDG Uptake
Direct Engagement
Socio-Economic Conditions

International level Production level

The framework relies on several studies to collect data for each part, or node, of the theory of
change. For example:
• studies on context will collect information on regulatory developments or the level of informality
in supply chains;

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• studies on uptake will examine companies’ implementation of specific due diligence practices;
• studies on the market for responsible trade in minerals will look at the performance of due
diligence programmes and relative volumes of responsibly traded minerals;
• studies on impacts will aggregate data on the incidence of serious human rights abuses or
armed conflict in producing countries, among many other indicators.
Comparing the results at each node will then enable investigation of the relationships between
them. Each study outlines methodologies, indicators, and data sources to generate evidence-based
conclusions.
It may not be possible to isolate and estimate the effect of the Minerals DDG on specific outcome
dimensions with quantitative precision. The framework will, however, collect a significant amount
of data that can affirm (or call into question) the theory of change and its underlying
assumptions. The usefulness of the framework will emerge most saliently from the picture it will build
of specific due diligence topics across the dimensions of the theory of change. Consider the issue of
tax payments: The framework collects data on this topic at every node along the theory of change,
starting with public financial management performance, through to companies’ and due diligence
programmes’ transparency on tax payments, and finally to receipts by governments. Similarly, the
framework helps infer relationships between different parts of the theory of change on issues as diverse
as de-risking, opportunities in the formal economy and decent work deficits. The studies will therefore
not only help identify where there are shortcomings with implementation, but also the most impactful
points of entry for addressing such shortcomings and enhancing existing positive outcomes.
More promising, the level of detail of the framework’s findings is projected to significantly
improve over time, due both to the increased quality of corporate self-reporting necessitated by
regulation and market requirements as well as the increased confidence made possible by data
collected over multiple cycles. The framework will also allow for interesting comparisons to be made
of implementation between different regions, for example, between producing countries with significant
experience in implementation and those where companies are just beginning to conduct due diligence.
Ultimately, through these distinct analytical lenses, the framework aims to provide actionable
information for stakeholders:
• for policymakers to continue stitching together a global rules-based system for responsible
mineral supply chains;
• for industry, market makers and exchanges to improve uptake of the Minerals DDG, and
strengthen the incentives for doing so;
• and to empower civil society organisations with data that allows them to hold companies and
governments accountable, ensure that due diligence is context-sensitive and help mineral-
producing communities reap the benefits of improved governance of the sector.

How will the rollout work practically?

The OECD will supervise deployment of the framework in several selected countries and supply chains.
Pursuant to its purpose of monitoring and evaluating implementation of the Minerals DDG, the M&E
Framework has a global geographic scope and is applicable to all minerals. A means to select
country-supply chain pairs in which to deploy the framework is provided in Chapter 6. of this M&E
framework. The OECD will continue to liaise with stakeholders, in particular partner organisations,
independent researchers, companies and industry associations collecting data on mineral supply
chains, to promote a harmonised approach to impact measurement and address identified data gaps
through bespoke studies as necessary.

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1. Objectives and Development of the

M&E Framework

M&E Framework Objectives

This M&E Framework puts forward a hypothetical mechanism through which the uptake of the
Minerals DDG could affect change in mineral markets and influence producer conditions in
CAHRAs. Further, the Framework offers methods to measure the underlying phenomena in order to
substantiate or reject the proposed hypotheses. To this end, it defines relevant concepts and key
terms, identifies indicators to be applied, as well as existing datasets from which to draw. It also
addresses the question of impact attributable to the Minerals DDG.

M&E Framework Development

The steps pursued in the development of this M&E Framework were four-fold:
TOR: The development of this M&E Framework was premised on the OECD’s Terms of
Reference (TOR), which involved extensive stakeholder input over a period of 18 months.
Further guidance was received by the OECD’s Secretariat along each critical step of the M&E
Framework’s development.
Advisory group consultations and dialectic: From the outset and along the main milestones, the
specifications and parameters of this M&E Framework were discussed and critiqued by the
Informal Advisory Group, a group of academic and civil society representatives, as well as
OECD representatives. Their input was incorporated at each main iteration.
Literature review (precedents): Leading (economic) theory was applied to the matter at hand,
including system theory, game theory, and literature specific to the issue of minerals associated
with conflict and adverse impacts. Also, the basic characteristics home to minerals markets
were considered. In addition, other precedents involving the measurement of policy
implementation were considered. Relevant literature is discussed throughout this Framework.
Design and application: Last, upon being operationalised, the research methods, guiding
specifications, parameters and indicators were tested through a case study.

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2. OECD Due Diligence Guidance

Ten years have passed since the OECD Due Diligence Guidance on Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk Areas (Minerals DDG) was first adopted in May 2011 by
OECD members and non-member Adherents to the OECD Guidelines for Multinational Guidelines.
The Minerals DDG is addressed to companies active in mineral supply chains, and calls on them to
carry out comprehensive due diligence through a 5-step framework to avoid contributing to serious
human rights abuses, conflict financing and other forms of financial crimes through their extractive and
sourcing practices. The Minerals DDG is intended to be used by any company (potentially) sourcing
minerals from conflict-affected and high-risk areas (CAHRAs). The Minerals DDG emphasises a
progressive approach and encourages companies to stay engaged and mitigate risks instead of
avoiding them, except in specific circumstances outlined by the Minerals DDG in which the severity of
the risk precludes remaining engaged, or in which risk mitigation is not feasible or has failed.

The five steps of due diligence

The Minerals DDG (OECD, 2016) sets out the following five-step framework for carrying out due
diligence:

Step 1: Establish strong company management systems

Step 2: Identify and assess risks in the supply chain

Step 3: Design and implement a strategy to respond to identified risks

Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices

Step 5: Report annually on supply chain due diligence

Annex II Adverse impacts

Annex II of the Minerals DDG includes a model policy a company could adopt if it is sourcing minerals
from, or is itself operating in, “conflict-affected and high-risk areas.” At its core are “significant adverse
impacts”, “associated with extracting, trading, handling and exporting minerals from conflict-affected
and high-risk areas” (OECD, 2016: 20):

1. Serious abuses associated with extraction, transport or trade of minerals:

• torture, cruel, inhuman and degrading treatment;

• forced or compulsory labour;
• worst forms of child labour;
• gross human rights violations / widespread sexual violence;

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• war crimes / serious violations of international humanitarian law / crimes against humanity /
genocide.

2. Direct or indirect support to non-state armed groups, that:

• illegally control mine sites, transportation routes, trading hubs;

• illegally tax or extort money or minerals at points of access to mine sites, transportation routes
and/or trading hubs;
• illegally tax or extort intermediaries, export companies or international traders.

3. Public or private security forces

• Direct or indirect support to public or private security forces who illegally control mine sites,
transportation routes, trading hubs;
• Use of public or private security forces other than to protect and maintain rule of law for mine
sites, transportation routes, trading hubs;
• Public or private security forces not engaged in accordance with the Voluntary Principles on
Security and Human Rights;
• Adverse impacts on vulnerable groups related the presence of public and/or private security
forces.

4. Bribery and fraudulent misrepresentation of the origin of minerals

• Bribery or disguise of mineral origin, misrepresentation of taxes, fees, and royalties related to
any form of mineral extraction, handling, transport and export.

5. Money laundering

• Reasonable risk of the presence of money laundering related to extraction, trade, handling,
transport and export of minerals.

6. Non-payment of taxes, fees and royalties due to governments

• Taxes, fees and royalties related to mineral extraction, trade and export are not paid
appropriately and disclosed.
For the first and second set of adverse impacts, the company commits itself, as soon as the company’s
due diligence identifies such a risk, to “neither tolerate nor by any means profit from, contribute to, assist
with or facilitate the commission by any party of” and to an immediate cessation of sourcing activities
(OECD, 2016: 20). For the remainder of the impacts, a company commits itself to immediate mitigation
strategies in a time-bound manner while supply chain commerce continues.

The scope of the guidance and supplements

OECD (2016) clarifies that the due diligence guidance therein is indeed applicable to all extracted
minerals. In the absence of a dedicated Supplement for a specific mineral/metal, companies should
apply the recommendations of the relevant Supplement of the Minerals DDG, as per Annex I. For
industrial and minor metals, companies should refer to the Supplement on 3Ts. For precious and
platinum group metals, companies should refer to the Supplement on Gold. Where the
recommendations in one or both of the supplements are not applicable to a company’s supply chain
because of the way the mineral/metal is produced or traded, companies should explain and publicly
disclose why.

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Table 2.1. Classification of metals and relevant Supplements

Minerals/metals Minerals DDG
supplement
Precious and platinum group metals, precious stones (e.g. gold, iridium, osmium, palladium, Supplement on Gold
platinum, rhodium, ruthenium, silver, diamonds, jade, rubies)
Industrial and minor metals (e.g. tin, tungsten, tantalum, bauxite, copper, lead, zinc, nickel, Supplement on Tin,
iron, molybdenum, cobalt, manganese, antimony, vanadium, titanium, lithium, chromium, Tantalum and Tungsten
lanthanum)
Note: This table is not exhaustive as to the scope of minerals covered. The Minerals DDG is applicable to all minerals, including energetic
mineral.

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3. Typology of peacebuilding
interventions

Addressing the private sector, the Minerals DDG provides a due diligence sourcing standard. To place
this policy “intervention” in context, a peacebuilding framework “Evaluating Peacebuilding Activities in
Settings of Conflict and Fragility,” is offered by the OECD (2012). It allows the Minerals DDG’s aims to
be placed in the relevant typology on the various types of peacebuilding interventions.
In particular, three “theories of change” highlighted in the typology have direct relevance to the approach
taken by the Minerals DDG and the Theory of Change of this M&E Framework.

Table 3.1. Peacebuilding in settings of conflict and fragility – common theories of change
Theory of Change Examples of methods
Individual change: If we transform the consciousness, Individual change through training, personal transformation
attitudes, behaviours and skills of many individuals, we will or consciousness-raising workshops or processes;
create a critical mass of people who will advocate peace dialogues and encounter groups; trauma healing.
effectively.
Healthy relationships and connections: Strong Processes of intergroup dialogue; networking; relationship-
relationships are a necessary ingredient for peacebuilding. building processes; joint efforts and practical programmes
If we can break down isolation, polarisation, division, on substantive problems.
prejudice and stereotypes between/among groups, we will
enable progress on key issues.
Withdrawal of the resources for war: Wars require vast Campaigns aimed at cutting off funds and national budgets
amounts of material (weapons, supplies, transport, etc.) for war; conscientious objection and/or resistance to military
and human capital. If we can interrupt the supply of people service; international arms control; arms (and other)
and goods to the war-making system, it will collapse and embargoes and boycotts.
peace will become possible.
Reduction of violence: If we reduce the levels of violence Ceasefires; creation of zones of peace; withdrawal or
perpetrated by combatants and/or their representatives, retreat from direct engagement; introduction of
we will increase the chances of bringing security and peacekeeping forces and interposition; observation
peace. missions; accompaniment efforts; promotion of non-violent
methods for achieving political, social and economic ends;
reform of security sector institutions (military, police, justice
system/ courts, prisons).
Social justice: If we address the underlying issues of Long-term campaigns for social and structural change; truth
injustice, oppression/exploitation, threats to identity and and reconciliation processes; changes in social institutions,
security, and peoples’ sense of injury/victimisation, it will laws, regulations, and economic systems.
reduce the drivers of conflict and open up space for peace.
Good governance: Peace is secured by establishing stable New constitutional and governance arrangements and
and reliable social institutions that guarantee democracy, entities; power-sharing structures; development of human
equity, justice, and the fair allocation of resources. rights, rule of law, anti-corruption; establishment of
democratic, equitable economic structures; economic
development; democratisation; elections and election
monitoring; increased participation and access to decision
making.
Political elites: If we change the political calculus and Raise the costs and reduce the benefits for political elites of
perception of interests of key political (and other) leaders, continuing war and increase the incentives for peace;
they will take the necessary steps to bring peace. engage active and influential constituencies in favour of

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Theory of Change Examples of methods

peace; withdraw international support/ funding for warring
parties.
Grassroots mobilisation: “When the people lead, the Mobilise grassroots groups to either oppose war or to
leaders will follow.” If we mobilise enough opposition to advocate positive action; use of the media; non-violent
war, political leaders will be forced to bring peace. direct action campaigns; education and mobilisation effort;
organising advocacy groups; dramatic or public events to
raise consciousness.
Peace agreements/accords: Some form of political Official negotiations among representatives; civil society
settlement is a prerequisite to peace – we must support a dialogues to support negotiations; track 1½ or 2 dialogue
negotiation process among key parties to the violence. among influential persons.
Economic action: People make personal decisions, and Use of government or financial institutions to change supply
decision makers make policy decisions based on a system and demand dynamics; control incentive and reward
of rewards and incentives and punishment and sanctions systems; boycotts and embargoes.
that are essentially economic in nature. If we can change
the economies associated with war making, we can bring
peace.
Public attitudes: War and violence are partly motivated by TV and radio programmes that promote tolerance;
prejudice, misperceptions, and intolerance of difference. modelling tolerant behaviour; symbolic acts of
We can promote peace by using the media (television and solidarity/unity; dialogue among groups in conflict, with
radio) to change public attitudes and build greater subsequent publicity.
tolerance in society.
Transitional justice: Societies that have experienced deep Truth and reconciliation commissions; criminal prosecutions
trauma and social dislocation need a process for handling and war crimes tribunals; reparations; community
grievances, identifying what happened, and holding reconciliation processes; traditional rites and ceremonies;
perpetrators accountable. Addressing these issues will institutional reforms.
enable people to move on to reconstruct a peaceful and
prosperous society.
Community reintegration: If we enable displaced people Negotiation and problem solving to enable returns;
(IDPs/refugees) to return to their homes and live in relative intergroup dialogue; ex-combatant community engagement;
harmony with their neighbours, we will contribute to processes for handling land claims; trauma healing.
security and economic recovery.
Culture of peace: If we transform cultural and societal Peace education; poverty eradication; reduction of social
norms, values and behaviours to reject violence, support inequalities; promotion of human rights; ensuring gender
dialogue and negotiation, and address the fundamental equality; fostering democratic participation; advancing
causes of the conflict, we can develop the long-term tolerance; enhancing the free flow of information and
conditions for peace. knowledge; reducing the production of and traffic in arms.
Source: OECD (2012)

Withdrawal of the resources for war

Cutting off funds for war is an effective peacebuilding intervention. Noting that the duration of conflict
was, at the turn of the millennium, “more than double that of conflicts that started prior to 1980,” Collier
et al. (2003) offer a number of explanations, inter alia:
• “Rebel groups can generate revenues and purchase armaments.”
• “Rebellions have gradually changed their character, becoming less political and more
commercial.”
• “Violence entrepreneurs, whether primarily political or primarily commercial, may gain from war
to such an extent that they cannot credibly be compensated sufficiently to accept peace.”
• “Those who see themselves as extortionists benefit from the absence of the rule of law in areas
they control.”
Illustrating point 3 in particular, and partially explaining how internal armed conflict is perpetuated, Vogel
and Stearns (2018: 2) observe that national “political and military elites have become increasingly
invested in conflict, rendering it an end in itself.” Further, “for a narrow elite” internal conflict became
“deeply functional,” to the extent that instead of “promoting cohesion and discipline, the government

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has perceived its security apparatus primarily as a means for distributing patronage, only occasionally
prioritizing stability” (ibid).
The scenario of exogenously withdrawing the resources for war in a given CAHRA, to apply game
theory, may be best characterised through a public-goods game. A public good, e.g. national defence
or police service, is characterised by two conditions: (1) non-rivalry (a good, once consumed, does not
reduce the amount available for others), (2) non-excludability (in which it is not possible to provide a
good without it being possible for others to benefit). Firms signing onto due diligence generate positive
externalities and, thus, is undersupplied in equilibrium. By punishing and rewarding actors through a
carrot and stick approach towards due diligence (that amplifies the benefits of participation or,
equivalently, the costs of non-compliance), national and international standard-setting regimes can
change behaviour that results in a “shift” to a more virtuous equilibrium.
Considering that an estimated 5,000 mining and trading companies – representing 3.4% of the Group
of 8 (G8) firms – account for 94.6% of the total number of traders in minerals on which no due diligence
has been conducted (non-DDM) in the G8, a relatively finite group of companies would need to be
persuaded to comply. 1 If these ca. 5,000 firms, located upstream in the minerals supply chain, could be
prevented from trading in so-called “conflict minerals” (Mizuno, Ohnishi and Watanabe, 2016: 13), the
flow of such minerals could almost be eliminated within the G8. Mizuno et al. conclude: “When these
firms refuse to buy conflict minerals from their suppliers, the supply chains of many intermediaries which
are positioned upstream suffer.”
Conversely, if even a fraction of the world’s trading and consuming companies were to act as
opportunistic minerals buyers without conducting due diligence (DD), the business model of those
selling non-DDM would continue to be viable, and business transactions with armed groups and
organised crime would continue to occur. In that sense, an overwhelming majority of firms would need
to be stag hunters in order for the trade in non-DDM to become non-viable and non-lucrative (Skyrms,
2001).
As per the Minerals DDG, pre-competitive or implicit cooperation is necessary to identify and
economically “isolate” non-DDM before or after entering the market. Yet, as direct communication
between perfect or near-perfect competitors would in most jurisdictions equate to anti-trust violations,
such “cooperation” would exist only if either coordinated through third parties or in the form of common
policies, e.g. agreements not to procure minerals that have not undergone sufficient due diligence. The
supply chain knock-on effects are considerable and not to be underestimated.

Economic action

Changing supply and demand dynamics fostered through companies’ sourcing decisions is furthermore
noted by the OECD as an effective peacebuilding intervention. Indeed, the Minerals DDG expects
companies to use their leverage with suppliers to improve conditions of extraction and trade, and
ultimately to disengage in the most harmful circumstances, or once other mitigation options are
exhausted as per Annex II of the Minerals DDG. 2
One discretionary lever the Minerals DDG ascribes to companies concerns the terms of supplier
contracts. Contract theory is used to find theoretical ways to motivate agents to take appropriate actions,

1Using Standard & Poor's (S&P) Capital IQ data, and crunching 60 billion pairs of firms, Mizuno et al. mapped the
entire supply chains of 423,024 of the world’s major incorporated firms. They found that 80% of the world’s firms
are connected to any other business via six customers or suppliers (Mizuno, Ohnishi and Watanabe, 2016).
2 To cite an example of a company taking such action, Apple (2020) reported that it had removed 123 smelters or
refiners located in its extant supply chains since 2009.

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and this Framework is mindful of typical situations, e.g. adverse selection and signalling scenarios.
Applied to the context of minerals, due diligence data collection and supplier engagement are ways to
counteract the common information asymmetry germane to markets, and in doing so reduce the
potential for adverse selection (in which the principal is not informed about a certain characteristic of
the agent at the time the contract is written). With the act of “signalling,” one party credibly conveys
information about itself to the other party. In the context of non-DDM, an actor operating in traditionally
opaque markets might employ signalling, notably by obtaining a 3rd party audit or certificates that
provide some form of assurance in the veracity of the company’s claim.
Most mineral supply chain structures are shaped like an hourglass, with the number of actors
progressively decreasing from mine to SOR, only to increase again after the SOR level and moving
further downstream. As the SOR level represents a control point with bundled purchasing power,
downstream due diligence efforts and assurance programmes such as the London Bullion Market
Association (LBMA) and the Responsible Minerals Initiative (RMI) have honed in on this supply chain
tier. These assurance programmes then issue whitelists of SORs that pass audits and belong to the
program. The existence of blacklists would be equally important from a standpoint of impact, and
containing the flow of non-Due Diligence/non-audited minerals.

Culture of peace

As set out in the Foreword of the Minerals DDG, the Guidance is intended to cultivate transparent
mineral supply chains and sustainable corporate engagement in the mineral sector with a view to
enabling countries to benefit from their mineral resources in addition to preventing the extraction and
trade of minerals from becoming a source of insecurity.
Justification for such interventions is provided by empirical studies investigating the determinants of
political violence, that generally find a positive association between poverty and the probability of conflict
(Collier and Hoeffler, 2004; Fearon and Laitin, 2003; Hegre and Sambanis, 2006). Findings have shown
that in countries with abundant natural resources and relatively low rates of economic growth, social
development and political stability, violent conflict erupts or persists, described as the “paradox of
plenty” (Bruch, 2016). The presence of valuable minerals in a context of conflict effectively fans the
flames: Empirical research conducted for the African region found that the higher the mineral value, the
more likely it will attract the attention of armed groups. Conducting a meta-analysis of natural
experiments that use difference-in-difference designs to estimate the causal effect of international
commodity price changes on armed conflict,” Blair, Christensen and Rudkin (2021) find that price
increases in lootable commodities provoke conflict. This finding is notably echoed by Stoop, Verpoorten
and van der Windt, (2019), who find that an "exogenous rise in the value of ASM sites leads to increases
in battles, attacks against civilians and looting, indicating competition between rapacious armed
groups."
Besides armed conflict, serious hostility, tension and abuses can also emerge from the displacement
of artisanal and small-scale mining (ASM) by large-scale—or industrial—mining (LSM) (Stoop,
Verpoorten and van der Windt, 2019). Given the empirical linkages between scarcity and conflict, it is
concerning that some due diligence programmes have produced “ambiguous” outcomes that “threaten
an informal ASM sector already in jeopardy” (Vogel, Musamba and Radley, 2018: 1). Similarly, an
investigation honing in on mining reindustrialisation involving a gold mine in the South Kivu Province of
the DRC, found that “despite generating a 25–fold increase in productivity,” there was no “significant
wage growth for most industrial workers, compared to the wages earned in artisanal mining” (Radley,
2020; 1). Furthermore, due to the “displacement of artisanal mining to more marginal deposits,” ASM
employment had fallen 50%, and mining wages had decreased by around 40% (ibid).

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The above examples highlight how fostering a culture of peace is linked to the social and economic
context of producing communities. Indeed, doing so effectively in the mining sector may include
interventions that explicitly aim to promote inclusive economic outcomes and actively promote human
rights and gender equality.
On gender equality in particular, stakeholders spanning governments, the private sector and civil society
acknowledge that empowering women and girls is the best way to achieve positive economic and
inclusive social development outcomes. The Stakeholder Statement on Implementing Gender-
Responsive Due Diligence and ensuring the human rights of women in Mineral Supply Chains adopted
at the OECD Forum on Responsible Mineral Supply Chains commits stakeholders to implement and
support gender-responsive due diligence, and to provide equitable opportunity for women to participate
in and benefit from the sector (OECD, 2019).
Aside from the benefits of greater peace and stability for economic welfare, some due diligence
interventions are designed to provide enhanced economic opportunity in the formal sector and, as a
result, may improve governments’ ability to mobilise revenue. Depending on their approach, DDPs may
also affect the terms and conditions on which minerals are traded, and can therefore have economic
consequences for mining communities. Policies – whether governmental or by DDPs or individual
companies – that produce scarcity, poverty and inequality, run counter to the objectives of the Minerals
DDG, and justify the inclusion of socio-economic conditions in the ultimate outcome level of this
Framework.

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4. Theory of change

A Theory of Change (TOC) is a “theory of how and why an initiative works” (The Center for Theory of
Change Inc, 2019). At the onset of an M&E endeavour, however, a TOC comprises a set of hypotheses,
which, once tested and accepted, may deserve the label “theory” in the scientific sense.
This TOC thus details the hypothesised mechanism through which corporate uptake of the Minerals
DDG may have an on-the-ground effect. Grounding the TOC in an analysis of both the context of the
intervention and the role of the target audience of the Minerals DDG ensures the plausibility of achieving
the impact outlined in the TOC, and the extent to which this hypothesised impact is realistic.

Assumptions

Each stage of the anticipated change pathway is associated with a series of assumptions that were
identified during the development of the TOC. Since assumptions can change over time, the illustration
of the TOC does not include any specific identified assumption. The initial list of assumptions includes
the following.

Assumption #1: Corporate purchasing power in supply chains may encourage the formation of legal, formal, inclusive
markets if exercised responsibly, or conversely can produce the opposite if wielded indiscriminately.

Assumption #2: In the context of CAHRAs, conflict is not caused, per se, by the trade in minerals.1 Rather, such
conflict is sustained or exacerbated by indiscriminate purchasing of minerals originating from CAHRAs.

Assumption #3: Minerals sourced from a CAHRA are likely to be exposed to one or more of the risks identified in
Annex II.

Assumption #4: In the context of the Information Age and the 4th industrial revolution, the accurate verification of
mineral provenance and extraction conditions and context is technologically feasible.

Assumption #5: Buyers for non-DDM will be present. For many minerals, there is also a domestic market. The
difficulty of curtailing the flow of illegal goods is illustrated by drug smuggling. One can therefore not realistically reduce
the possibility of the sale of minerals funding armed groups to 0%. However, one can, through collaborative efforts,
bring down (international) demand for non-DDM on the part of formal, legal commerce and thus also drive down the
price of non-DDM relative to DDM (through less demand).

Assumption #6: The degree to which due diligence is executed in line with the Minerals DDG, at the individual market
actor level, will be reflected in that market actor’s public documents, including relevant policies and Minerals DDG-
informed reporting.

Assumption #7: To varying degrees, upstream and downstream actors exercise responsibility in the market by
differentiating between suppliers based on their Minerals DDG-premised due diligence performance. In doing so
(“responsible purchasing”), they influence, at an aggregate level, demand for the various mineral sources.

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Assumption #8: If companies do not empirically demonstrate that they are taking necessary action concerning their
purchasing decisions, they are presumed to be effectively avoiding their responsibility with regard to Annex II Adverse
Impacts.

Assumption #9: Through multi-stakeholder action, in line with Minerals DDG Step 3 (OECD 2016): “Design and
implement a strategy to respond to identified risks,” through multi-stakeholder action market actors can effectively
pool information, resources and systems, and so achieve efficiency effects (e.g. by joining associations and supporting
initiatives that address the issues at hand).2

Assumption #10: The more DDM flowing out of CAHRAs, the less opportunity there is for mining operations to fund
armed groups and organised crime (causing Annex II Adverse Impacts). Improved production and trade practices –
reflected through the geographic expansion of due diligence programmes in the upstream – will translate into fewer
minerals being sold with the potential to benefit armed groups.

Assumption #11: Private sector action, properly implementing the Minerals DDG, is able to curtail revenue flowing to
armed groups. According to supply and demand dynamics, a reduced demand for non-DDM would depress their
prices, and thus reduce the revenue potentially benefitting armed groups.

Assumption #12: Both DDM and non-DDM are currently traded (the trade in DDM does not equal 0). Viable DDPs
exist.

Assumption #13: For the sake of the TOC model, we assume that the total amount of minerals produced is constant
– i.e. any increase/decrease in DDM is 100% offset by a decrease/increase in non-DDM. In reality, however, that is
not necessarily the case, especially in the context of dynamic markets in which ASM operates.

Assumption #14: While the Minerals DDG mainly targets company actions and behaviours related to minerals flowing
out of CAHRAs, the well-being of miners and their communities is also referenced.3 Also, since relevant literature
provides empirical evidence between socio-economic conditions (SEC) and the potential for conflict, the SEC of
miners and their communities are considered in this Framework.

Notes.

1. Findings have shown that in countries with abundant natural resources and relatively low rates of economic growth, social development
and political stability, violent conflict erupts or persists, described as the “paradox of plenty” (Bruch, 2016). The presence of valuable minerals
in a context of conflict effectively fans the flames: Empirical research conducted for the African region found that the higher the mineral
value, the more likely it will attract the attention of armed groups. Conducting a meta-analysis of natural experiments that use difference-in-
difference designs to estimate the causal effect of international commodity price changes on armed conflict,” Blair, Christensen and Rudkin
(2021) find that price increases in labour-intensive (capital-intensive) and lootable commodities prevent (provoke) conflict. Specifically with
respect to ASM, increases for artisanally mined commodities (principally, gold and diamonds) raise the likelihood of armed civil conflict.
This finding is notably echoed by Stoop, Verpoorten and van der Windt, (2019), who find that an "exogenous rise in the value of ASM sites
leads to increases in battles, attacks against civilians and looting, indicating competition between rapacious armed groups." Berman et al.
(2014: 1) observe that “secessionist insurgencies are more likely in mining areas,” and that “the appropriation of a mining area by a group
increases the probability that this group perpetrates future violence elsewhere.” Bates (2008) argues that governments can use force to
either protect or prey upon their citizens: Whether a government functions as a guardian or a warlord largely depends on: (1) public revenues,
(2) the presence of natural resources, and (3) the benefits from predation. He then examines the interactions between mineral wealth, state-
capacity, and armed insurgent groups with a focus on Africa. Thus, these findings may also help to predict which minerals are likely to
become associated with conflict-financing risks in the context of a CAHRA.

2. Multi-stakeholder action is evidenced on various levels and in different forms, for example:
• cross-recognition of audit programmes, where audit systems recognize each other’s audits (e.g. LBMA and RMI)
• data exchange standards (e.g. IPC-1755, Conflict Minerals Data Exchange Standard)
• pre-competitive supply chain information flow (e.g. software vendors iPoint-systems or Assent Compliance)
• audited and non-audited SORs (e.g. RMI’s CMRT, which functions as both)
• pre-competitive working groups (e.g. RMI working groups)
• joint sponsorship of interventions (e.g. the Public-Private Alliance for Responsible Minerals Trade.

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3. The Foreword of the Minerals DDG highlights that the “Guidance provides companies with a complete package to source minerals
responsibly in order for trade in those minerals to support peace and development and not conflict” (OECD, 2016: 3). In this vein, the
Appendix in the Supplement on Gold features steps companies may take to “minimise the risk of marginalisation of the artisanal and small-
scale mining sector, particularly the victims of extortion, while promoting conflict-free gold supply chains, thereby creating economic and
development opportunities for artisanal and small-scale miners” (OECD, 2016: 114). While participation in one or more DDPs is a way for a
company to partially meet its due diligence responsibilities, it is, however, not a substitute for carrying out its own due diligence. See Minerals
DDG (OECD, 2016: 114), Appendix, Supplement on Gold: “Suggested measures to create economic and development opportunities for
artisanal and small-scale miners.”

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Framework

Figure 4.1. Theory of change

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Initial Conditions

Minerals DDG implementation, at the company level, would involve following its stipulated five Steps.
Carrying out robust due diligence is a precondition to identify and mitigate negative conditions
associated with the extraction and trade of minerals to be purchased as per Annex II. Conversely, the
model includes the possibility that a company may not conduct due diligence (a).

Figure 4.2. Due diligence decision tree (ToC)

Due diligence on specific minerals to be purchased would lead to bifurcation (b) or (c). Each of these
conditions is informed by Annex II of the Minerals DDG, paragraphs 1 and 3. These first and second
adverse impacts – i.e. 1. Serious abuses associated with extraction, transport or trade of minerals, and
2. Direct or indirect support to non-state armed groups – are prioritised in the sense that they “prompt
immediate disengagement” (c). This latter condition itself is expected to not further negative conditions
related to Annex II (x). If, however, the conditions as spelled out in paragraphs 1 and 3 are absent, the
company proceeds with (d) through (h).

Immediate level outcomes

As per the Minerals DDG, down- and up-stream actors have a central role to play in either not sourcing
– or sourcing with special care – minerals linked to Annex II Adverse Impacts.
The myriad of companies in minerals-based supply chains make daily decisions to engage with,
disengage from, or suspend operations with specific suppliers and supply chains or to invest in risk
mitigation or harm reduction in line with the Minerals DDG. Conversely, they may simply ignore the risks
or not take Minerals DDG-informed action.

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Assessing this behaviour allows one to categorise companies according to their DD practices. The
following six basic actor types are featured in the ToC:
No Due Diligence: The company provided no evidence of OECD-premised due diligence.
De-risking: The company stated they (a) avoided engaging in, doing business in, or sourcing from
certain countries, or (b) avoided engaging with – or sourcing from – certain production types
(e.g. ASM).
Unconditional purchasing: The company indicated that while they carried out some DD, they did
not assess conditions for purchases of minerals or intermediate forms. Further, the company
did not indicate that, if sourcing from CAHRAs, its supply chains exclusively purchased DDM.
Non-purchase engagement: The company indicated they responsibly disengaged their supply
chains from CAHRAs when they found conditions as per Annex II paragraphs 1 and 3, but
invested in harm reduction and/or risk mediation.
Partial risk management: The company indicated that they purchased minerals (or intermediate
forms) on condition of source material associated with a Due Diligence Programme (DDP), but
did not engage further. 3
Enhanced risk management: The company indicated that they (a) responsibly disengaged their
supply chains from a given CAHRA when they found conditions as per Annex II paragraphs 1
and 3, (b) prudently engaged their supply chains in conditions according to paragraphs 10 and
14, and (c) engaged their supply chains across a spectrum of risk management actions:

3 While participation in one or more DDPs is a way for a company to partially meet its due diligence responsibilities,
it is, however, not a substitute for carrying out its own due diligence.

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Figure 4.3. Immediate level outcomes (ToC)

Downstream
• use of leverage
• contract conditions
• capacity-building of suppliers
• grievance mechanisms
• direct engagement on Annex II-cited phenomena
• DDP participation and/or provision of financial support to DDPs

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Upstream
• on-the-ground risk assessments
• capacity-building
• ASM formalisation
• child labour remediation
• engaging multi-stakeholder efforts to assist vulnerable populations
• tracking and disclosing payments to governments
• formalising security arrangements
• DDP participation

Minerals DDG-aligned risk mitigation and harm reduction activities are thus complemented by Minerals
DDG-inspired pro-active engagement that may enhance positive impacts on miners and their
communities. 4

Intermediate level outcomes

Individual company-level procurement decisions at the micro level to mitigate, suspend, disengage, or
engage, will, at the macro level, be reflected, ceteris paribus, in the demand and supply for Due
Diligence Minerals, i.e. minerals that have originated from a DDP.
Purchasing through mining operations and associated chain-of-custody systems that have undergone
a robust responsible sourcing and due diligence process is an effective way for companies to empirically
demonstrate that they sourced from a CAHRA in accordance with Annex II of the Minerals DDG. The
Framework tallies DDM volumes and ratios of incident resolution, per mineral and per CAHRA, to obtain
aggregate-level values. The M&E Framework thus yields empirical measures of the degree of due
diligence. If these values are low, one may conclude that a critical mass of due diligence is not
evidenced.

4 See Minerals DDG (OECD, 2016: 114), Appendix, Supplement on Gold: “Suggested measures to create
economic and development opportunities for artisanal and small-scale miners.”

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Figure 4.4. Intermediate level outcomes (ToC)

Ultimate level outcomes

At the ultimate outcome level of the TOC, there are two categories: the first focuses on the private
sector’s effect on the conditions highlighted in ANNEX II, and the second concerns relevant actions that
affect socio-economic conditions (SEC) for miners and mining communities.

Figure 4.5. Ultimate level outcomes (ToC)

Private sector’s effect on adverse impacts Private sector’s effect on socio-economic

of Annex II (serious human rights violations conditions for miners and mining
and/or direct/indirect support of armed communities
groups and criminal networks)

Figure 4.6. DDP ultimate outcomes

below breaks down the particular impacts featured in the TOC, 12 individual Annex II impacts and 3
SEC impacts. In sum, the private sector’s effective implementation of the Minerals DDG would
hypothetically result in the reduction of its active contribution to Annex II Adverse Impacts. Moreover,
the more widely and conscientiously the Minerals DDG is implemented by private sector actors, the
more substantial its positive impact across ultimate-level outcomes.

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Figure 4.6. DDP ultimate outcomes

Hypotheses

Since the stated Theory of Change is initially untested, it is therefore a fully hypothetical mechanism at
the outset. The TOC is to be validated through hypothesis-premised assessments as laid out in this
Framework, while no validation of assumptions is proposed. In other words, the hypotheses are tested
through the conduct of related assessments underpinning the M&E Framework. Linkages between
featured elements will be consequently explored and subsequent adjustments proposed if need be.

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Figure 4.7. Hypotheses

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On an individual mineral basis, the following (null) hypotheses positions are taken. Should the required
research called for in this M&E Framework determine that any hypothesis ought to be
rejected, alternative hypotheses are proposed.

Hypothesis Cluster 1 (Due Diligence Minerals Demand)

IF a critical mass of companies purchases minerals on condition of DDP participation, but without other
Minerals DDG-related conditions (m),
or
IF a critical mass of companies proceeds with mineral purchases under conditions and/or risk mitigation
actions fully in line with the Minerals DDG (including DDP participation) (n),
THEN demand for Due Diligence Minerals from CAHRAs will rise, ceteris paribus.
Conversely:
IF a critical mass of companies declines to purchase minerals and completely disengage (de-risking)
(k),
and/or
IF a critical mass of companies proceeds with mineral purchases without conditions despite evidence
of Annex II Adverse Impact risks (I),
THEN demand, for Due Diligence Minerals from CAHRAs will fall, ceteris paribus.

Hypothesis Cluster 2 (Due Diligence Minerals Supply)

IF demand for Due Diligence Minerals from CAHRAs rises,

THEN the quantity of Due Diligence Minerals from CAHRAs supplied will consequently also rise over
the long run (more DDPs, larger scale) (q),
AND there will be more market access for Due Diligence Minerals (p), ceteris paribus.
Conversely:
IF demand for Due Diligence Minerals from CAHRAs falls,
THEN the quantity of Due Diligence Minerals from CAHRAs supplied will consequently fall over the long
run (fewer DDPs, smaller scale) (q),
AND, there will be less market access for Due Diligence Minerals (p), ceteris paribus.

Hypothesis Cluster 3 (Annex II Impacts)

IF the supply of Due Diligence Minerals from CAHRAs rises (r),

or
IF there is a critical mass of private sector engagement that fosters capacity and formalisation
(enhanced risk management) (s),
THEN the private sector will make a positive difference on the adverse impacts of ANNEX II, ceteris
paribus.
Conversely:
If the supply of Due Diligence Minerals from CAHRAs falls (t),

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and
IF there is an absence of private sector engagement that fosters capacity and formalisation (enhanced
risk management) (s),
THEN the private sector will make a negative difference on the adverse impacts of ANNEX II, ceteris
paribus.

Hypothesis Cluster 4 (SEC Impacts)

IF the supply of Due Diligence Minerals from CAHRA rises (u),

or
IF there is a critical mass of private sector engagement that fosters capacity and formalisation
(enhanced risk management) (w),
THEN the private sector will make a positive difference on socio-economic conditions of miners and
mining communities, ceteris paribus.
Conversely:
IF the supply of Due Diligence Minerals from CAHRAs falls (v),
and
IF there is an absence of private sector engagement that fosters capacity and formalisation (enhanced
risk management) (w),
THEN the private sector will make a negative difference on socio-economic conditions of miners and
mining communities, ceteris paribus.

Hypothesis Cluster 5 (Global Context)

IF the global demand for in-scope minerals rises,

THEN that will result in increased demand for Due Diligence Minerals from CAHRAs, ceteris paribus.
Conversely:
IF the global demand for in-scope minerals falls,
Then that will result in decreased demand for Due Diligence Minerals from CAHRAs, ceteris paribus.

Hypothesis Cluster 6 (CAHRA Context)

IF the prevalence of ANNEX II Adverse Impacts in a CAHRA decreases significantly,

or
IF the business and operating environment in a CAHRA improves significantly,
THEN that will result in increased demand for Due Diligence Minerals from that CAHRA, ceteris paribus.
Conversely:
IF the prevalence of ANNEX II Adverse Impacts in a CAHRA increases significantly,
or
IF the business and operating environment in a CAHRA worsens significantly,
Then that will result in decreased demand for Due Diligence Minerals from that CAHRA, ceteris paribus.

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5. The impact blueprint

Dimensions of Impact

The impact blueprint refers to the conversion of the Theory of Change into a results-based model that
provides the basis to validate the stated hypotheses and provide analytical insight in the impact of the
Minerals DDG over time. As Figure 5.1 shows, the Theory of Change converts into a results framework
with three key outcomes, namely:
• Ultimate outcome level: Improved Annex II and socio-economic conditions
• Intermediate outcome level: Due Diligence Minerals supply and demand
• Immediate outcome level: Increased supply chain capacity for due diligence

Figure 5.1. Theory of Change linked to the results framework and to the hypotheses

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Each outcome dimension is investigated through M&E verification, i.e. assessments that determine the
degree to which the hypothesised change is occurring, validating or invalidating specific relationships
outlined in the Theory of Change. Each outcome dimension is in turn developed in greater detail, with
indicators associated with the outcome as described in the next chapter.
Table 5.1. Results dimensions and descriptions
Results dimension Description
Annex II and Socio- Annex II and socio-economic conditions of miners are improved as a result of companies in
Economic Conditions the mineral(s) supply chain implementing due diligence-based processes in accordance
with the Minerals DDG
Annex II Adverse Significant Annex II Adverse Impacts associated with the extraction, transport or trade
Impacts of minerals
Socio-Economic Socio-Economic Conditions of miners and mining communities
Conditions
Due Diligence Minerals Growing supply and demand of Due Diligence Minerals
Supply and Demand
Mineral supply Mineral(s) production in line with Minerals DDG and documented sufficiently to access
international markets
Mineral demand Mineral(s) demand levels, incorporation of source verification and due diligence
documentation
Supply Chain Capacity for Downstream and upstream companies have the systems and capacity in place to assure
Due Diligence that approaches for due diligence are established and functioning
Supply chain Level of management systems implementation associated with the minerals supply
management systems chain
Supply chain Mineral provenance, production, purchase and chain-of-custody traceability along the
transparency upstream and downstream supply chain
Risk identification, Level of risk monitoring and documentation and the associated risk mitigation actions
monitoring and mitigation along the supply chain
Audits, reporting Level of transparency reflected in the published annual Step 5 reporting
transparency

Results Framework
Table 5.2. Results framework
Outcome Minerals DDG Outcomes Dimensions of Impact Dimension of M&E
Level Verification
Ultimate Companies in the minerals supply chain Annex II Adverse Impacts Prevalence/incidents of 12
Outcome do not contribute to serious human rights Annex II Adverse Impacts
abuses and conflict
Companies in the mineral supply chain Socio-Economic • Livelihood
support the socio-economic conditions of Conditions of miners and
miners and mining communities mining communities • Gender equality
• Occupational Health and
Safety (OHS)
Intermediate Minerals-based industries applying Due Diligence Minerals Due Diligence Minerals Trade
Outcome OECD Minerals DDG-based due Quality and scale of Due
diligence Diligence Programmes
Immediate Both upstream and downstream Increased supply chain Supply chain management
Outcome companies align their programmes to the capacity systems
OECD Minerals DDG Transparency of commodity
metadata
Risk identification, monitoring
and mitigation
Audits, reporting
transparency (Step 5
reporting)

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6. Selecting geographic areas and

commodities to study using the M&E
Framework

Scientific measures and thresholds are used to select priority geographic areas and mineral
commodities to study the impact of the Minerals DDG using the M&E Framework. As a matter
of practicality, relevance and methodological soundness, selected geographic areas will
conform with the Minerals DDG’s definition of conflict-affected and high-risk areas (CAHRAs).
The Minerals DDG expects companies to develop and disclose a methodology to assess risks
in their supply chains. As part of this process, in particular to effectively identify red flags,
companies are called upon to identify CAHRAs in addition to other risk factors related to
suppliers and circumstances. In any case, the identification of CAHRAs will vary between
stakeholders and methodologies, and evidence of Annex II risks should prompt enhanced due
diligence regardless. This is reflected by the importance accorded by the methodology outlined
in this chapter to the prevalence of such risks. The methodology outlined in this chapter has
been developed to identify CAHRAs with greatest relevance for this research. Any geographic
area(s) that the methodology indicates would be appropriate to study using the M&E Framework
do not represent any definitive list of CAHRAs, and the methodology pertains solely to use of
the M&E framework. Nonetheless, the data sources included in this chapter would be relevant
to identifying CAHRAs in the exercise of due diligence and risk assessments in general.

Identifying geographic areas

In September 2020, the European Commission Directorate General for Trade (DG TRADE)
published a website with an indicative, non-exhaustive and regularly updated list of conflict-
affected and high-risk areas (as set out in Article 14(2) of the Regulation). The objective of this
website is to maintain a list to facilitate the calibration of due diligence efforts made by EU
importers of the relevant metals and minerals (EU, n.d.). For the purpose of the M&E
Framework, while reference is made to the EU website, the CAHRA determination is done using
the methodology outlined in this section.

a. Definitions

A CAHRA, as defined in the Glossary and for the purposes of this M&E framework, may
comprise one or both conditions: conflict and/or high-risk. Countries and their subdivisions are
codified in ISO 3166, and such lists are made available from the United Nations Statistics
Division.

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b. Scientific measures

To operationalise and provide scientific measures for these two conditions (conflict-affected and
high-risk), established indexes lend themselves.

“Conflict-affected”
According to the Minerals DDG, conflict is characterized “by the presence of armed conflict,
widespread violence, including violence generated by criminal networks, or other risks of
serious and widespread harm to people” (OECD, 2016a:66). It is further defined as “conflict of
international or non-international character, which may involve two or more states, or may
consist of wars of liberation, or insurgencies, civil wars” (Ibid).
The University of Heidelberg’s Conflict Barometer measures and categorizes conflict according
to five levels (disputes, non-violent crises, violent crises, limited wars, wars).

Figure 6.1 Conflict barometer categories

Source: HIIK (2020), Conflict Barometer 2019, https://hiik.de/wp-content/uploads/2020/08/ConflictBarometer_2019_4.pdf.

Given that wars and limited wars are commonly accompanied by human rights abuses,
Internally Displaced Persons (IDPs) and political instability and weakness, according to its
taxonomy, at least the two most severe categories (limited wars, wars) would meet the OECD’s
definition of conflict-affected.
For the contextual assessment of the M&E Framework, another relevant measure is “the Global
Peace Index (GPI), which ranks 163 independent states and territories according to their level
of peacefulness” (IEP, 2020). The GPI is produced by the Institute for Economics & Peace
(IEP), which is an independent, non-partisan, non-profit think tank. Using 23 qualitative and
quantitative indicators from authoritative sources, the GPI encompasses 99.7% of the world’s
population, and assesses the state of peace across three dimensions:
1. level of societal safety and security;
2. extent of ongoing domestic and international conflict; and
3. degree of militarisation (Ibid).

Given the wider scope of the Global Peace Index approach, it is more useful as a source for
building a general understanding of the broader context of countries or regions under
consideration. Whereas, the Heidelberg barometer, with its narrower focus on conflict at the

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national and sub-national levels, is better suited to the selection of countries and regions to
study using specific thresholds.
While, for the purposes of the M&E Framework, the Heidelberg Conflict Barometer is used as
a principal source, other data sources may also be relevant and can be consulted accordingly.
The following sources may also serve as reference points.
• World Bank’s Worldwide Governance Indicators (WGI) project, which includes an
indicator Political Stability and Absence of Violence, for which it collects information for
over 200 countries and territories over the period 1996–2019 (along with five other
dimensions of governance – Voice and Accountability, Government Effectiveness,
Regulatory Quality, Rule of Law and Control of Corruption) (World Bank Group, n.d.a).
• Armed Conflict Location & Event Data Project (ACLED), is a disaggregated data
collection, analysis, and crisis mapping project. “ACLED collects the dates, actors,
locations, fatalities, and types of all reported political violence and protest events
around the world” (ACLED, n.d.).
• Fragile States Index, developed by the Fund for Peace, is based on a conflict
assessment framework (“CAST”), developed by FFP for assessing the vulnerability of
states to collapse. It is important to note, however, that this index also incorporates
other non-conflict related variables (FFP, 2020).
• Proprietary indexes measuring conflict, including matrices offered by IHS Markit and
Verisk Maplecroft.

“High-risk areas”
High-risk areas are defined in the Minerals DDG: “where there is a high risk of conflict or of
widespread or serious abuses as defined in paragraph 1 of Annex II of the Guidance” (OECD,
2016a). Furthermore: “Such areas are often characterised by political instability or repression,
institutional weakness, insecurity, collapse of civil infrastructure, widespread violence and
violations of national or international law” (Ibid).
To measure the degree to which any given geography qualifies as a “high-risk area” the OECD’s
multi-dimensional Fragility Framework may be relevant, as featured in its States of Fragility
publications. Fragility is defined as a “combination of exposure to risk and insufficient coping
capacity of the state, system and/or communities to manage, absorb or mitigate those risks”
(OECD, 2016b). Furthermore, “fragility can lead to negative outcomes including violence, the
breakdown of institutions, displacement, humanitarian crises or other emergencies” (Ibid). The
framework combines five relevant dimensions that encompass political, societal, economic,
environmental and security measurements.
It should be noted that the Fragility Framework relies on a number of international measurement
frameworks, including those mentioned above in this Chapter, such as the University of
Heidelberg’s Conflict Barometer. Additional resources on corruption, money laundering and tax
evasion such as the Financial Action Task Force’s list of high-risk and non-cooperative
jurisdictions and country reports, as well as the Natural Resource Governance Institute’s
Resource Governance Index can provide relevant information on institutional weakness in high-
risk areas.

c. Thresholds / Criteria

For the purposes of implementing the M&E Framework, an operational, quantitative threshold
for CAHRAs is required to enable evidence-based selection of countries or regions in which to
use the M&E Framework.

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Conflict: Using the University of Heidelberg’s Conflict Barometer, for the purposes of prioritizing
those countries in which the highest level of conflict is taking place, violent crises, limited wars,
and wars are within the scope of the methodology. For 2019, this translates to 15 wars involving
12 countries and 23 limited wars in 19 countries around the world (HIIK 2020).
High-risk areas: Against the OECD Fragility Framework, this methodology includes within
scope those countries measured as having a fragility level of 4 to 5. This operationalisation is
visualized in Figure 6.2 below. Thirteen countries were highlighted as “extremely fragile” in its
2020 report (OECD, 2020).

Figure 6.2. CAHRA measurement and scope for M&E Framework

Conflict-Affected and High-Risk Areas (CAHRA)

Conflict of international or national character Exposure to risk and insufficient coping capacity of
the state, system and/or communities to manage,
Heidelberg’s Conflict Barometer (levels 3-5) absorb, or mitigate those risks.
OECD’s Fragility Framework (levels 4-5)

Identifying relevant minerals

After prioritising CAHRA, the selection will be further filtered according to specific mineral supply
chains. Just as a “conflict threshold” is needed for the purposes of selecting countries for study
with the M&E Framework, the second lens through which the M&E Framework is applied is the
minerals dimension.

A. Definitions

The 3rd edition of the OECD Minerals DDG clarified that the scope of the guidance does not
only pertain to 3TG, but to all minerals:
This third edition of the OECD Due Diligence for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas provides clarification on the scope of the Guidance by
removing language in the Introduction Guidance that was perceived to limit its application only
to the supply chains of tin, tantalum, tungsten and gold. The updated edition now clarifies that
the Guidance provides a framework for detailed due diligence as a basis for responsible supply
chain management of all minerals (OECD 2016a:4).

B. Thresholds / Criteria

In order to narrow the focus to minerals that have been linked to the adverse impacts as per
Annex II, this methodology applies the following criterion: a credible source will need to have
provided evidence that a particular Annex II adverse impact is linked to a particular mineral
being exploited in a particular country (CAHRA). We operationalise “validated” as findings
originating from at least two separate sources (i.e., two corroborating publications). We
operationalise “credible” as a source originating from a governmental, academic or journalistic
outlet.

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There must be evidence of ongoing prevalence of an Annex II adverse impact linked to the
mineral and geographic area under consideration to remain in-scope of the M&E Framework.
These data will be obtained from the monitoring cycles as per the M&E Framework. Related
factors for consideration that may influence a mineral’s propensity to become linked to Annex
II risks include the following:
● Produced in CAHRA region: A mineral or metal’s production, processing or trade in a
CAHRA (as defined and operationalised above).
● Relative value: There is evidence that the higher the value and the more easily lootable
a commodity is, the more likely it is to become a source of conflict and attract the
attention of armed groups (Christensen, Blair and Rudkin, 2021). This finding may help
predict which minerals/metals are at risk of being linked to conflict in a CAHRA.
● Fungibility: In economics, fungibility is the property of a good or a commodity whose
individual units are essentially interchangeable (Frankenfield, 2020). The degree to
which there is domestic/regional consumption of the commodity, avoiding the need for
export, and the ease with which the commodity is exchanged for another, are relevant
factors. In contexts where commodity currencies instead of fiat currencies are common,
gold or diamond are inter alia used as a currency.

Identifying links to Annex II adverse impacts

After prioritizing CAHRA and minerals, the selection will be further filtered according to the
prevalence and intensity of Annex II adverse impacts.
In order to appropriately frame the context in which company actions occur, the M&E
Framework will leverage country-level statistics to appropriately frame the business and
operating environments in which companies implement their due diligence responsibilities. The
relative actions or inaction of national governments will thus be considered in this M&E
Framework to establish context.

a. Definitions

For Annex II adverse impact we in-scope the 6 themes of the Annex II, which comprise
adverse impacts related to (further detailed in the ‘Scientific measures’ section
following):
1. serious human rights abuses;
2. non-state armed groups;
3. public or private security forces;
4. bribery and fraudulent misrepresentation of the origin of minerals;
5. money laundering;
6. non-payment of taxes, fees and royalties due to governments.

b. Scientific Measures

The following key indicators measure the adverse impacts as per Annex II. As
indicators 1 through 5 concern the population-level, the unit is individual cases per 1
million inhabitants. Regarding indicators 6 through 12, the highest-value, non-
representative measure concerns either the number of people affected or monetary
value of damage.

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Table 6.1 Annex II adverse impacts

Minerals DDG Annex II Indicator

1. Human-rights serious abuses – Serious abuses associated with extraction, transport or trade of
minerals:
(i) Torture, cruel, inhuman and degrading (1) Prevalence of torture, cruel, inhuman and degrading
treatment treatment (cases per 1 million inhabitants).
(ii) Forced or compulsory labour (2) Prevalence of forced / compulsory labour (cases per 1 million
inhabitants).
(iii) Worst forms of child labour (3) Prevalence of worst forms of child labour (cases per 1 million
inhabitants).
(iv) Gross human rights violations / (4) Prevalence of widespread sexual violence (cases per 1
widespread sexual violence million inhabitants).
(v) War crimes / serious violations of (5) Conflict-related deaths (cases per 1 million inhabitants).
international humanitarian law / crimes
against humanity / genocide
2. Direct or indirect support to non-state armed groups, that:
i) Illegally controlled mine sites, (6) Top documented adverse incidents of illegally controlled
transportation routes, trading hubs mine sites, transportation routes, trading hubs (highest-value,
non-representative).
ii) Illegally taxed or extorted money or (7) Top documented adverse incidents of illegally taxed or
minerals at mine site access points, extorted money or minerals at mine site access points,
transportation routes and/or trading hubs transportation routes and/or trading hubs (highest-value, non-
representative).
iii) Illegally taxed or extorted (8) Top documented adverse incidents of illegally taxed or
intermediaries, export companies and/or extorted intermediaries, export companies and/or international
international traders traders (highest-value, non-representative).
3. Public or private security forces
(9) Top documented adverse incidents regarding security forces
in the past 3-5 years (highest-value, non-representative).
4. Bribery and fraudulent misrepresentation of the origin of minerals
(10) Top documented adverse incidents regarding bribery and
fraudulent misrepresentation in the past 3-5 years (highest-
value, non-representative).
5. Money laundering
(11) Top documented adverse incidents involving money
laundering in the past 3-5 years (highest-value, non-
representative).
6. Non-payment of taxes, fees and royalties due to governments
(12) Top documented adverse incidents regarding the non-
payment of taxes, fees and royalties due to governments in the
past 3-5 years (highest-value, non-representative).

c. Thresholds / Criteria
The first criteria, for the purposes of this M&E Framework, for a particular Annex II adverse
impact to trigger a CAHRA-country to be in scope, is for the presence of an Annex II adverse
impact to be reported by a credible and validated source.
Credible: We operationalise “credible” as comprising a scientific, governmental or
journalistic publication, which would be consulted to potentially in-scope a

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particular Annex II adverse impact.

Validated: We operationalise “validated” as the Annex II adverse impact-related findings
as originating from at least two separate sources.

Combination of Scoping Factors

A 3-factor model is put forward to organise information on country/region, mineral, and Annex
II adverse impacts to help select country or region-commodity pairs to study using the M&E
Framework:

Instrumentalising the in-scoping criteria described in previous sections, the following table
represents an approach for systematising the scoping methodology involving the three variables
(evidence of CAHRA status, ANNEX II adverse impacts, as well as specific minerals produced,
processed or traded in CAHRAs).

Table 6.2 Scoping matrix

Mineral Conflict areas Annex II adverse In-scope
High-Risk areas
s impacts CAHRA
Heidelberg’s Conflict OECD’s Fragility
Barometer (levels 4- Framework (levels
5) 4-5)
(0=No, (insert 1 at (insert level in each
(0=No, 1=Yes)
1=Yes) corresponding level) category)

CAHRA
Environmental
Violent crises

Limited wars
Non-violent
producing

Economic
Disputes

Security
Political

Societal
Mineral

crises

Validated Annex II
Wars

condition

0- 0- 0- 0- 0-
0-1 1 2 3 4 5 0-1 Mineral
5 5 5 5 5
Ranking
CAHRA A
generated
CAHRA B through
algorithm
etc.

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7. M&E Framework

Monitoring vs. Evaluation

The M&E Framework follows the hypothesised causal logic of the Theory of Change and the
corresponding results framework. However, it also provides additional details about how the
hypotheses will be verified, indicators used, how they will be measured, and how the information
is intended to be used. After identifying the key indicators, the M&E plan assigns the appropriate
levels of rigour and outlines the assessment methodology. The assessment methodology
guides the M&E activities throughout the assessment implementation (before, during and after).
When an initiative is planned to be ongoing, and progress needs to be monitored along the way,
a Longitudinal Time Series is often used. In M&E framework design, the impact indicators are
measured at baseline and the full set (or a subset of the impact indicators) are measured at
subsequent regular intervals to have sufficient data to show long-term trends. This design is
appropriate in high-risk security situations or when working with at-risk populations in order to
ensure impact trends can provide early insight for more agile intervention. In rigorous empirical
studies, this design is applied as a Quasi-Experimental Longitudinal time series. It is considered
the most scientific proof of impact with a pre-test and post-test with controls, in addition to
sufficient data over time, including post-intervention, to show long term trends and sustainability.
This design can, however, also be applied to a research design without a control group. This
rigorous – yet flexible – design approach will measure the in-scope phenomena periodically
over time.
The concepts of Monitoring and Evaluation are defined as follows:
Evaluation is defined as a systematic “assessment of the design, implementation and outcome
of an on-going or completed intervention” in order to assess value (FORMIN, 2006: 39). The
results of an evaluation should provide stakeholders with the information they need to analyse
whether the Minerals DDG and its TOC are meeting its anticipated objectives. The exercise of
“evaluation” falls into one of two categories, being either formative or summative.
• A summative evaluation is the term for a final assessment to reveal whether a higher
programme goal was achieved. This type of evaluation would commonly serve as a post
mortem on an initiative by assessing whether or not the goals were achieved.
• A formative evaluation is the term given to an assessment performed for the purpose of
improving an initiative and is thus conducted during the course of implementation. A
formative evaluation aims to reveal whether progress is being made towards achieving
planned goals, and whether this progress is unfolding as planned or needs be improved
upon.
In this case, evaluation refers to the periodic collection, examination and analysis of information
that pertains to the Minerals DDG Theory of Change, and the Minerals DDG implementation
outcomes (immediate, intermediate and ultimate). With the Minerals DDG being implemented

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by companies sourcing from CAHRAs, it would be appropriate to approach the evaluation

aspect of this Framework in the ‘formative’ evaluation context as, in the private sector context,
continuous improvement is pursued. As such, the evaluation covers principally only those
matters over which the change in the phenomena being measured may arguably be attributed
back to ongoing Minerals DDG implementation activities.
Impact Monitoring is defined as “the continuous assessment of the intervention and its
environment” (FORMIN, 2006: 31). It is a form of surveillance which regularly monitors
outcomes. Multiple indicators are followed to measure changes in the main aspects of the
process, rather than just focussing on specific questions predetermined by the longer-term
evaluation framework. As conditions in CAHRAs and supply chains are constantly changing,
through Impact Monitoring, stakeholders will have the ability to review the broad outcomes of
their efforts with real-time data to make decisions immediately, rather than waiting to compare
and contrast results at subsequent points in time (i.e. through evaluation assessments).
When monitoring impacts, the Framework goes beyond the individual actions (activities and
outputs) of companies performing Due Diligence and purchasing DDM. Impact concerns the
changes at the outcome level, in the occurrences of Annex II Adverse Impacts and/or variation
of socio-economic conditions that are generated from having more formalised supply chains
and safer working conditions for miners and mining communities. The results of impact
monitoring provide stakeholders with the information they need to analyse outcomes, identify
trends and patterns related to shorter-term outcomes, and identify problems before they
become serious obstacles to performance and progress.
Table 7.1 outlines the type of assessment (Monitoring or Evaluation) that will be applied through
the application of this M&E Framework.

Table 7.1. Monitoring vs. Evaluation, attribution vs. contribution

Goal level Description Monitoring vs. Attribution
Evaluation
Ultimate A. Annex II Adverse Monitoring, 3rd order attribution (does not only depend on supply
Outcome Impacts Evaluation of DDM)
B. Socio-Economic Monitoring, 3rd order attribution (does not only depend on supply
Conditions Evaluation of DDM)
Intermediate C. Due Diligence Evaluation 2nd order attribution between Minerals DDG and
Outcome Minerals Trade demand for DDM (does not only depend on Minerals
DDG uptake)
D. Due Diligence Evaluation 2nd order attribution between Minerals DDG and
Programmes supply of DDM (does not only depend on demand for
Minerals DDM)
Immediate E. Downstream Evaluation 1st order attribution between Minerals DDG and
Outcome Minerals DDG uptake individual market actor practices
F. Upstream Minerals Evaluation 1st order attribution between Minerals DDG and
DDG uptake individual market actor practices
Context G. Global Minerals Evaluation Not applicable
DDG Context Profile No attribution theorised at the onset
H. CAHRA Context Monitoring, Not applicable
Profile Evaluation No attribution theorised at the onset

Source: Author’s own

In graphical format, Figure 7.1 shows how the Monitoring and Evaluation exercises relate to the
Theory of Change, previously presented.

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Figure 7.1. Monitoring vs. evaluation

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M&E Periodicity

At what intervals should the Minerals DDG M&E Framework collect data and
compare its findings?

Given the serious nature of the subject matter (conflict, serious human rights abuses, financial crime),
yearly monitoring research is recommended. For evaluations on the other hand, as they take into
account the rate of change over time and assess outcomes based on research findings, a longer time
frame in the range of every 3-5 years is appropriate. Given that this M&E Framework has been
published 10 years after the Minerals DDG was released, its first evaluation will be considered a quasi
“baseline,” and available historical data will be used to estimate the expected rate of change.
Annual monitoring of results will indicate the rate of change at the outcome level, which may then be
used to trigger the appropriate timing of a subsequent evaluation. The monitoring plan keeps a
continuous eye on how impacts evolve in the rapidly changing environments of CAHRAs. The set of
monitoring indicators is proposed to be implemented annually. However, for a particular CAHRA and
mineral that is experiencing exceptionally high variability related to ANNEX II adverse impacts, it may
make sense to change the frequency of data collection, for example, to twice annually (every six
months). The data will serve to update a “Minerals DDG implementation” dashboard that would serve
to visualise the ‘change’ observed in CAHRAs with respect to Minerals DDG impact. In sum, the M&E
Framework thus calls for both annual monitoring and periodic evaluations.

Primary vs. Secondary Data, Levels of Rigour

Primary research involves the gathering of data first-hand. Secondary research involves the use of
data/information that originates from primary research conducted by others. Assessments C, D, E and
F feature primary research, and Assessments A, B, G and H feature secondary research (see
Table 7.2).
The level of rigour of the assessment methodology refers to the precision and thoroughness of the
methods employed. Rigour refers to the quality and source of the data and information (evidence) being
used, in addition to how the information is analysed and utilised. A rigourous evaluation would be
objective, precise, and have sufficient time and budget allocated to its execution. Applied research
involving scientific design, sampling, data collection and analysis is recommended as a minimum level
of rigour for the purposes of this M&E Framework.

Table 7.2. Primary vs. secondary data sources

Goal level Assessments Data sources
Ultimate Outcome A. Annex II Adverse Impacts Secondary data
B. Socio-Economic Conditions Secondary data
Intermediate Outcome C. Due Diligence Minerals Trade Primary data
D. Due Diligence Programmes Primary data
Immediate Outcome E. Downstream Minerals DDG uptake Primary data
F. Upstream Minerals DDG uptake Primary data
Context G. Global Minerals DDG context profile Secondary data
H. CAHRA context profile Secondary data

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Attribution vs. Contribution

In order to determine the potential impact of the Minerals DDG, one needs to establish attributable
action or influence premised on the Minerals DDG.
In general, a causal link between (parts of) an observed change and a specific intervention is
established though attribution or contribution.

Attribution: Attribution is determined when one may attribute observed changes to the intervention being
studied. As featured in the Glossary of Terms, addressing the “‘attribution problem’ implies both isolating and
accurately measuring the particular contribution of an intervention and ensuring that causality runs from the
intervention to the outcome” (Leeuw and Vaessen, 2009: xii). Relying on quantitative research methods, e.g.
Randomised Control Trials (RCT), the aim of attribution-premised studies is impact evaluation. Also, attribution
does not imply "sole attribution." One intervention may very well not have been the sole cause of the observed
change.

Contribution: Through ‘contribution analysis’, data on trends in outcomes and plausible explanatory factors of
observed trends are used to show that an intervention contributed to the outcome. One of two methods, which
do not rely on quantifying effects attributable to an intervention, are applied: (1) Causal Contribution Analysis
(CCA), and (2) the General Elimination Methodology (GEM). CCA relies on chains of logical arguments that are
verified through careful analysis (Mayne, 2001), a “non-quantitative way to solve the attribution problem” (Leeuw
and Vaessen, 2009: 31). Applying GEM involves (a) identifying possible explanations and then (b) gathering and
analysing data to see if the possible alternative explanations can be ruled out.

Depending on whether quantitative or qualitative methods were applied, either the term “attribution” or
the term “contribution” will be used to describe whether an effect was observed between elements
featured in the ToC, i.e. between the Minerals DDG, immediate, intermediate and ultimate outcome
levels (described in Table 7.1 and illustrated in the figure below. The relationship between each ToC
level will be assessed upon obtaining the results of each assessment section.
Where it would not possible to establish attribution, e.g. because a research design was implemented
that did not produce a sufficient number of observations to allow for relevant statistical analyses, non-
quantitative methods will be applied to establish contribution (namely, CCA or GEM). illustrates that
while the direction of action flows from the Minerals DDG to the CAHRA, attribution works the other
direction, and asks what, if any, changes to the ultimate outcome level can be traced back to the
Minerals DDG.
The intervention in question is the roll-out of the Minerals DDG. Fundamentally, we are interested in
learning how the Minerals DDG – as a standard – has influenced market actors, and how their
purchasing behaviour and other relevant supply chain engagement, in turn, is reflected in the work and
output of upstream due diligence programmes.

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Figure 7.2. Attribution or contribution between levels of action

Direction of Theory of Change action

Direction of attribution/contribution

Attribution / Attribution / Attribution /

Contribution Contribution Contribution

At the immediate level, the downstream and upstream corporate uptake of the Minerals DDG is
measured and assigned to six categories into which companies’ data (drawn from their public
representations) are inserted.
On-the-ground DDPs represent the intermediate level action. Since DDPs vary in scope and
configuration, one must parse the objectives and results of each in-scope DDP. To what extent do they
detect and potentiate the mitigation of adverse impacts as per the 12 Annex II priorities, while not
negatively affecting socio-economic conditions? Also, to what extent are they built around the priorities
of the Minerals DDG? The necessary data for that will be collected through a survey.
Finally, for the ultimate outcome level, what are the trends on the ground vis-a-vis the 12 Annex II
priorities and Socio-Economic Conditions (SEC) of miners? The necessary data for that will be collected
through a metadata analysis. (An example of this would be the analysis provided in the annual study
the U.S. Government Accountability Office does for sexual violence in the DRC). With this analysis, one
may judge to what extent the big picture is impacted by the Minerals DDG.
Based on anecdotal evidence, we may anticipate findings. With respect to the immediate outcome level,
since companies are – to varying degrees – implementing the Minerals DDG in their policies, systems,
programmes and processes, evidence for attribution may likely be found. Between the intermediate
DDM demand-supply level and the ultimate outcome level, while it may not be possible to isolate and
accurately estimate the effect of one particular contribution to a macro-level outcome, the intervention’s
contribution on the outcome is nonetheless understood and either anecdotally or empirically reported.

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While it is challenging to isolate and estimate the effect of the Minerals DDG’s implementation on
specific ultimate outcomes, the OECD expects to be able to collect a significant amount of data that
can at least affirm (or call into question) the theory of change and its underlying hypotheses. The data
used to evaluate the existence and strength of the relationships presented by the ToC will grow with
further data collection cycles, better reporting by industry (including in response to legislation and
market requirements), and supporting complementary studies if necessary and contingent on available
resources.

Identification of Data and Methodological Gaps

To understand the effects of a particular DDP in a given CAHRA, depending on the type of funding
mechanism, a DDP will undertake a programme evaluation on a regular basis. These may vary from a
simple process evaluation targeting beneficiaries to a robust impact evaluation design assessing the
program’s effectiveness in achieving its ultimate goals. Apart from the design, further quality variables
also hinge on the independence of the evaluation, evaluator competence, and whether the assessment
was on- or off-site.
The analysis of particular evaluations, or noting their absence (e.g. in a particular CAHRA), may occur
through an appropriate gap analysis, such as carried out through the deployment of the M&E
framework. The findings may help harmonise future research, and appropriate coordination may occur
through umbrella organisations such as the OECD in concert with partners (e.g. government agencies,
international organisations, and DDPs). Indeed, one of the objectives of the OECD Secretariat, through
piloting the Framework, will be to compile topics on which there are significant data gaps. The
Secretariat will therefore indicate such gaps when publishing the results of this framework’s
implementation, and liaise closely with DDPs and the research community in order to signal priorities
for future research and together address such gaps.
An inventory of relevant studies and data, with a particular focus on impact evaluations targeting the
subject of DDP performance, will reveal potential methodological gaps. Applicable studies may thus be
assessed for their rigour in order to improve future research on the effects of DDPs, including research
that employs quasi-experimental or experimental methods, which would include the employment of
comparison groups that enable evaluators to better isolate the effects of DDPs.
Three tables would reveal the basic specifications of applicable DDP evaluations. Table 7.3 pinpoints
the type of evaluation conducted, Table 7.4 the thematic coverage of the evaluation, and Table 7.5
practical evaluation considerations.

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Table 7.3. Type of evaluation

DDP name:
Check type of evaluation Time frame
implemented covered
Quasi-experimental designs (relatively robust)
1. Pre-test/post-test non-equivalent control group design with statistical
matching of the two groups.
2. Pre-test/post-test non-equivalent control group design with judgmental
matching of the two groups.
Quasi-experimental designs (less robust)
3. Pre-test/post-test comparison where the baseline study is not
conducted until the project has been under way for some time.
4. Pipeline control group design.
5. Pre-test/post-test comparison of project group combined with post-test
comparison of project and control group
6. Post-test comparison of project and control groups
Non-experimental designs (least robust)
7. Pre-test/post-test comparison of project group
8. Post-test analysis of project group
Note. Typology is based on Impact Evaluations and Development -- Nonie Guidance on Impact Evaluation (see Leeuw and Vaessen, 2009:
109)

Table 7.4. Ultimate outcome dimensions treated by evaluation

Ultimate outcome dimensions yes / no
Annex II Adverse Impacts
1. Serious Human rights abuses associated with extraction, transport, or trade of minerals
2. Direct or indirect support to non-state armed groups
3.Public or private security forces
4. Bribery and fraudulent misrepresentation of the origin of minerals
5. Money laundering
6. Non-payment of taxes, fees and royalties due to governments
Socio-economic conditions of miners
1. Livelihoods
2. Occupational health and safety
Source: Author’s own

Table 7.5. Evaluation process indicators

Indicator Response
1. On-site evaluation?
2. Days evaluator(s) spent on evaluation – desk
3. Days evaluator(s) spent on evaluation – on-site
4. Primary data collected?
5. # of interviews held, key informant (single respondent)?
6. # of interviews held, focus groups (multiple respondents)?
7. Independence of evaluator(s), i.e. reputation of external evaluation entity
Source: Author’s own

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8. Evaluation plan

The evaluation plan is based on the same cause-effect logic as the theory of change and the impact
framework. It involves scientific methods to launch inquiries that obtain data. Data, when analysed,
produce findings, that either refute or uphold the hypotheses as previously outlined.
After the initial evaluation or baseline has been completed, a better understanding will be gained of the
expected change that will occur in the defined cause-effect logic of the theory of change and how that
change will occur.

Methods

Scientific methods are employed by the M&E framework in order to empirically gauge the degree of
Minerals DDG implementation, as well as the effect of such implementation on CAHRAs.
The scientific approaches incorporated into this framework involve the:
• Incorporation of pertinent literature and theory;
• Performance of characterisations, including making observations, defining terms, and
describing measurements of the subject of inquiry;
• Posing empirically measurable research questions;
• Specification of research design, data sources, sampling, data collection and data analysis
methods for each assessment;
• Testing of hypotheses, including in order to be able to either confirm or refute them;
• Application of appropriate statistical analysis and visualisation of results.

Key Questions

Key questions guide the inquiry in accordance with each of the assessment sections featured in the
Framework. The answers to these questions challenge and/or confirm the hypothesis made in the
theory of change. The M&E framework poses the following key questions for the evaluation plan.

Table 8.1. Evaluation, key questions

Goal level Assessment section Key question
Ultimate A. Annex II Adverse To what extent are Annex II Adverse Impacts occurring in mining and
Outcome Impacts mineral processing areas in the CAHRA?
B. Socio-Economic What are the socio-economic conditions of miners in the CAHRA?
Conditions To what extent are miners and mining communities economically affected
by DDPs?
Intermediate C. Due Diligence What is the degree of demand for DDM from the CAHRA?
Outcome Minerals Trade
D. Due Diligence What is quality and scale of DDPs supplying minerals from the CAHRA?

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Goal level Assessment section Key question

Programmes
Immediate E. Downstream To what degree are companies in downstream mineral supply chains
Outcome Minerals DDG Uptake aligned with the OECD's 5-step due diligence framework?
F. Upstream Minerals To what degree are companies in upstream mineral supply chains aligned
DDG Uptake with the OECD's 5-step due diligence framework?
Context G. Global Trends What is the current backdrop of trends and emerging issues related to the
sourcing of minerals from CAHRAs at the international level?
H. CAHRA Context What are the current business and operating environment issues that affect
Profiles a company’s ability to conduct business and/or operate in the
sector/CAHRA?

Source: Author’s own

Types of Data Consulted

Designed to measure the impact of the Minerals DDG, this M&E framework presents a blueprint for
data collection, data analysis and generating evidence-based conclusions principally featuring four
types of data:
Corporate, self-reported data: To gauge the degree of OECD awareness and uptake, self-
reported data on the part of companies will be taken into account. Many companies around the
world claim to be applying the Minerals DDG to varying degrees. However, how exacting they
are in their Step 5 reporting, in particular whether they properly account for Annex II adverse
impacts and whether they make a plausible case that those risks are being actively managed
must be evaluated.
Empirical, economic data: While self-reported data is useful to gauge the maturity of due
diligence programmes, primary data is needed to assess market behaviour and the degree of
ground-level verification per CAHRA. Thousands of purchasing decisions happening on a daily
basis determine from whom, and at what price, minerals are bought. Ultimately, companies that
have issued a policy in line with Annex II commit themselves to a code of conduct that would
also be discernable at the aggregate level. To detect whether there is a cumulative response in
the market, this framework looks at macro-level economic indicators such as volumes of DDM
vs. non-DDM being exported from specific CAHRAs. If DD is being effectively implemented by
a critical mass of companies, this will also be reflected in the extent to which actors are engaging
with DDPs that work on the ground.
Annex II adverse impact data: This Framework also provides for the tracking of extraction-
level realities, in particular the prevalence of Annex II adverse impacts associated with in-
scoped CAHRA-mineral pairs.
Context data: Other circumstantial evidence provides the background to explain changes in
the impact metrics. Existing context-based metrics offer descriptive statistics and trends to build
a meaningful understanding that accounts for contextual factors when interpreting specific
impact measurements.
Companies’ actions do not occur in a vacuum. The actions of other stakeholders (especially national
governments) can directly and/or indirectly affect changes in Annex II impacts. For example, migration,
CSO participation in mine site monitoring, government requirements on mineral certification, etc. all
affect conflict risks in mines. These contextual factors are featured in the two context components of
the M&E framework and can be considered in the selection and prioritisation of CAHRA-mineral pairs
during the scoping exercise.

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Context is dynamic, not static, as the world is constantly changing. Understanding a company’s
incentives, influences and pressures in the larger “responsible sourcing context” provides insights into
a company’s direct and indirect, individual and/or collective actions, contributing to the overall impacts
achieved through the implementation of the Minerals DDG. As this M&E framework’s main focus is the
measurement and reporting on the Minerals DDG’s impact on mineral sourcing from CAHRAs, it is vital
to clarify the distinction between impact- and context-based metrics. These terms are not synonymous,
although they do often overlap.
Impact metrics are – by themselves – insufficient for the purpose of assessing performance. Impact
metrics are far more relevant when expressed against a backdrop of the changes in global-local
business and operating environments over time or changes that occur to relevant markets, norms and
institutions. A context-based backdrop is designed to provide a relevance check for impact metrics.
Context-based metrics can do that well; impact measures by themselves do not.
It is not the intention of the M&E framework to collect primary data on any context-based metrics, nor
to use such metrics to perform complex correlations and/or causal link analyses. The objective is to use
existing context-based metrics (indexes such as the WGI, etc.) to leverage descriptive statistics and
narrative to sense-check and help interpret specific impact measurements.
No company is an island. Other stakeholders can affect a company’s effectiveness through a complex
interaction of economic, social, political, technological and environmental activities. For companies to
implement the Minerals DDG with success in a particular CAHRA and/or with a particular conflict
mineral, they need to understand the relationships with other stakeholders that shape their environment.
This normally consists of:
• Understanding the company’s complex interactions in its market context, and with its primary
stakeholders.
• Analysing the kinds of market forces and influences that have the potential to impact business
success today and in the future.
• Identifying how to integrate this thinking into business strategy and planning to capture the most
value and ensure long-term success.
Furthermore, there is a two-way interaction between the business and its context. Society creates costs
and value for businesses and business creates value and costs for society. A contextual backdrop of
this larger environment can provide a greater understanding of analytics that frame a company’s
success/difficulty conducting business in its environment. As such, the M&E framework defines three
categories of context that provide a relevant backdrop to each of the Minerals DDG impact dimensions
as follows:
• Global trends provide the M&E Framework with an up-to-date backdrop on trends and emerging
issues relating to responsible sourcing of minerals from CAHRAs at a global level.
• CAHRA profiles as related to the operating environment:
‒ as it relates to mitigated minerals markets, providing the M&E framework with an up-to-
date backdrop of the external factors that affect a company’s ability to build and conduct
a successful business in a sector/CAHRA.
‒ as it relates to supply chain capacity, providing the M&E framework with a backdrop of
the factors that affect a company’s prospects and ability to operate in a sector/CAHRA.

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Evaluation Sections

The Evaluation plan of the M&E Framework features eight evaluation components represented by the
following eight assessment sections. Figure 8.1 illustrates how the eight assessment sections are
related to and overlaid on the theory of change.

Figure 8.1. Assessment sections as related to the Theory of Change

Global
Context
(Section G)

CAHRA
Context
(Section H)

The following eight assessment sections are combined to implement the evaluation component of the
M&E framework.

Section A: Annex II Adverse Impacts

Assessment type: Evaluation

Key question(s): To what extent are Annex II Adverse Impacts occurring in mining and
mineral processing areas in the CAHRA?

Research design: Meta-analysis of existing research and data, longitudinal. The conduct of
a meta-analysis of scientific surveys undertaken on Annex II adverse
impacts would allow for big-picture trends to be revealed. In order to be
relevant, the occurrence of Annex II Adverse Impacts will be
geographically linked to mineral extraction and trade routes (e.g.,
intercommunal violence and human rights abuses in a non-mineral
extraction area of a country would not be in-scope). Sub-national level
data will be employed to this end.

Data sources Secondary data sources, examples of which are featured in Table 8.2.)

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The inclusion threshold would constitute internationally recognised/cited

datasets, scientific surveys and investigative journalism/research reports
from reputable sources.

Unit(s) of analysis This assessment will encompass three units of analysis (see Figure 8.2):
• general population living within the in-scope CAHRA;
• worker/miner population within the in-scope CAHRA;
• organisation (upstream supply chain actor).

Key metric(s): Prevalence / incidents will be taken for each indicator.

Sampling: Given the reliance on secondary data, the meta-analysis would defer to
the sampling methods employed in the primary research.

Assessment themes: As per Annex II adverse impacts:

• Serious abuses associated with mining activities;
• Direct or indirect support to non-state armed groups;
• Public or private security forces;
• Bribery and fraudulent misrepresentation of mineral origin;
• Money laundering;
• Non-payment of taxes, fees and royalties due to government.

Indicators: This assessment features 12 indicators – one per Annex II adverse

impact.

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Figure 8.2. Units of analysis

Table 8.2. Annex II Adverse Impact indicators

Minerals DDG Annex II Indicator Data source examples (for the DRC)
1. Serious human rights abuses – Serious abuses associated with extraction, transport or trade of minerals:
(i) Torture, cruel, inhuman and Prevalence of torture, cruel, inhuman • Case-file information (e.g. UN
degrading treatment and degrading treatment (cases per Organization Stabilization Mission –
1 million inhabitants) If relying on MONUSCO (n.d.) and UN (2020a)
• DDP incident reporting
crowdsourced data, calculate • “Specific instances” brought to NCPs
prevalence. – offices set up by governments that
have adhered to the OECD
Guidelines for Multinational
Enterprises
(ii) Forced or compulsory labour Prevalence of forced / compulsory • Global Slavery Index (Walk Free
labour (cases per 1 million Foundation, 2018)
inhabitants). • ILO (n.d.a): Forced labour, modern
slavery and human trafficking
• DDP incident reporting
• “Specific instances” brought to NCPs
– offices set up by governments that
have adhered to the OECD
Guidelines for Multinational
Enterprises

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Minerals DDG Annex II Indicator Data source examples (for the DRC)
(iii) Worst forms of child labour Prevalence of worst forms of child • ILO (n.d.b): Child Labour
labour (cases per 1 million • United Nation Children Fund
inhabitants). (UNICEF)’s Multiple Indicator
Cluster Survey (UNICEF, n.d.)
• ILO, UNICEF and World Bank
(2018)
• Alliance 8.7 (n.d.)
• DDP incident reporting
• “Specific instances” brought to NCPs
– offices set up by governments that
have adhered to the OECD
Guidelines for Multinational
Enterprises
(iv) Gross human rights violations Prevalence of widespread sexual • Demographic and Health Survey
/ widespread sexual violence violence (cases per 1 million (ICF, n.d.)
• Harvard Humanitarian Initiative /
inhabitants). United Nations Development
Programme (UNDP) surveys (e.g.
HHI, n.d.)
• Reported Cases of Sexual Violence
in South Kivu Province, DRC –
Ministry of Gender, DRC
Government
• Kivu Security Tracker (KST, n.d.)
(v) War crimes / serious violations Conflict-related deaths per 1 million • UN Group of Experts reports (UN,
of international humanitarian law / inhabitants. n.d.)
crimes against humanity / • Non-Governmental Organisation
genocide (NGO) reports (Amnesty
International, n.d.; HRW, n.d.;
Enough, n.d.)
• Armed Conflict Location and Event
Data Project (ACLED, n.d.)

2. Direct or indirect support to non-state armed groups

i) Illegally controlled mine sites, Documented adverse incidents* of • Supply chain incident reports
transportation routes, trading hubs illegally controlled mine sites, (reported as part of corporate Step 5
reports)
transportation routes, trading hubs. • 3rd party incident reporting
ii) Illegally taxed or extorted money Documented adverse incidents of
or minerals at mine site access illegally taxed or extorted money or • UN Group of Experts reports
points, transportation routes • Investigative journalism / research
and/or trading hubs minerals at mine site access points, reports (e.g. on illegal trade)
transportation routes and/or trading • "Specific instances" brought to
hubs. National Contact Points (NCPs) –
offices set up by governments that
iii) Illegally taxed or extorted Documented adverse incidents of have adhered to the OECD
intermediaries, export companies illegally taxed or extorted Guidelines for Multinational
and/or international traders Enterprises
intermediaries, export companies
and/or international traders. • DDP incident reporting
3.Public or private security forces
Documented adverse incidents • Investigative journalism / research
regarding security forces in the past reports
• DDP incident reporting
3-5 years.
4. Bribery and fraudulent misrepresentation of the origin of minerals

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Minerals DDG Annex II Indicator Data source examples (for the DRC)
Documented adverse incidents • Investigative journalism / research
regarding bribery and fraudulent reports
misrepresentation in the past 3-5 • OECD Portal for Supply Chain Risk
Information (OECD, 2021)
years. • DDP incident reporting
5. Money laundering
Documented adverse incidents • Investigative journalism / research
involving money laundering in the reports
past 3-5 years. • OECD Portal for Supply Chain Risk
Information (OECD, 2021)
• DDP incident reporting
6. Non-payment of taxes, fees and royalties due to governments
Documented adverse incidents • Investigative journalism / research
regarding the non-payment of taxes, reports
fees and royalties due to • OECD Portal for Supply Chain Risk
Information (OECD, 2021)
governments in the past 3-5 years.
• DDP incident reporting
• Extractive Industries Transparency
Initiative (EITI, 2020)

Note: * The interpretation of data collected for indicators on a discrete basis (i.e. as documented adverse incidents) as opposed to aggregate
prevalence should give consideration to the severity of such incidents, including if they are of an irremediable character.

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Section B: Socio-Economic Conditions of Miners and Mining Communities

Assessment type: Evaluation

Key question(s): • What are the socio-economic conditions of miners and mining
communities in the CAHRA?
• To what extent are miners and mining communities economically
affected by DDPs?

Research design: • Cross-sectional study consisting of a survey of in-scope DDPs;

• Meta-analysis of independent surveys of miners and mining
communities.
A meta-analysis of information on socio-economic conditions would allow
for a comparison between the SEC of miners associated with a DDP to
those who are not.

Data sources Two data sources are envisioned:

• Primary data provided by DDPs;
• Secondary data sources featuring surveys of miners and mining
communities.

Unit(s) of analysis The population of miners within the in-scope CAHRA, both miners working
in participation with a DDP and those who are not. The benefit to the wider
mining communities will be inferred.

Key metric(s): Livelihoods and Occupational Health & Safety (OHS) are the main themes
of the SEC section.

Sampling: Given the reliance on secondary data, the meta-analysis would rely on the
sampling methods employed in the primary research.

Assessment themes: The Minerals DDG is premised on the notion that cutting the link between
mineral production and trade and adverse human rights and corruption-
related impacts can help countries benefit from their natural resources.
Furthermore, the Minerals DDG includes specific risk mitigation measures
intended to provide greater opportunities for formal trade to largely
informal parts of the sector. DDPs, however, may affect the terms and
conditions on which minerals are traded. These dynamics are closely
bound up with the implementation of the Minerals DDG and may have
consequences for the socio-economic welfare of miners and mining
communities. Studies of DDP implementation should uncover how DDPs
influence SEC outcomes related to the above issues. Livelihood impacts
will be measured through miner income, gender ratios, savings and cell
phone ownership. OHS of miners is measured through injury and fatality
data as well as through the use of mercury (in the case of gold mining).
The difference between the DDP values and national averages will
provide a way to compare the performance of each in-scope DDP.

Indicators: This assessment features 11 indicators.

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Table 8.3. SEC indicators

Indicators Data source examples
(for the DRC)
Livelihoods
1. Mining income per month (disaggregated by gender) compared to • In-scope DDPs
national average GNI. • National statistics
2. Gender parity for income derived from mining. • Reports, e.g. IPIS (2020)
3. Household income (month) from mining as a percentage of total • Academic studies, e.g. Radley
household income. (2020), Geenen et al. (2020), etc.
4. Income derived from mining in DDP Areas of Operation, on the part of • Disclosures of payments
DDP miners (compared to non-mining community members).
5. Payments to government from mining activity (e.g. fees for mining,
exploration and export licenses; royalties; taxes; payments).
6. Cell phone ownership of DDP participant households, compared to
national average.
7. Gender gap for cell phone ownership of DDP participant households
versus national average.
8. Average % of savings over average income for participating surveyed
community members (F/M).
OHS
9. Instances of workplace death (per 100 workers, disaggregated by • In-scope DDPs
gender).
10. Instances of workplace injuries (per 100 workers, disaggregated by
gender).
11. Gold produced without mercury as percentage of that produced with
mercury, in Areas of Operation (AO).

Section C: Due Diligence Minerals Trade

Assessment type: Evaluation

Key question(s): What is the degree of DDM demand from the CAHRA?

Research design: Cross-sectional, longitudinal, data aggregation.

Data sources Primary and secondary sources will be consulted:

• Primary data collection involving in-scope mineral DDPs.
• Secondary data collection involving total in-scope minerals production
values.
In the event there are diverging numbers between the various sources of
data (e.g. between national statistics, UN, EITI, etc.), expert estimations
will be considered.

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Unit(s) of analysis The export of in-scope mineral(s) flowing through DDPs (see typology in
Glossary). Only DDPs involved in mineral sourcing (and thus collecting
related data) will be included in these metrics.

Key metric(s): Three key metrics are targeted:

• Volumes of DDM vs. non-DDM produced (typically a measure of
minerals transacted at the mine or upstream trader)
• Volumes of DDM vs. non-DDM transacted at level of export (officially
and estimated)
• Volumes of DDM vs. non-DDM refined outputs imported into third
countries

Sampling: For the export level, given a finite number of official exporters cooperating
with institutionalised DDPs, it is both opportune and feasible to assess
them all (i.e. sample the universe). For the total mineral production values,
official data will be triangulated with other sources of evidence, e.g. expert
estimations, EITI, etc., where the credibility of the officially reported data
has been questioned.

Assessment themes: Measuring the variable volumes of DDM vs. non-DDM transacted at
export level, and the ratio of these two volume points over time, will, to a
large extent, ceteris paribus, indicate the efficacy of the aggregate due
diligence and procurement actions on the part of in-scope companies.

Indicators: This assessment features seven indicators.

Table 8.4. Minerals trade indicators

Indicators Data Sources

1. Type and volume/weight of DDM Primary data collection involving all in-scope mineral DDPs.
produced.
2. Type and volume/weight of non-DDM Official data triangulated with other sources of evidence, e.g. expert
estimations, EITI (2020), etc.
produced in the CAHRA.
3. Type and volume/weight of DDM Primary data collection involving all in-scope mineral DDPs.
exported (export level).
4. Type and volume/weight of non-DDM Official data triangulated with other sources of evidence, e.g. expert
estimations, EITI (2020), etc.
exported (export level) in the CAHRA.
5. Type and volume/weight of DDM Official import data in jurisdictions with due diligence legislation that
regulate imported metals; exchanges and market makers; corporate
refined metal outputs imported into self-reporting and annual reports on operations.
third countries.
6. Type and volume/weight of non-DDM Official import data; corporate self-reporting and annual reports on
operations.
refined metal outputs imported into
third countries.
7. Quantity (#) of buyers. Primary data collection involving all in-scope mineral DDPs.

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Section D: Quality and Scale of Due Diligence Programmes

Assessment type: Evaluation

Key question(s):
What is the quality and scale of DDPs supplying minerals from CAHRAs?

Research design: A cross-sectional, longitudinal research design is envisioned that surveys

in-scope DDPs (as with Section C), as well as the producer-level
participants of the DDP (DDP Tier 1) for triangulation purposes.

Data sources Primary data collection involving in-scope mineral DDPs/producer-level.

Unit(s) of analysis The primary units of analysis are: (1) DDP organisation-level, and (2)
producer (cooperative/miner) level.

Key metric(s): The following key metrics are featured in this assessment:
• Types of DDPs, i.e. incidents per adverse impact (DDM1-DDM12)
identified, followed-up and mitigated (see Figure 8.3 and Table 8.6)
• Quality of DDP with regard to processes and outcomes, in particular
with regard to DDP stakeholder participation and control of leakage-
in (see Table 8.5)

Sampling: All DDPs operating in CAHRAs within the scope of the study or comprised
of members or programme participants sourcing from such CAHRAs
(universe) are in-scope. A literature review and the snowball method will
yield the list of operational DDPs in each selected CAHRA.

Assessment themes: DDPs are queried in order to assess their value addition with respect to
mitigating Annex II Adverse Impacts. Each DDP is categorised according
to its objectives vis-à-vis Annex II, i.e. DDM1-DDM12 (see Figure 8.3).
DDPs are requested to provide mineral-specific data on incidents
identified and followed-up/mitigation actions. In addition, the
membership/participation, employment related to minerals production and
trade covered by such DDPs, and the extent of stakeholder consultation
for on-the-ground risk mitigation purposes are featured in order to capture
the support/patronage for – and overall scale of – each in-scope DDP. The
data collected through this section can then be applied and/or linked to
the Section C study on trade volumes.

Indicators: This assessment features 15 indicators.

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Figure 8.3. Due Diligence Programmes and relevant impacts

Table 8.5. DDP indicators

Indicators Data Sources
Processes
# of DDP members or participants in the form of companies, cooperatives or other In-scope DDPs
supply chain actors directly participating in the programme(through direct participation
in minerals traded through the programme, explicit use of programme data or providing OECD Alignment
Assessments
financial support or paying fees to the DDP).
# participating mine workers/estimated employment of participating mine sites and
upstream trade hubs prior to export (only applicable to DDPs that directly involve
upstream actors).
# people participating annually in stakeholder consultations related to risk mitigation.
Level of alignment with the Minerals DDG assessed through an OECD Alignment
Assessment if available.
Did the DDP track mineral sales and compare them to corresponding financial flows?
(In order to detect and deter fraud, illicit financing, financial crimes, and leakage-in –
fraud being a primary risk as per point 4 of Annex II).
Did the DDP establish and maintain a complete registration system of miners and mine
sites? (Accounting for the principal mining inputs through the registration of miners and
mine sites allows one to control for fraud, illicit financing, misrepresentation and
leakage-in, fraud being a primary risk as per point 4 of Annex II).

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Did the DDP triangulate data on relevant events from multiple sources (as data validity
is enhanced through triangulation)?
Did the DDP publicly report meta-level data (as meta-data reporting enhances visibility
of the initiative)?
Outcomes
# of incidents identified per adverse impact (see Table 8.6). Primary data collection
involving all in-scope
# of incidents followed-up per adverse impact (see Table 8.6). mineral DDPs.
# of incidents mitigated per adverse impact (see Table 8.6).
Percent (%) of Annex II-relevant incidents, managed through a DDP, associated with
a particular mineral, which has been followed-up upon/mitigated, per adverse impact.
Percent (%) of Annex II-relevant incidents, managed through a DDP, associated with
a particular mineral, which has been followed-up upon/mitigated, aggregated.
Average DDM price at export level per volume/weight unit ($).
Average % of refined metal product price, per volume/weight unit at point of export.

Table 8.6. Incidents detected vs followed-up vs mitigated through each in-scope DDP
Adverse impact variable # of relevant # of relevant # of relevant
incidents incidents incidents
identified followed-up on mitigated
through DDP through DDP through DDP
system system system
Human-rights serious abuses – Serious abuses associated with extraction, transport or trade of minerals
Incidents of torture, cruel, inhuman and # of relevant # of relevant # of relevant
incidents incidents incidents
degrading treatment.
Incidents of forced / compulsory labour. # of relevant # of relevant # of relevant
incidents incidents incidents
Incidents reported of worst forms of child labour. # of relevant # of relevant # of relevant
incidents incidents incidents
Incidents reported of sexual violence. # of relevant # of relevant # of relevant
incidents incidents incidents
Incidents reported of conflict-related deaths. # of relevant # of relevant # of relevant
incidents incidents incidents
Direct or indirect support to non-state armed groups
Incidents reported of illegally controlled mine # of relevant # of relevant # of relevant
sites, transportation routes, trading hubs. incidents incidents incidents
Incidents reported of illegally taxed or extorted # of relevant # of relevant # of relevant
money or minerals at mine site access incidents incidents incidents
points, transportation routes and/or trading
hubs.
Incidents reported of illegally taxed or extorted # of relevant # of relevant # of relevant
intermediaries, export companies and/or incidents incidents incidents
international traders.
Public or private security forces
Incidents related to public or private security # of relevant # of relevant # of relevant
forces. incidents incidents incidents
Bribery and fraudulent misrepresentation of the origin of minerals

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Incidents related to bribery and fraudulent # of relevant # of relevant # of relevant

misrepresentation. incidents incidents incidents
Money laundering
Incidents related to money laundering. # of relevant # of relevant # of relevant
incidents incidents incidents
Non-payment of taxes, fees and royalties due to governments
Incidents related to non-payment of taxes, fees # of relevant # of relevant # of relevant
and royalties due to governments. incidents incidents incidents
total total total

Section E: Downstream Minerals DDG Uptake

Assessment type: Evaluation

Key question(s): To what degree are companies in the downstream minerals supply chain
demonstrating uptake of the OECD's 5-step due diligence framework?

Research design: Cross-sectional, longitudinal study

Data sources Primary data collection based on corporate self-reporting (e.g. Step 5
reports or similar), operationalising the items stipulated for disclosure as
per OECD Step 5 and other relevant information on sourcing practices
that may feature as part of corporate disclosures. Relevant corporate
representations are located in various reporting sources, e.g.:
• Company websites
• Conflict minerals policy
• Mineral sourcing policy
• Responsible sourcing of raw materials policy
• Code of conduct
• Supplier code
• Sustainability report
• Integrated annual report
• Devices Sustainability Report
• U.K. Modern Slavery Statement
• California Transparency in Supply Chains Statement
• U.S. Form SD filings
• RMI Reasonable Country of Origin Inquiry (RCOI) Data

Unit(s) of analysis The downstream section of the supply chain features the OEM level,
situated at the far end (often consumer-facing) of the supply chain. OEMs
are selected as the unit of analysis based on their disproportionate
purchasing power vis-à-vis the lower tiers.

Key metric(s): A company’s implementation of Minerals DDG Steps 1-5, through the
perspective of Step 5 reporting. The data collected in Note: * Collectively,
G20 members represent around 80% of the world’s economic
output, 66% of the global population, and 75% of international
trade. As of 2020, there are 20 members of the group: Argentina,
Australia, Brazil, Canada, China, European Union, France,

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Germany, India, Indonesia, Italy, Japan, Mexico, Republic of

Korea, Russia, Saudi Arabia, South Africa, Turkey, United
Kingdom, and United States (https://g20.org/).

Table 8.7 will allow any given company under study to be classified
according to the typology offered in the ToC. The case frequency in each
category will inform the degree of Minerals DDG uptake at the aggregate
level. In addition, discrepancies between Annex II-relevant allegations and
company self-reporting will also be analysed.

Sampling: As assessing the thousands of OEMs that represent the universe of such
companies (even if one selected just one country) would simply not be
feasible given the TOR-specified parameters, we suggest taking a
statistically representative sample of companies at the OEM level A
random sampling method to derive a representative sample is employed
to select industries, sectors, or all companies with products containing
minerals, depending on the M&E scope. To this end, it would first need to
be determined what type of company has products that contain an in-
scope mineral: in the case of tin, tungsten, tantalum and gold (3TG), an
approach featuring a Standard Industrial Classification (SIC) analysis is
advised as performed by Bayer and Hudson (2017). Findings would then
be extrapolated to non-U.S. markets. In order to proxy the supply chain
impact that companies would be achieving through their Minerals DDG
update (generating an “impact score”), their uptake could be multiplied by
their income, spend, or purchasing power. While one supply chain study
(Mizuno, 2016) focused on companies within the G8, extending the inquiry
to the Group of 20 (G20) would allow for the inclusion of other large
mineral-demand markets, e.g. China and India.* Upon extrapolating the
sample data, the findings may then be generalised for entire industries,
sectors or all companies.

Assessment themes: The Minerals DDG features reporting stipulations in Step 5 that a company
properly implementing the Minerals DDG will follow. The degree of
corporate disclosure may then be consequently assessed as an indication
of a company’s implementation of the Minerals DDG (see Table 8.7).

In order to determine whether a downstream company engages in

enhanced risk management, one should examine the extent to which a
company features: the use of leverage, contract conditions, capacity-
building of suppliers, DDP participation, grievance mechanisms and direct
upstream engagement on Annex II (see Table 8.7 and Table 8.8).

Furthermore, a gap analysis will point to any discrepancies between self-

reported procurement/sourcing behaviour of a given company and
allegations it faces on risks and adverse impacts as per the 12 dimensions
of Annex II (covering the period of the interval between evaluations).

Indicators: This assessment section features Downstream Step 5 indicators as

itemised in Table 7.7.

Note: * Collectively, G20 members represent around 80% of the world’s economic output, 66% of the global population, and 75% of
international trade. As of 2020, there are 20 members of the group: Argentina, Australia, Brazil, Canada, China, European Union, France,
Germany, India, Indonesia, Italy, Japan, Mexico, Republic of Korea, Russia, Saudi Arabia, South Africa, Turkey, United Kingdom, and United
States (https://g20.org/).

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Table 8.7. Downstream Step 5 indicators

Downstream Minerals DDG uptake indicators Annex II / Annex II
III / Gold / III / 3T
suppl. suppl.
Step 1: Management Systems
1 The company mentioned the OECD Minerals DDG in public document(s). -- --
2 The company published a policy for responsible minerals sourcing / trade. p. 113 p. 53
Note: The policy should be sourcing and/or raw materials-focussed.
3 The company’s policy takes into account the six main adverse impacts as per the Annex II p. 17 p. 17
model policy, disaggregated by impact.
4 The company seeks to direct suppliers to source through SORs that have successfully -- --
undergone an independent third-party audit (e.g. as provided by RMI’s RMAP, LBMA, RJC)
or second-party audit.
5 The company’s supply chain policy was incorporated into commercial contracts and/or p. 17, 74, p. 17, 38,
written agreements with suppliers. 99 40
6 The commercial contracts and/or written agreements with suppliers contained flow-down -- --
provision clauses in which the company’s supply chain policy is made relevant in lower tiers.
Note: the Minerals DDG states that companies should “build leverage, over suppliers who
can most effectively prevent or mitigate the identified risk.” (p.18)
7 The company’s contracts contained due diligence performance clauses p. 104
8 The company monitored the compliance with its supply chain policy in commercial contracts p. 74, 99, p. 40
with suppliers. 104
9 The company had in place a supplier escalation process in the event of non-compliance -- --
with the company’s supply chain policy.
10 The company explained “the management structure responsible for the company’s due p. 113 p. 53
diligence and who in the company is directly responsible.”
Note: The description can include departments in charge, persons in charge, involvement
of executives.
11 The company described internal systems of transparency, information collection and control p. 113 --
over the supply chain.
Note: For downstream companies, this includes a system of transparency and control that
companies use to identify SORs, all countries of origin and transit of the minerals supplied
to SORs in their supply chain.
12 The company described “the company’s database and record-keeping system.” p. 113 --
13 The company had an operational-level grievance mechanism in line with the Minerals p. 17 p. 17
DDG under the period of review.
Note: The grievance mechanism may be a general mechanism (for all sorts of grievances)
as long as it is specifically for the supply chain AND is mentioned in minerals
documents/policies. Examples would be email addresses or a hotline.
Step 2: Risk assessment
14 The company described “the steps taken to identify refiners in their supply chain.” p. 113 p. 53
15 The company participated in or supported “independent third-party audits” of SORs’ due p. 106, p. 47
diligence practices (for example through industry programme membership). 110
Note: Such programmes include the RMI, LBMA, and RJC.
16 The company participates, through membership and/or financial support, in an upstream -- --
DDP (see DDP criteria in the Glossary of Terms).
17 The company required its suppliers to participate in a due diligence programme through -- --
membership and/or financial support.
18 The company assessed the due diligence practices of the smelters/refiners in its supply p. 113 p. 53
chain, including disclosing the “published list of qualified smelters/refiners through industry
validation schemes conforming to the due diligence processes” recommended in the
Minerals DDG.
Note: Among other features, such industry schemes must include Step 4 audits of
smelters/refiners.

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19 The company explained “the methodology of [its] supply chain risk assessments.” p. 113 --
20 The company disclosed “the actual or potential risks identified.” p. 113 --
Step 3: Risk management
21 The company described “the steps taken to manage risks.” p. 113 --
22 The company included “a summary on the strategy for risk mitigation in the risk p. 113 --
management plan.”
Note: This should include how companies are responding to specifically identified
risks/incidents.
23 The company assisted “suppliers in building capacities with a view to improving due p. 104, p. 43, 45
diligence performance.” (p. 17) 113
24 The company described “the involvement of affected stakeholders.” p. 113 --
25 The company disclosed “the efforts made […] to monitor and track performance for risk p. 113 p. 46
mitigation.”
Note: The Minerals DDG e.g. recommends that companies: “Implement the risk
management plan, monitor and track performance of risk mitigation, report back to
designated senior management and consider suspending or discontinuing engagement with
a supplier after failed attempts at mitigation.” (p. 46)
26 The company disclosed all the instances and results of follow-up to evaluate significant and p. 113 --
measurable improvement.
27 The company disclosed “the number of instances where the company has decided to p. 112 --
disengage with suppliers and/or supply chains, consistent with Annex II, without disclosing
the identity of those suppliers, except where the company deems it acceptable to do so in
accordance with applicable laws."
28 The company accounted for its mitigation action, structured according to the six main p. 20 p. 20
adverse impacts as per the Annex II model policy.
Note: The six “significant adverse impacts,” “associated with extracting, trading, handling
and exporting minerals from conflict-affected and high-risk areas” are (1) “serious abuses
associated with the extraction, transport or trade of minerals”; (2) “direct or indirect support
to non-state armed groups”; (3) “public or private security forces”; (4) “bribery and fraudulent
misrepresentation of the origin of minerals”; (5) “money laundering”; and (6) non-payment
“of taxes, fees and royalties due to governments” (OECD, 2016: 20).
29 The company has no unaddressed allegations relating to the six main adverse impacts as -- --
per the Annex II model policy.
30 The company has no unaddressed allegations relating to the six main adverse impacts as -- --
per the Annex II model policy, which contradict public representation(s) the company has
made.

Assessing in-scope companies for their corporate supply chain behaviour allows one to further
categorise them. The following six basic actor types are featured in the figure below.

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Figure 8.4. Company due diligence and purchasing modes

Non purchase Enhanced risk

Unconditional engagement Partial risk management
No due diligence De-risking purchasing management
Company Company
Company Company declines proceeds with
Company proceeds declines to Company
proceeds with to purchase and purchases under
with mineral purchase/suspends purchases on
mineral purchases completely conditions and/or
purchases without purchasing certain condition of DDP
without carrying disengages risk mitigation
conditions despite minerals but participation, but
out DD (de-risking) actions in line with
evidence of invests in risk without DDG-
Annex II risks mitigation/harm related conditions DDG
remediation (including DDP)

High responsibility

Medium responsibility

Low responsibility

The indicators used for such classification are listed in the table below. Best judgment should be used
to categorize companies based on uptake sources.

Table 8.8. Downstream supply chain actor classification

Supply Chain
Actor(s)
Actor’s name
1. No Due Diligence
a. The company provided no representation or evidence of OECD-premised due diligence. Yes/No
Source
b. The company did not mention Minerals DDG in public document(s). Yes/No
Source
2. De-risking
a. The company’s representations stated they avoid engaging in, doing business in, or sourcing Yes/No
from certain countries. Source
b. The company’s representations stated they avoid engaging with – or sourcing from – certain Yes/No
production types (e.g. ASM). Source
3. Unconditional purchasing
a. The company’s representations indicated that while they carried out some DD, they did not Yes/No
assess on-the-ground conditions before purchases of minerals or intermediate forms. Source
b. The company’s representations did not indicate that, if sourcing from CAHRAs, their supply Yes/No
chains exclusively purchased DD-minerals. Source
4. Non-purchase engagement
a. The company’s representations indicated that they responsibly dis-engaged from their Yes/No
CAHRAs supply chains as they found conditions as per Annex II paragraphs 1 and 3. Source
b. The company’s representations indicated that if they found conditions as per Annex II Yes/No
paragraphs 1 and 3, the company invested in harm reduction and/or risk remediation. Source

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5. Partial risk management

a. Company’s representations mentioned explicit engagement of DDPs (e.g. in terms of Yes/No
membership, volumes and engagement on incidence monitoring and resolution). Source
b. The company indicated that they purchased minerals (or intermediate forms) on condition of Yes/No
source material associated with a DDP, but did not engage further. Source
6. Enhanced risk management
a. The company’s representations indicated that they responsibly dis-engaged from their supply Yes/No
chains leading to CAHRAs when they found conditions as per Annex II paragraphs 1 and 3. Source
b. The company’s representations indicated that they prudently engaged supply chains in Yes/No
conditions according to paragraphs 10 and 14. Source
c. The company’s representations indicated engagement across a spectrum of actions, which included the following
themes captured through the following indicators:
• Use of leverage (Table 8.7: 4 to 9) Yes/No
Source
• Contract conditions (Table 8.7: 4 to 7) Yes/No
Source
Yes/No
• Capacity-building of suppliers (Table 8.7: 23)
Source
• Grievance mechanisms (Table 8.7 13) Yes/No
Source
• Direct engagement on Annex II-cited phenomena (Table 8.7: 2, 3, 21 to 28) Yes/No
Source
Yes/No
• DDP participation or provision of financial support to DDPs (Table 8.7: 16)
Source

Section F: Upstream Minerals DDG Uptake

Assessment type: Evaluation

Key question(s): To what degree are companies in the upstream minerals supply chain
demonstrating uptake of the OECD's 5-step due diligence framework?

Research design: Cross-sectional, longitudinal study

Data sources Primary data collection based on corporate self-reporting (Step 5 reports
or equivalent).

Unit(s) of analysis The upstream section of the supply chain features, at the top of the
upstream supply chain (according to the Minerals DDG typology), the
SOR level, which comprises the main unit of analysis of this assessment.
Positioned at the ultimate supply chain control point, smelters, refiners,
and diamond cutters exercise comparatively high discretionary power
from whom, and on what terms, they source their minerals. Given this
pinch point, with a finite number of smelters/refiners (for each mineral) or
cutter (for diamonds), it is feasible to construct an accurate list of all SoRs
for each mineral. This is done by triangulating data from various SoR
assurance programs (RMI, LBMA, RJC, etc.), trade data and industry
publications. For some minerals, the list would need to be established
from scratch.

Key metric(s): Minerals DDG Steps 1-5, through the perspective of Step 5 disclosure. As
with the downstream section, the data collected will allow any given
company under study to be classified according to the typology offered in
the TOC (See Table 8.9) The case frequency in each category will inform

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the degree of Minerals DDG uptake.

Sampling: Wherever feasible, all registered SOR-level actors, as per the to-be-
defined scope of the M&E Framework, will be surveyed for the purpose of
this section assessment. For example, in the 3TG space there were 332
SORs in 2018. In the cobalt industry, there were 52 cobalt refiners (both
fine and crude cobalt refiners as per the RMI taxonomy) in 2018 (Bayer et
al., 2018).

Assessment themes: The Minerals DDG features reporting stipulations in Step 5 that a
company properly implementing the Minerals DDG will follow. The degree
of corporate disclosure may then be consequently assessed as an
indication of a company’s implementation of the Minerals DDG (see
Table 8.9).

This narrow assessment scope for the stipulated disclosure is required as

a given company can implement the full letter and spirit of the Minerals
DDG, but opt to still only provide the minimum elements stipulated for
disclosure by Step 5 according to their signalling strategy (transparency ≠
quality of due diligence and purchasing behaviour).

In order to determine whether an upstream company engages in

enhanced risk management, the extent to which an upstream company
carries out on-the-ground risk assessments, capacity-building, ASM
formalisation, child labour remediation, engaging multi-stakeholder efforts
to assist vulnerable populations, tracking and disclosing payments to
government, and formalisation of security arrangements is assessed (see
Table 8.9).

Included in the uptake assessment is an analysis of Annex II-relevant

allegations against the company originating from a credible source, and
how the company responded, if at all. Each of the 12 dimensions in Annex
II are in scope. This analysis then reveals a pattern regarding the type and
frequency of allegations concerning relevant corporate behaviour.

Indicators: This assessment section features the following indicators.

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Table 8.9. Upstream Step 5 indicators

Upstream Minerals DDG uptake indicators Annex II / Annex II /
III / Gold III / 3T
suppl. suppl.
Step 1: Management Systems
1 The company mentioned the OECD Minerals DDG in public document(s). -- --
2 The company published a due diligence policy for responsible minerals sourcing / trade. p. 111 p. 52
Note: The policy should be sourcing and/or raw materials focused.
3 The company’s policy takes into account the six main adverse impacts as per the Annex II p. 17 p. 17
model policy, disaggregated by impact.
4 The company supports ASM formalisation either through: (a) direct engagement with ASM p. 115, p. 25, 27
workers or operators, including through commercial and/or sourcing relationships with such 116, 117
entities, or (b) indirect engagement, for example by providing support to partnerships
seeking to formalise ASM.
5 The company explained “the management structure responsible for the company’s due p. 111 p. 52
diligence and who in the company is directly responsible.”
Note: Description can include departments in charge, persons in charge, involvement of
executives.
6 The company described internal systems of transparency, information collection and p. 111 p. 52
control over the supply chain, explaining how this operates.
Note: Upstream companies must have a chain of custody or traceability system if they
have identified red flags.
7 The company described “the company’s database and record keeping system and p. 111 p. 52
explain[ed] the methods for identifying all suppliers, down to the mine of origin and the
methods for sharing the information about due diligence throughout the supply chain.” (p.
111)
8 The company developed or supported a grievance mechanism and provided evidence p. 17 p. 17
attesting to the fact that it is operational.
Note: The grievance mechanism may be a general mechanism (for all sorts of
grievances) as long as it is specifically for the supply chain AND is mentioned in minerals
documents/policies. Examples would be email addresses or a hotline.
Step 2: Risk assessment
9 The company carried out on-the-ground risk assessment(s) and published risk assessment -- p. 52
using Annex II categories, including the disclosure of aggregate results.
10 The company explained “how the company identified red flag operations or red flags in p. 111 --
their supply chain, including the verifications of supplier representations proportional to
risk.”
11 The company described the “red flags identified in the supply chain.” p. 113 --
12 The company described “the steps taken to map the factual circumstances of those red p. 111, --
flag operations and red flagged supply chains.” 112
13 The company outlined “the methodology, practices and information yielded by the on-the- p. 112 --
ground assessment team, including whether and how the company collaborated with other
upstream companies and how the company ensured that all joint work duly takes into
consideration circumstances specific to the individual company.”
14 The company disclosed “the actual or potential risks identified” using Annex II categories. p. 112 --
15 The company participates, e.g. through membership, in an upstream DDP (see DDP -- --
criteria in the Glossary of Terms).
Step 3: Risk management
16 The company described “the steps taken to manage risks.” p. 112 p. 52
17 The company included “a summary of the strategy for risk mitigation in the risk p. 112 p. 52
management plan.”
Note: The plan and/or summary should include how companies are responding to
specifically identified risks and incidents.
18 The company itself – or through participation in a relevant programme– carried out actions p. 116 --

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in order to prevent or remediate child labour (e.g. vocational training, psychosocial support,
awareness-raising, other forms of training, support for formal education).
19 The company itself – or through participation in a relevant programme– engaged in multi- p. 22, 64, p. 22
stakeholder efforts to assist vulnerable populations. 114
20 The company disclosed “information on payments made to governments in line with EITI p. 111 p. 52
criteria and principles (where relevant).”
21 The company ensured that security arrangements with public or private security forces p. 22, 23, p. 22, 23,
were formalised and made only in accordance with the Voluntary Principles on Security 116, 117 55, 56, 59
and Human Rights.
22 The company described “capability-training, if any, and the involvement of affected p. 112 p. 52
stakeholders,” held in the last 12 months.
23 The company disclosed “the efforts made by the company to monitor and track p. 112 p. 52
performance for risk mitigation and all the instances and results of follow-up after 6 months
to evaluate significant and measurable improvement.” (p. 112)
24 The company disclosed “the number of instances where the company has decided to p. 112 --
disengage with suppliers and/or supply chains, consistent with Annex II, without disclosing
the identity of those suppliers, except where the company deems it acceptable to do so in
accordance with applicable laws.”
25 The company has no unaddressed allegations against it relating to the six main adverse -- --
impacts as per the Annex II model policy.
26 The company has no unaddressed allegations against it relating to the six main adverse -- --
impacts as per the Annex II model policy, which contradict public representation(s) the
company has made.
Step 4: Audits
27 The company published “the summary audit reports of refiners with due regard taken of p. 112 p. 53
business confidentiality and other competitive or security concerns.”
28 The company published an audit report that includes SOR “details and the date of the p. 112 --
audit.”
29 The company published an audit report that includes “the audit activities and methodology.” p. 112 --
Note: As “defined in Step 4(A)(4), where an Industry Programme or Institutionalised
Mechanism in conformance with [the] Guidance and as defined in Step 4(B)(2) has not
published these details.”
30 The company published an audit report that includes “the audit conclusions.” p. 112 --
Note: As “defined in Step 4(A)(4), as they relate to each step in this Guidance.”

The supply chain engagement of upstream companies will be classified according to the same six
categories as the downstream companies (see Figure 8.5), assessed through the criteria in Table 8.10.
Best judgment should be used to categorize companies based on uptake sources.

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Figure 8.5. Company DD and purchasing modes

Non purchase Enhanced risk

Unconditional engagement Partial risk management
No Due Diligence De-risking purchasing management
Company Company proceeds
Company Company declines Company proceeds Company
declines to with purchases
proceeds with to purchase and with mineral purchases on
purchase/suspends under conditions
mineral purchases completely purchases without condition of DDP
purchasing certain and/or risk
without carrying disengages conditions despite participation, but
minerals but mitigation actions
out DD (de-risking) evidence of without DDG-
invests in risk in line with DDG
Annex II risks mitigation/harm related conditions (including DDP)
remediation

High responsibility

Medium responsibility

Low responsibility

Table 8.10. Upstream supply chain actor classification

Supply Chain
Actor(s)
Actor’s name
1. No Due Diligence
a. The company provided no representation or evidence of OECD-premised due diligence. Yes/No
Source
b. The company did not mention Minerals DDG in public document(s). Yes/No
Source
2. De-risking
a. The company’s representations stated they avoid engaging in, doing business in, or sourcing Yes/No
from certain countries. Source
b. The company’s representations stated they avoid engaging with – or sourcing from – certain Yes/No
production types (e.g. ASM). Source
3. Unconditional purchasing
a. The company’s representations indicated that while they carried out some DD, they did not Yes/No
assess on-the-ground conditions before purchases of minerals or intermediate forms. Source
b. The company’s representations did not indicate that, if sourcing from CAHRAs, their supply Yes/No
chains exclusively purchased DD-minerals. Source
4. Non-purchase engagement
a. The company’s representations indicated that they responsibly disengaged from their CAHRAs Yes/No
supply chains as they found conditions as per Annex II paragraphs 1 and 3. Source
b. The company’s representations indicated that if they found conditions as per Annex II Yes/No
paragraphs 1 and 3, the company invested in harm reduction and/or risk remediation. Source
5. Partial risk management
a. Company’s representations mentioned explicit engagement of DDPs (e.g. in terms of Yes/No
membership, volumes and engagement on incidence monitoring and resolution). Source
b. The company indicated that they purchased minerals (or intermediate forms) on condition of Yes/No
source material associated with a DDP, but did not engage further. Source

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6. Enhanced risk management

a. The company’s representations indicated that they responsibly disengaged from their supply Yes/No
chains leading to CAHRAs when they found conditions as per Annex II paragraphs 1 and 3. Source
b. The company’s representations indicated that they prudently engaged supply chains in Yes/No
conditions according to paragraphs 10 and 14. Source
c. The company’s representations indicated engagement across a spectrum of actions, which included the following
themes captured through the following indicators:
• On-the-ground risk assessments ( Yes/No
Source
• Table 8.9: 9, 10)
• Capacity-building ( Yes/No
Source
• Table 8.9: 18, 19, 22)
• ASM formalisation ( Yes/No
Source
• Table 8.9: 4)
• Child labour remediation ( Yes/No
Source
• Table 8.9: 17, 18)
• Engaging multi-stakeholder efforts to assist vulnerable populations Yes/No
Source
• Table 8.9: 19)
• Tracking and disclosing payments to governments ( Yes/No
Source
• Table 8.9 20)
• Formalising security arrangements ( Yes/No
Source
• Table 8.9: 21)

Section G: Global Minerals DDG Context Profile

Assessment type: Evaluation

Key question(s): What is the current context on trends and emerging issues relating to
responsible sourcing of minerals from CAHRAs at the international level?

Research design: Literature review and synopsis of most current reports on global trends
most directly related to the demand of minerals studied in Assessment
Section C.

Data sources Secondary data sources (indexes), examples of which featured in

Table 8.11.

Unit(s) of analysis National-level phenomena and market trends related to in-scope

CAHRAs.

Key metric(s): Data to be used from referenced literature, operationalised with indicators
in Table 8.11.

Sampling: Authoritative sources are consulted for this assessment.

Assessment themes: This assessment will review the identified and expanded sources dealing
with relevant global trends related to the demand of minerals studied in
Assessment Section C.

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Indicators: This assessment features 8 domains (see Table 8.11).

Table 8.11. Global Minerals DDG context indicators

Domains Data sources
A. Normative and legal drivers of mineral supply chain due diligence
Global standards and instruments • OECD and UN instruments on responsible business conduct
incorporating responsible business conduct • OECD and UN conventions
(OECD, UN)
• National legislative repositories
Global conventions and international law • OFAC lists; FCPA and UK Bribery Act
relevant to responsible business conduct
• Mapping coverage of in-scoped supply chains by prospective
Regional and national legislation and international normative drivers of due diligence
regulations
Sanctions and legal judgments targeting or
affecting entities involved in or linked to the
minerals trade
B. Market drivers of mineral supply chain due diligence
Rules mandating supply chain due diligence • London Metal Exchange (LME), Responsible Jewellery
in mineral supply chains set forth by industry Council (RJC), London Bullion Market Association LBMA),
associations and exchanges for members Dubai Multi Commodities Centre (DMCC), Responsible
and listed entities Mineral Initiative (RMI), World Gold Council (WGC), etc.
• Mapping coverage of in-scoped supply chains by prospective
market drivers of due diligence
Market behaviour & investment trends • Deloitte: Annual trend analysis on the future of mining (Swart,
Insights, strategies, and forward-thinking 2020), recurring desk review
analysis
Demands from communities and investors

Section H: CAHRA Context Profiles

Assessment type: Evaluation

Key question(s): What are the current issues related to the business and operating
environment that affect a company’s ability to conduct business and/or
operate in the sector/CAHRA and may influence the way it conducts due
diligence?

Research design: Literature review and supporting data informing descriptive analysis of
most current national index reports most directly related to the impacts at
the intermediate and ultimate outcome levels. These index domains
provide a backdrop to the identified impact indicators.

Data sources Secondary data sources (indexes), as recommended in Table 8.12

Unit(s) of analysis National-level statistics for each identified and studied CAHRA.

Key metric(s): Data on regulatory, financial, formalisation and the security environment

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in CAHRA are derived from indexes, featuring the themes in Table 8.12.

Sampling: Authoritative sources are consulted for this assessment.

Assessment themes: Using identified validated global indexes, the research will review sections
and related data corresponding to referenced impact indicators.
Descriptive statistics, along with relevant narrative, will provide a CAHRA
profile as a backdrop to referenced impact indicators.

Indicators:
This assessment features 17 domains (see Table 8.12).

Table 8.12. In-scope context profile domains

Domains Data sources
Regulatory environment
Voice and accountability • World Bank: Worldwide Governance Indicators (World
Political stability and absence of violence Bank Group, n.d.a)
Government effectiveness • World Bank: Country Policy and Institutional
Assessment (World Bank Group, n.d.b)
Regulatory quality
• Transparency International: Corruption Perceptions
Rule of law
Index (Transparency International, 2021)
Control of corruption
Economic environment
Ease of doing business • ILO informality data
Employment informality • Global Financial Inclusion (FINDEX) database
Financial inclusion • World Bank: Mineral rents (% of GDP)
Mining and metals sector as share of GDP • World Bank: Ease of Doing Business (World Bank
Presence of hyperinflation (rate of local currency Group, n.d.c)
inflation of more than 50% per month)
Formalisation environment
Defined regulatory environment for ASM • Ministry of mines implementing the UNITAR
Established supply chain procedures Formalization Framework (de Haan and Turner, 2018)
Adequate enabling environment • African Mining Legislation Atlas
Presence and enforcement of gender and child • Other desk-based research
protection norms and regulations
Security environment
Level of safety and security • Institute for Economics and Peace: Global Peace Index
Level of conflict (IEP, 2020).
Level of militarisation • University of Heidelberg: Conflict Barometer (HIIK,
2019).
• OECD “States of Fragility” Reports (OECD, 2018b).

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Evaluation Report

The purpose of an impact assessment and/or evaluation report is to communicate outcomes and impact
in relation to goals and/or hypothesis and a theory of change. A comprehensive evaluation report should
contain the following topics, addressed to a broad audience.

Discuss the findings per assessment, answering each research question

The results of studies will be compared in order to draw meaningful links and conclusions on the
strength of such links if they exist. For example, the DDP trade volume data (e.g. X kg of mineral
transacted per year) may be compared with documented action regarding Annex II incidents (e.g. X
incidents identified, Y incidents followed-up, and Z incidents mitigated).
Of further interest would be to qualify the volumes of DDP transacted in terms of whether or not the
DDP also exercised control over leakage-in/fraud through mineral sales tracking and comparison to
corresponding financial flows. In addition, one may compare the volumes of DDP transacted to DDP
participation in terms of membership, number of mine workers, and stakeholder risk mitigation
consultation.
An inter-section comparison is particularly important for the findings of Sections C and D (due diligence
minerals trade and quality and scale of due diligence programmes). For example, while studies on
uptake (E and F) may reveal data about the levels of uptake specific to upstream and downstream
supply chain segments, they can also stand alone as studies, each with a corresponding node along
the theory of change.
Only by assessing how Sections C and D relate to one another, however, can we develop a clear
understanding of the overall trade in responsibly sourced minerals. In other words, we need to build an
understanding of both quality of due diligence programmes, and the scale (volumes of minerals traded
through such programmes) to have a complete picture.

Table 8.13. Quantitative measures of DDP quality and scale

Measure(s) of volumes per year Measure(s) of DDP quality and scale, per year

• X incidents identified
• Y incidents followed-up
• Z incidents mitigated
X kg of mineral(s) transacted
• DDP membership (#)
• Mine workers (#)
• Stakeholder risk mitigation consultation (#)

Note. The quantitative measures are the result of calculating the square root of the multiplication between “kg of mineral” and the
corresponding indicator in Error! Reference source not found..

Further measures of quality include the following four binary measures.

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Table 8.14. Qualitative measures of DDP quality and scale

Further measures of quality Yes / No
Mineral flow tracking and comparison with corresponding financial flows
Registration system of miners and mine sites
Data triangulation (one or more sources to observe the same phenomenon)
Public reporting of meta-level data

Evaluate TOC hypotheses

As a next step, once the key questions have been answered, the M&E Framework will be in a position
to validate or reject the ToC hypotheses, and offer explanations for any difference. Table 8.15 further
details how the assessment sections relate to the specific hypothesis identified.

Table 8.15. Assessment related to hypothesis clusters

Assessments Sections Hypothesis Cluster #
Section A: Annex II Adverse Impacts 3, 6
Section B: Socio-Economic Conditions of Miners 4
Section C: Due Diligence Minerals Trade 1, 2, 5, 6
Section D: Due Diligence Programmes 2, 3, 4
Section E: Minerals DDG Downstream Uptake 1, 3, 4
Section F: Minerals DDG Upstream Uptake 1, 3, 4
Section G: Minerals DDG Global Profile 5
Section H: CAHRA Context Profile 6

Conduct further research and discuss results of attribution/contribution

analyses

Thereafter, further analysis between the sections may be conducted, premised on the following
questions.

Table 8.16. Evaluation, further key questions

Further key questions

1. Is downstream and upstream Minerals DDG uptake, with respect to comprehensiveness and content, concordant
or discordant?

2. If Minerals DDG uptake is relatively “robust” at the aggregate level (according to typology), is that condition
reflected in the demand for DDM?

3. Is there more DDM supply than demand (i.e. a gap between supply and demand) or vice versa?

4. How do the quality and scale compare to the volumes of DDM minerals traded through DDPs?

5. If DDPs quality and scale are significant, is the impact reflected in Annex II Adverse Incidents and miners SEC
conditions?

6. Are the socio-economic trends comparable to the Annex II Adverse Impacts trends?

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7. Are current trends and context in mining reflected in the way downstream and upstream actors conduct business?

8. Is the CAHRA context affecting downstream and upstream actors in their ability to conduct business?

9. Is the CAHRA context influencing the way downstream and upstream actors conduct due diligence?

Measuring the phenomena as per the primary questions, over time, longitudinal observations are
potentiated.

Table 8.17. Evaluation, longitudinal questions

Longitudinal questions

1. Are changes in Minerals DDG uptake correlated with the demand for DDM?

2. Is downstream DDP participation correlated with DDM demand?

3. Is upstream DDP participation correlated with DDM demand?

4. Is enhanced risk management in the downstream correlated with DDM demand?

5. Is enhanced risk management in the upstream correlated with DDM demand?

6. Are requirements/conditions for suppliers to participate in DDP correlated with DDM demand?

7. Are requirements/conditions for suppliers to undertake enhanced risk management correlated with DDM demand?

8. To what degree is the demand for DDM from the CAHRA changing over time?

9. To what degree is the supply for DDM from the CAHRA changing over time?

10. Is the supply of DDM correlated with a change of ANNEX II Adverse Impacts?

11. Is the supply of DDM correlated with a change in socio-economic conditions of miners and mining communities?

12. Is a global demand for in-scope minerals correlated with DDM demand?

13. Is a change at the immediate outcome level correlated with changes at the ultimate outcome level?

Answering these questions will provide further evidence to support or refute the M&E Framework’s
hypotheses.
Table 8.18 summarises the indicators used for the evaluation assessment.

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Table 8.18. Evaluation Framework

Outcome Dimension of
Minerals DDG outcome Indicators Data type Frequency Data source(s)
level impact
Ultimate Companies in the Annex II Adverse See Table 8.2 Secondary See Table 8.2
Outcome mineral supply chain do Impacts data 3-5 years
not contribute to serious
human rights abuses
and conflict
Companies in the Socio-Economic See Table 8.3 Primary 3-5 years
mineral supply chain Conditions of data/ Data from DDPs
support the socio- miners and mining Secondary Independent surveys of miners and mining
economic conditions of communities data communities
miners and mining
communities
Intermediate Minerals-based DDM Trade See Table 8.4. Primary 3-5 years Data collection involving in-scope DDPs
Outcome industries applying data/ Official data triangulated with other sources of
OECD based due Secondary evidence, e.g. expert estimations, EITI, etc.
diligence data
DDPs See Table 8.5 Primary data 3-5 years In-scope DDPs

Immediate Industries align their Increased See Note Primary data 3-5 years Sample data collection on in-scope mineral-
Outcome programmes to the downstream supply sourcing companies
See Table 8.7
Minerals DDG both chain capacity
upstream and See Table 8.8
downstream

Increased See Table 8.9 Primary data 3-5 years Data collection on in-scope mineral-sourcing
upstream supply companies at the SOR level
chain capacity See Table 8.10

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Outcome Dimension of
Minerals DDG outcome Indicators Data type Frequency Data source(s)
level impact
Global Backdrop of global Normative and Secondary 3-5 years OECD and UN instruments on responsible
Context trends influencing legal drivers of See Table 8.11 data business conduct; UN and OECD conventions;
industry decisions and mineral supply National legislative repositories; OFAC lists; FCPA
investments chain due diligence and UK Bribery Act; Mapping coverage of in-
scoped supply chains by prospective international
normative drivers of due diligence
Market drivers of Secondary 3-5 years London Metal Exchange (LME), Responsible
mineral supply data Jewellery Council (RJC), London Bullion Market
chain due diligence Association LBMA), Dubai Multi Commodities
Centre (DMCC), Responsible Mineral Initiative
(RMI), World Gold Council (WGC), etc.; Mapping
coverage of in-scoped supply chains by
prospective market drivers of due diligence;
Deloitte: Annual trend analysis on the future of
mining (Swart et al., 2020)
CAHRA Backdrop of CAHRA Regulatory See Table 8.12 Secondary 3-5 years World Bank: Worldwide Governance Indicators
Context operating environments environment data (World Bank Group, n.d.a); World Bank: Country
influencing industry Policy and Institutional Assessment (World Bank
decisions and Group, n.d.b); Transparency International:
behaviours Corruption Perceptions Index (Transparency
International, 2021)
Economic Secondary 3-5 years ILO informality data; Global Financial Inclusion
environment data (FINDEX) database; World Bank data: Mineral
rents (% of GDP); World Bank: Ease of doing
business (World Bank Group, n.d.c)
Formalisation Secondary 3-5 years Ministry of mines implementing the UNITAR
environment data Formalization Framework (de Haan and Turner,
2018); African Mining Legislation Atlas
Security Secondary 3-5 years Institute for Economics and Peace: Global Peace
environment data index (IEP, 2020); University of Heidelberg:
Conflict Barometer (HIIK, 2019); OECD “States of
Fragility” Reports (OECD, 2018b)

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9. Monitoring plan

Methods

This Minerals DDG M&E Framework further establishes measures for routine, annual monitoring and
reporting on DDP outcomes, as well as the evolution of the interplay between CAHRA and at-risk minerals.
The monitoring plan is based on the same cause-effect logic as the Theory of Change as featured in the
evaluation plan and provides indicators to be measured on an annual basis. After the initial evaluation
baseline has been completed, the monitoring plan keeps a continuous eye on how these impacts evolve
in the rapidly changing environments of CAHRA. This agile understanding will allow for improvements to
the periodic evaluation process, and, as such, regularly update the overall M&E plan. Thus, the monitoring
plan itself represents an annual, ongoing, iterative process.

Key Questions

Key questions guide the monitoring inquiry, which are associated with the Theory of Change. They are
similar to those asked in the evaluation plan and are aimed to not only monitor the key impacts associated
with the identified DDPs, but also monitor the CAHRA. The monitoring plan of the M&E Framework poses
the following key questions.

Table 9.1. Key Monitoring questions

Goal level Section Key questions
Ultimate A. Annex II adverse To what extent are Annex II Adverse Impacts occurring?
Outcome impacts
B. Socio-Economic What are the socio-economic conditions of miners?
Conditions
Context H. CAHRA Profiles What are changes in business and operating environments that affect a
company’s ability to conduct business and/or operate in the CAHRA?

Table 9.2. Summary monitoring-indicators

Goal level Section Indicators
Ultimate Outcome A. Annex II Adverse Impacts 19 indicators: one per Annex II sub-point
B. Socio-Economic Conditions 10 indicators: one per SEC sub-point
Context H. CAHRA Profiles 2 indicators: Global Peace Index
3 indicators: Formalization Framework
2 indicators: Worldwide Governance Indicators

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Section A: Annex II Adverse Impacts

Assessment type: Monitoring

Key question(s): To what extent are Annex II Adverse Impacts occurring?

Research design: Cross-sectional, longitudinal study

Data sources Primary data, annual invitation for DDPs to self-report.

Unit(s) of analysis DDPs, which engage actors (e.g. ASM mining cooperatives) at the
production-level of the upstream supply chain.

Key metric(s): Primary data collection using self-reporting approach using indicator(s) in
Table 9.3.

Sampling: An invitation for due diligence programmes to self-report will be launched

annually. DDPs may opt to self-include in this process.

Assessment themes: The monitoring indicators at the Annex II ultimate outcome level will serve
as a backdrop for the annual incident reporting. The change over time in
reported incidents and their nature will provide a window into the changing
supply chain impact landscape. Of particular interest is the change in
prevalence and nature of Annex II Adverse Impacts in the supply chain as
reported by DDPs in the upstream supply chain.

Indicators: This assessment features Annex II-premised indicators.

Table 9.3. Monitoring indicators for Annex II Adverse Impact risks

Adverse impact variable # of relevant # of relevant # of relevant
incidents incidents incidents
identified followed-up on mitigated
through DDP through DDP through DDP
system system system
Human-rights serious abuses – Serious abuses associated with extraction, transport or trade of minerals
Incidents of torture, cruel, inhuman and # of relevant # of relevant # of relevant
incidents incidents incidents
degrading treatment.
Incidents of forced / compulsory labour. # of relevant # of relevant # of relevant
incidents incidents incidents
Incidents reported of worst forms of child # of relevant # of relevant # of relevant
incidents incidents incidents
labour.
Incidents reported of sexual violence. # of relevant # of relevant # of relevant
incidents incidents incidents
Incidents reported of conflict-related deaths. # of relevant # of relevant # of relevant
incidents incidents incidents
Direct or indirect support to non-state armed groups
Incidents reported of illegally controlled mine # of relevant # of relevant # of relevant
incidents incidents incidents
sites, transportation routes, trading hubs.
Incidents reported of illegally taxed or # of relevant # of relevant # of relevant
incidents incidents incidents
extorted money or minerals at mine site

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Adverse impact variable # of relevant # of relevant # of relevant

incidents incidents incidents
identified followed-up on mitigated
through DDP through DDP through DDP
system system system
access points, transportation routes and/or
trading hubs.
Incidents reported of illegally taxed or # of relevant # of relevant # of relevant
incidents incidents incidents
extorted intermediaries, export companies
and/or international traders.
Public or private security forces
Incidents related to public or private security # of relevant # of relevant # of relevant
forces. incidents incidents incidents
Bribery and fraudulent misrepresentation of the origin of minerals
Incidents related to bribery and fraudulent # of relevant # of relevant # of relevant
incidents incidents incidents
misrepresentation.
Money laundering
Incidents related to money laundering. # of relevant # of relevant # of relevant
incidents incidents incidents
Non-payment of taxes, fees and royalties due to governments
Incidents related to non-payment of taxes, # of relevant # of relevant # of relevant
incidents incidents incidents
fees and royalties due to governments.
total total total

Section B: Socio-Economic Conditions of Miners

Assessment type: Monitoring

Key question(s): What is the change in socio-economic conditions of miners and their
communities as reported by DDPs in the upstream value chain?

Research design: Cross-sectional, longitudinal study.

Data sources Two data sources are envisioned:

• Primary data, short-form survey of DDPs;
• Secondary data sources featuring surveys of miners and mining
communities.

Unit(s) of analysis The upstream section of the supply chain features only the bottom of the
upstream supply chain, being the ASM mining cooperatives as part of
participating DDPs.

Key metric(s): OHS conditions and income levels (see Table 9.4).

Sampling: An invitation for DDPs to self-report will be launched annually. DDPs can
opt to self-include in this process.

Assessment themes: The indicators of the SEC ultimate outcomes will further inform the annual

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monitoring reports. The change over time in reported socio-economic

impacts on miners and their communities will provide a window into the
changing supply chain impact landscape.

Indicators: This assessment features 11 indicators (see Table 9.4).

Table 9.4. Monitoring indicators for Socio-Economic Conditions

Indicators Data sources examples
(for the DRC)
Livelihood
Mining income per month (disaggregated by gender) compared to • In-scope DDPs
national average GNI. • National statistics
Gender parity for income derived from mining. • Reports, e.g. IPIS (2020)
Household income (month) from mining as a percentage of total • Academic studies, e.g. Radley
household income.
Income derived from mining in DDP Areas of Operation, on the part (2020), Geenen et al. (2020), etc.
of DDP miners (compared to non-mining community members). • Disclosures of payments
Payments to government from mining activity (e.g. fees for mining,
exploration and export licenses; royalties; taxes; payments).
Cell phone ownership of DDP participant households, compared to
national average.
Gender gap for cell phone ownership of DDP participant households
versus national average.
Average % of savings over average income for participating
surveyed community members (F/M).
OHS
Instances of workplace death (per 100 workers, disaggregated by • In-scope DDPs
gender).
Instances of workplace injuries (per 100 workers, disaggregated by
gender).
Gold produced without mercury as percentage of that produced with
mercury, in Areas of Operation (AO).

Section H: CAHRA Context Profiles

Assessment type: Monitoring

Key question(s): What are the ongoing business and operating-environment matters that
affect a company’s ability to conduct business and/or operate in the
sector/CAHRA?

Research design: Review of most current national index reports.

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Data sources
Secondary data sources (indexes), examples of which featured in
Table 9.5.

Unit(s) of analysis National-level statistics for each identified and studied CAHRA.

Key metric(s): Data to be used is drawn from identified indexes. No primary data
collection needed.

Sampling: Index sections providing a targeted backdrop to identified Impact

indicators.

Assessment themes: Using identified, validated global indexes, this monitoring exercise will
review themes and data corresponding to referenced Minerals DDG
indicators. Descriptive statistics along with relevant narrative will provide
a backdrop to the ultimate outcome topics

Indicators: This assessment features 7 indicators.

Table 9.5. Monitoring indicators for in-scope CAHRA Contexts

Indicators Data sources
Regulatory environment
Political stability and absence of violence • World Bank: Worldwide Governance Indicators (World
Control of corruption Bank Group, n.d.a)
• Transparency International: Corruption Perceptions Index
(Transparency International, 2021)
Formalisation environment
Defined regulatory environment for ASM • UNITAR Formalization Framework (de Haan and Turner,
Adequate enabling environment 2018)
Presence and enforcement of gender and child • African Mining Legislation Atlas
protection
Security environment
Level of terrorism impact • University of Heidelberg: Conflict Barometer (HIIK, 2019)
Levels of conflict • Global Peace Index (IEP, 2020)
• OECD "States of Fragility Reports" (OECD, 2018b)

Monitoring Reports

Monitoring, in the context of the Minerals DDG, is the ongoing process of collecting and analysing essential
data in order to stay informed about ongoing developments and efforts in the sector. While the periodic
Evaluation assessments of the Minerals DDG take a careful look at its impact over time, the monitoring
process that keeps a finger on the pulse in between these periodic evaluations. When a new evaluation
process starts, evaluators would review the results of past monitoring cycles undertaken since the previous
evaluation and use them to determine the focus of the new evaluation process. In other words, Monitoring
informs Evaluation and allows the overall M&E process to be effective.
Monitoring reports should be produced at an annual interval.

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A quality monitoring report should include the following:

● The changes observed during the monitoring cycle concerning the featured topics;
● Updates in the status of Minerals DDG implementation;
● An estimate of the number of direct and indirect beneficiaries, relative to target groups;
● Current (or potential) issues concerning the ToC’s ultimate outcome level;
● A description of any problems or constraints that affect implementation (and proposed solutions)
and their proposed (or implemented) solutions;
● Plans and schedules for subsequent monitoring cycles.
The reports are based on a standardized format as per the M&E Framework, which helps track changes
over time.
The monitoring indicators to be implemented are presented in table Table 9.6 below.

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Table 9.6. Monitoring Framework

Outcome Minerals DDG outcome Dimension of Indicators Data type Frequency Data sources
level impact
Ultimate Companies in the mineral Annex II Adverse See Table 9.3 Primary data Annual Short-form survey of DDPs.
Outcome supply chain do not contribute Impacts
to serious human rights abuses
and conflict support
Companies in the mineral Socio-Economic See Table 9.4 Primary data/ Annual • Short-form survey of DDPs.
supply chain support the socio- Conditions of Secondary
economic conditions of miners miners data • Independent surveys of miners and mining
and mining communities communities.
CAHRA Backdrop of CAHRA operating Regulatory • Political stability and Secondary Annual World Bank: Worldwide Governance Indicators
Context environments influencing environment data (World Bank Group, n.d.a); Transparency
industry decisions and absence of violence International: Corruption Perceptions Index
behaviours • Control of corruption (Transparency International, 2021)
Formalisation • Defined regulatory Secondary Annual UNITAR Formalization Framework (de Haan
environment data and Turner, 2018); African Mining Legislation
environment for Atlas
ASM
• Adequate enabling
environment
• Presence and
enforcement of
gender and child
protection
Security • Level of terrorism Secondary Annual University of Heidelberg: Conflict Barometer
environment data (HIIK, 2019); Institute for Economics and
impact Peace: Global Peace Index (IEP, 2020); OECD
• Level of conflict "States of Fragility Reports" (OECD, 2018b).

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Glossary

The following operational definitions and typologies are applied in this document.
Armed groups: As per the definition of the OECD (2016: 66) Minerals DDG: “non-state armed groups or
their affiliates who:
• illegally control mine sites or otherwise control transportation routes, points where minerals are
traded and upstream actors in the supply chain; and/or
• illegally tax or extort money or minerals at points of access to mine sites, along transportation
routes or at points where minerals are traded; and/or
• illegally tax or extort intermediaries, export companies or international traders.”
Artisanal and Small-scale Mining (ASM): “Formal or informal mining operations with predominantly
simplified forms of exploration, extraction, processing, and transportation. ASM is normally low capital
intensive and uses high labour-intensive technology” (OECD, 2016: 65).
Attribution: The isolation and accurate assessment of “the particular contribution of an intervention, and
ensuring that causality runs from the intervention to the outcome” (Leeuw and Vaessen, 2009: 21).
Chain-of-custody: A record of the sequence of entities which have custody of minerals as they move
through a supply chain.
Conflict-affected and high-risk areas (CAHRAs): The OECD (2016: 66) characterises CAHRAs as
“Areas identified by the presence of armed conflict, widespread violence, including violence generated by
criminal networks, or other risks of serious and widespread harm to people. Armed conflict may take a
variety of forms, such as a conflict of international or non-international character, which may involve two
or more states, or may consist of wars of liberation, or insurgencies, civil wars. High-risk areas are those
where there is a high risk of conflict or of widespread or serious abuses as defined in paragraph 1 of Annex
II of the Minerals DDG. Such areas are often characterised by political instability or repression, institutional
weakness, insecurity, collapse of civil infrastructure, widespread violence and violations of national or
international law.”
Contribution: Where it is not possible to isolate and accurately determine attribution between the outcome
and an intervention (i.e. where it is not possible to quantitatively determine the degree/extent of causal
attribution”), but one can make “chains of logical arguments that are verified” through a causal contribution
analysis, one may use the term contribution (Leeuw and Vaessen, 2009: 19, 31).
Credible, independent 3rd party verifier: A qualified entity (which is not the producer nor the buyer),
which validates that a given event, condition, or practice has or has not taken place in accordance with set
standards.
Direct or indirect support to armed groups: “‘Direct or indirect support’ to non-state armed groups or
public or private security forces through the extraction, transport, trade, handling or export of [minerals]
includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical
assistance or equipment to, non-state armed groups, public or private security forces or their affiliates who:

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• illegally control mine sites or otherwise control transportation routes, points where gold is traded
and upstream actors in the supply chain; and/or
• illegally tax or extort money or gold at points of access to mine sites, along transportation routes
or at points where gold is traded; and/or
• illegally tax or extort intermediaries, export companies or international traders” (OECD, 2016: 66).
Downstream: The actors positioned in supply chain segments following the smelter/refiner tier of the
supply chain, up to and including original equipment manufacturers (OEMs), consumer-facing companies
and retailers.
Due Diligence (DD): OECD-premised due diligence constitutes: “an on-going, proactive and reactive
process through which companies can identify, prevent, mitigate and account for how they address their
actual and potential adverse impacts as an integral part of business decision-making and risk management
systems. Due diligence can help companies ensure they observe the principles of international law and
comply with domestic laws, including those governing the illicit trade in minerals and United Nations
sanctions” (OECD, 2016: 66-68).
A sub-category of DD is “Supply Chain Due Diligence,” which the OECD defines as follows: “With specific
regard to supply chain due diligence for responsible mineral sourcing, risk-based due diligence refers to
the steps companies should take to identify, prevent and mitigate actual and potential adverse impacts
and ensure that they respect human rights and do not contribute to conflict through their activities in the
supply chain” (OECD, 2016: 70).
Due Diligence Minerals (DDM): Minerals that are a product of a DDP (as defined below).
Due Diligence Programme (DDP) 5: At a minimum, a DDP is an initiative that invests in risk identification,
mitigation and/or harm remediation and meets all of the criteria in the table below. Individual upstream
company due diligence initiatives are in-scoped as DDPs for the purposes of this Framework if they feature
the criteria set out in this typology. Measuring the quality of these in-scope DDPs is performed in Chapter
7.4, Section D.

Table 9.7. Due Diligence Programme (DDP) criteria for M&E Framework studies
# DDP in-scoping criteria Explanation
1. Is comprised of at least one upstream mineral Engagement of the upstream, and mineral exploitation in particular,
producing or trading actor.* is a DDP focus.
2. Leverages collective/collaborative action Collective action creates synergies otherwise not exploited and is
between actors party to the initiative. important for influencing supply chains.
3. Makes and/or abides by a public commitment Alignment with the Minerals DDG, and targeting at least one of its
to conduct due diligence-related activities on Annex II adverse impacts is basic to in-scope DDPs.
at least one Annex II Adverse Impact..
4. Tracks events and/or grievances (“incidents”) The identification of incidents at their point of origin is a
at the mineral origin until point of export linked prerequisite for effectively responding to risks.
to one or more ANNEX II Adverse Impacts.
5. Manages and responds to risks by conducting A commensurate reaction, premised on the Minerals DDG, informs
corresponding mitigation measures and/or the degree of Minerals DDG alignment.
procedures as per the Minerals DDG.
6. Consults stakeholders as part of the process Stakeholder consultations enhances the ownership and
to identify and follow up/mitigate incidents. accountability of the operation.

5 The typology of Due Diligence Programmes in this Glossary is offered for the exclusive purpose of this M&E
Framework, and does not supersede or alter in any way the OECD methodology to assess the alignment of
institutionalised mechanisms and industry programmes with the Minerals DDG (2018c). Programmes that have been
independently assessed to be partially or fully aligned with the Minerals DDG in line with the Alignment Assessment
methodology of the OECD would automatically be considered a DDP for the purposes of this M&E Framework.

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7. Has a system of controls and transparency The best means of control and transparency within supply chains is
over the mineral supply chain in place, a chain-of-custody system (see definition in Glossary). Without a
including of mineral trade and transactions, i.e. robust chain-of custody system in place, the DDP is vulnerable to
traceability or chain-of-custody systems.* fraudulent misrepresentation of the origin of minerals among
supply chain actors party to the initiative (fraud being a primary risk
as per point 4 of Annex II).
8. Has in-scope practices and outputs assessed Independent 3rd party verification enhances the credibility and
through credible, independent 3rd party legitimacy of the operation.
verification on a regular basis.*
Note: *DDPs that are not involved in the sourcing or purchasing of minerals are exempted from criteria 1, 7, and 8.

Evaluation: The systematic collection, examination and analysis of information that pertains to the Theory
of Change and the implementation outcomes (immediate, intermediate and ultimate). The results of an
evaluation provide stakeholders with the information they need to determine whether the initiative is
meeting its anticipated objectives.
Grievance mechanism: A “mechanism allowing any interested party (affected persons or whistle-blowers)
to voice concerns regarding the circumstances of mineral extraction, trade, handling and export in a
conflict-affected and high-risk area. This will allow a company to be alerted of risks in its supply chain as
to the problems in addition to the company fact and risk assessments” (OECD, 2016: 40 and 74).
Illegal practices: Conduct in contravention of the national laws in which entities are operating.
Leakage-in: The flow of non-DDM into supply chains designated as DDM.
Market actor: A commercial enterprise that extracts, produces, trades, or consumes in-scope minerals.
Medium and Large-scale Mining (LSM): “[M]ining operations that are not considered to be artisanal or
small-scale mining” (OECD, 2016: 69).
Monitoring: “The continuous assessment of the intervention and its environment” (FORMIN, 2006: 31).
Non-Due Diligence Minerals (non-DDM): Minerals extracted from CAHRAs that have not been verified
whether or to what extent they contributed to human rights violations (Annex II Adverse Impacts, paragraph
1) and/or funded armed groups (Annex II Adverse Impacts, remaining paragraphs), i.e. do not have Due
Diligence Minerals status.
Upstream: The supply chain links from point of extraction (ASM, LSM) to and including the smelter or
refiner (SOR). This includes miners (artisanal and small-scale enterprises or medium and large-scale
mining companies), local traders or exporters from the country of origin, transporters, international traders
of mined or recyclable metals and refiners.
Traceability: The ability to query and verify the history, location, or application of an item by means of
documented, recorded identification. According to the Minerals DDG, at a minimum, the following
information is required:
• mine of mineral origin;
• quantity and dates of extraction;
• locations where minerals are consolidated, traded or processed;
• all taxes, fees, royalties or other payments made to governmental officials for the purposes of
extraction, trade, transport and export of minerals;
• all taxes and other payments made to public or private security forces or other
• armed groups;
• identification of all actors in the upstream supply chain;
• transportation routes.

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Monitoring and Evaluation Framework How to address bribery and corruption

risks in mineral supply chains
2022 edition

The development of this M&E Framework was premised on the OECD’s terms of reference,
which had involved extensive prior stakeholder input over a period of 18 months. Further
input and guidance was received by the OECD’s Secretariat at each step of the M&E
Framework’s development. It was critiqued by an Informal Advisory Group of academic and
civil society representatives. Leading theory was applied to the problem at hand, including
systems theory, game theory, and literature specific to the problematic of minerals associated
with conflict and adverse impacts.

The basic characteristics of minerals markets were considered, as well as precedents involving
the measurement of policy implementation. Upon being operationalised, the guiding
specifications and parameters in the form of particular research methods and indicators were
tested through example case studies, providing a perspective of how this M&E Framework is
to be applied.

For this reason, several examples spanning indicators and data sources were drawn from
experience implementing the DDG in the Democratic Republic of the Congo. These should
be considered indicative as specific national and sub-national data sources will be considered
for the deployment of the M&E Framework in selected countries