Responsible Minerals Initiative

The RBA’s Responsible Minerals Initiative (RMI) continued to make great progress in 2021, releasing five new assessment standards to match its original standards portfolio, including, for the first time, creating a dedicated standard for Environmental, Social and Governance (ESG) requirements for mineral and metal processors.

The RMI also launched an All-Minerals Due Diligence Standard. In addition, the RMI continued its market acceptance efforts, receiving conditional approval of one of its standards by the London Metals Exchange (LME) in 2021 and pursuing LME recognition for other relevant standards in 2022. The RMI collaborated with a number of multistakeholder initiatives, civil society, governments and key stakeholders, culminating in the RMI governance structure expanding to include multi-stakeholder representation on the RMI Steering Committee with representatives from civil society and academia who started to serve their first term in January 2022.

MEMBERSHIP OVERVIEW

The RMI continued to experience strong membership growth in 2021 with 50 new members. These members represented a wide range of sectors that included electronics, energy, industrial, and minerals processing. The 2021 year-end RMI membership count was 437.

Three new smelters or refiners (SORs) joined the RMI as Upstream Members in 2021. The RMI also welcomed two new Vendor Members and an Association Member in 2021. The RMI currently has 15 Upstream and 10 Vendor Members.

IN 2021, 309 OF THE 447 KNOWN TIN, TANTALUM, TUNGSTEN, GOLD, COBALT, MICA, COPPER, LITHIUM, NICKEL AND ZINC PROCESSORS, SMELTERS AND REFINERS WERE EITHER ACTIVE OR CONFORMANT TO THE RMAP OR A CROSSRECOGNIZED PROGRAM

PROGRAM INDICATORS

The RMI also continued enhancing its two assessment programs: the Responsible Minerals Assurance Process (RMAP) and the Downstream Assessment Program (DAP).

During the COVID-19 pandemic, the RMAP and DAP successfully adapted to a rapidly evolving public health situation, tenuous business climate, changing travel requirements and shifting restrictions worldwide to maintain steady participation among auditees. In 2021, 9 percent of all RMAP assessments due for a re-assessment were delayed due to COVID. Affected RMAP participants moved forward with assessments as soon as was feasible and/or made active progress on any required corrective actions. Our COVID-19 Virtual Assessment Policy, which was published in 2020, outlined the process for allowing certain assessments to include a virtual component to minimize time on-site where possible, accounting for risk and the complexity of assessment. In 2021 this allowed for approximately 30 percent of the assessments to include both in-person and virtual components. The remaining 70 percent of assessments were done in-person.

In 2021, 302 out of 418 known tin, tantalum, tungsten, gold and cobalt SORs were either active or conformant to the RMAP or a cross-recognized program. Fourteen cobalt refiners completed an on-site assessment in 2021, and several additional refiners and multi-metal processors should complete assessments in 2021. By the end of 2021, 56 percent of identified eligible cobalt refiners were participating in RMAP and 22 were conformant.

NUMBER OF CONFORMANT SMELTERS AND REFINERS

By Geography 75 (in 2021)

56

52

107 33

China Asia and Oceania

Europe and Russia Japan 25

North America 18

South America 6

Africa

NUMBER OF ACTIVE & CONFORMANT SMELTERS AND REFINERS By Metal (in 2021)

n CONFORMANT n ACTIVE

55

6 13 42 39

7

0 22

18

0 1 0 1 0 2 0 1

GLOBAL SMELTER PARTICIPATION IN DUE DILIGENCE PROGRAMS

Conformant Smelters & Refiners

NUMBER OF COMPLIANT SMELTERS 300

250

200

150

100

50

0

n Co n Au n W n Sn n Ta n Totals 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 0 0 0 0 0 0 0 0 0 2 10 21 0 0 11 31 56 78 90 98 103 105 107 107 0 0 0 1 9 29 39 41 42 43 42 40 0 0 3 9 22 56 66 69 74 45 50 53 2 10 15 23 43 46 46 42 40 37 37 36 2 10 29 64 130 209 241 250 259 232 246 257

In 2021, the RMAP continued expansion of its cobalt program to cobalt crude refiners located in the Democratic Republic of the Congo (DRC). The RMI has confirmed 13 crude refiners are eligible to undergo RMAP. Of the identified eligible crude refiners, two are currently active in RMAP and three are currently conformant in 2021.

Several first-time assessments for newly rolled-out standards were conducted in 2021. The RMI added mica as a mineral under RMAP with the release of its new mica processor standard. By the end of 2021, 18 eligible mica processors had been identified and three mica processors were participating in RMAP. The first Environmental, Social and Governance (ESG) standard assessment was completed as an add-on to RMAP in 2021, in conjunction with 1 of the 4 total Joint Due Diligence Assessments conducted in 2021. In addition, the first Gold Aggregator pilot assessment was organized and scheduled to take place in early 2022.

The RMI identified 49 new SORs across all minerals under RMAP scope in 2021, of which 12 were 3TG SORs, six were cobalt refiners, and 15 were mica processors. The RMI also identified three copper processors, eight lithium processors, four nickel processors, and one zinc processor. Eighteen tin smelters were added back as eligible due to returning to operations, while 11 SORs were considered no longer eligible due to a change or cessation in operations. Twelve SORs became conformant for the first time in 2021, and 21 joined the active list.

The RMI issued updates to its Conflict Minerals Reporting Template (CMRT) in April 2021 and released the new Extended Minerals Reporting Template (EMRT) in October 2021. The EMRT combines the previously released Cobalt Reporting Template (CRT) and Mica Reporting Template (MRT). While the CRT and MRT will be phased out in 2022, new minerals will be added to the EMRT scope pending IPC1755 amendments and feedback from the Minerals Reporting Template workgroup.

The Downstream Assessment Program (DAP) saw increased inquiries from downstream producers of tin, tantalum, tungsten and gold in response to the EU regulation and also received inquiries from downstream producers of cobalt as well. Eight downstream assessments were completed in 2021 and several are pending for 2022.

All 3TG assessments in 2021 were conducted against the RMI Revised Standards for Tin, Tantalum, Tungsten and Gold (issued in 2017).

QUALITY ASSURANCE AND CONTINUAL IMPROVEMENT

The RMI also continued enhancing its two assessment programs: the Responsible Minerals Assurance Process (RMAP) and the Downstream Assessment Program (DAP).

The RMI continued to grow its internal quality team to ensure quality and consistency in the implementation of the assessment standards requirements and methodology. The RMI Quality Team added another internal quality assurance member to further enhance the overall quality of the RMI’s assurance program for RMAP and DAP assessments. Over the course of 2021, the RMI also worked with the RBA’s Operations Team under the umbrella of a shared audit services model, on a joint strategy to stabilize and scale RMI audit and QC programs, including cross-training RBA’s internal and external reviewers. These additional resources have led to improved rates of quality reviews and an increase in auditor capacity-building support from the RMI. DAP was also integrated into RBA’s end-to-end audit management tool, RBA-Online, in 2021 following RMAP, which was integrated for 3TG and Cobalt earlier. Complete workflow and operations management functions available on the new platform led to increased program efficiencies in tracking and expediting the quality assurance process. Newly implemented RMI standards will also be integrated into RBA-Online in 2022.

In 2021 the RMI conducted a total of 16 shadow assessments, four of which were completed virtually. The RMI will continue to utilize a combination of in-person and virtual shadows as part of its quality assurance for RMAP and DAP assessments in 2022.

Of the RMAP assessments conducted in 2021,13 resulted in corrective action plans (CAPs). The most common non-conformances included: • Supply Chain Policy missing critical elements • Procedure to Identify Conflict-Affected and High-Risk

Areas (CAHRAs) missing critical elements and/or implemented inconsistently • Gaps in consistent implementation of Know-Your-

Counterparty (KYC) process • Company’s expectations that suppliers will undertake mineral supply chain due diligence and risk management consistent with the standards defined in Annex II of the OECD Due Diligence Guidance are not communicated to suppliers via contracts and/or written agreements • No Step 5 Public Due Diligence Report

RMAP ASSESSMENT NON-CONFORMANCE BY TYPE 2021

1.85% 1.96%

2.07% 2.61%

3.37%

3.59%

4.13% 0.87%

0.54% 0.43% 0.11%

27.5%

5.87%

7.17%

9.35%

14.13% 14.46%

Due Diligence Management System Design Supplier Relations Overall Conclusions 27.50% 14.46% 14.13%

Step 5 Report

9.35% High Risk Sourcing 7.17% Due Diligence Management System Implementation 5.87% Assessment of Due Diligence Practices and Qualitative Conditions 4.13% Transaction Review 3.59% Internal Material Control 3.37% Risk Mitigation 2.61% Mapping of Factual Circumstances 2.07% Identifying and Assessing Risks in the Supply Chain 1.96% Red Flags 1.85% Upstream Assurance Mechanisms 0.87% Due Diligence Management System 0.54% Due Diligence Management System Conclusions 0.43% Review of On-The-Ground Assessments 0.11%

• Missing chain-of-custody documentation • No on-the-ground assessments were completed where red flags were identified • No risk mitigation plan in place

As part of the OECD-aligned approach to continual improvement and to support auditees’ successful closure of non-conformances, the RMI developed a series of trainings specific to common findings. The auditee trainings also included case study scenarios to help deepen the auditee’s understanding of supply chain due diligence and RMI standards requirements. The RMI continued free smelter access to its Global Risk Assessment and Grievance Mechanism tools, and offered extensive technical assistance to support auditees’ development of policies and procedures that would satisfy the Standard’s requirements.

MARKET ACCEPTANCE

The RMI applied for recognition of the RMAP and DAP under the EU Delegated Act for Recognition of Industry Schemes in 2019. Throughout 2020, ECappointed assessors shadowed the RMAP and in 2021 the assessors shadowed DAP audits as part of the review process. At the end of 2021, the RMI received draft assessment results for RMAP and is anticipating final EC reports on RMAP and DAP in 2022.

In 2021 the RMI also began its journey to have its standards recognized by the London Metal Exchange (LME). The RMI Joint Due Diligence Standard and the ITA-RMI Tin Assessment Criteria received conditional approval from LME and the RMI initiated the process for its ESG Standard ISO alignment assessment, as required by the LME. In 2022, the RMI also hopes to have its Tin and Tantalum Standard, Cobalt Standard and All-Minerals Standard conditionally approved and will move forward to have all standards fully recognized by LME.

CAPACITY-BUILDING, TRAINING AND SMELTER FINANCIAL ASSISTANCE

In 2021 the RMI held trainings for a record number of attendees globally. For the first time since the COVID-19 pandemic began, the RMI was able to offer an in-person training for auditors and auditees, held in Xiamen, China. The RMI also delivered virtual auditee and auditor trainings. In collaboration with Synergy, the RMI also delivered five virtual, interactive training sessions in June and July on the RMAP standards requirements and assessment approach. The RMI held a DAP training for 300 attendees including RMI members, suppliers to members and other downstream companies interested in undergoing DAP, current DAP auditees, prospective DAP auditees, and RMI-approved auditors and technical assistance providers.

To further increase the awareness of OECD Due Diligence Guidance expectations for downstream companies as well as of the RMI Downstream Assessment Program, the RMI delivered a training specific to meeting the RBA Code D7 requirements. The RMI also delivered training to the International Conference on the Great Lakes Region (ICGLR), focusing on the RMAP and linkages with ICGLR. The RMI also held its annual virtual Audit Townhall for fully approved and provisionally approved auditing firms, where key programmatic updates were covered. In total, the RMI delivered 12 trainings with more than 1,350 participants in 2021. The RMI will deliver an in-depth, advanced auditing techniques training in Q1 of 2022 and will continue its commitment to support auditors and auditees through various training opportunities in 2022.

To continue supporting upstream due diligence, in 2021, the RMI expanded the use of Upstream Smelter Due Diligence Fund to upstream assurance mechanisms (UAMs) that requested financial assistance with their OECD alignment assessments. The purpose of the Fund is to support responsible sourcing from conflict-affected and high-risk areas (CAHRAs) for which there is not currently a recognized upstream assurance mechanism available. Recipients are required to provide deliverables that serve a public good, including on-the-ground risk assessments of mine sites, ongoing monitoring, capacity-building of local communities, development of template questionnaires or reports, or the publication of case studies.

The RMI continued offering its Financial Assistance Program, which pays for 75 percent of the cost of re-assessments for smelters and refiners with low volumes. The RMI disbursed financial assistance to nine smelters and refiners since the inception of this policy. The RMI continued to disburse funds under the Initial Audit Fund, paying for the full costs of initial assessments. Since 2014, the RMI has disbursed nearly US$2M to smelters under the Initial Audit Fund and disbursed approximately US$216,328 in 2021.

PARTNERSHIPS

The RMI and the Responsible Cobalt Initiative (RCI) continued their collaboration, which has facilitated validation of due diligence activities by companies in China and the DRC. The RMI and RCI worked from 2019 to 2021 to revise and update the Cobalt Refiner Due Diligence Standard, which was released in August 2021 and went into effect in January 2022.

The RMI, in collaboration with the Copper Mark, the International Lead Association (ILA), the International Zinc Association (IZA), and the Nickel Institute, issued a Joint Due Diligence Standard for Copper, Lead, Nickel and Zinc to enable companies to comply with the London Metal Exchange Responsible Sourcing requirements in February 2021. Covered metals processors can be audited to the standard using RMAP.

The RMI conducted four pilot assessments against the Join Standard in 2021, and several of those were in combination with the RMAP Cobalt Standard. The Joint Standard underwent OECD alignment assessment and was reissued in a finalized version in December 2021 after receiving determination of full alignment for the standard portion of the assessment (the implementation assessment is planned for 2022). The RMI also worked with the Copper Mark to develop a series of virtual Joint Standard trainings for auditees and auditors, and expanded a suite of freely available, animated online training programs for Risk Readiness Assessment (RRA) topics. For 2021, the RMI produced RRA modules covering greenhouse gases, forced labor, waste management, pollution, remuneration, biodiversity and protected areas. The RMI and the Responsible Mica Initiative released the Global Workplace Standard for Mica Processors in March 2021 after a member and public consultation process. The new Standard aims to improve conditions for workers in mica supply chains by leveraging the collective experience of these initiatives and benchmarking against internationally recognized frameworks.

The RMI and the International Tin Association (ITA) co-developed Criteria for Tin Smelting Companies, underwent OECD alignment assessment and, in March of 2021, the Criteria was determined to be fully aligned (assessment of the implementation is planned for 2022). Subsequently, the RMI ITA Joint Criteria was recognized as a conditionally approved standard for Track A of Responsible Sourcing Requirements by the London Metal Exchange (LME).

STANDARDS DEVELOPMENT

In addition to the publication/updating of four standards — the Cobalt Refiner Due Diligence Standard, RMI Joint Due Diligence Standard, Mica Standard, and ITA-RMI Tin Assessment Criteria — in 2021 the RMI finalized and published two other flagship standards that significantly expand the focus and reach of RMAP in terms of mineral scope and incorporation of environmental, social and governance indicators: • The Global Responsible Sourcing Due

Diligence Standard for Mineral Supply Chains

— All Minerals was launched in December 2021 and went into effect in January 2022. This

standard enables upstream companies, including processors, traders and mines, to be assessed on their responsible due diligence practices in the sourcing and processing of any mineral or metal. It complements the 3TGC-specific RMAP standards and can be used in conjunction with those standards by multi-metal facilities. It is designed to be aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from

Conflict-Affected and High-Risk Areas (OECD

Guidance) and to help companies adhere to regulatory requirements such as the existing EU

Conflict Minerals Regulation and pending EU Battery

Regulation. • The Environmental, Social & Governance (ESG)

Standard for Mineral Supply Chains was launched in June 2021. This standard marks an expansion of the RMI’s scope beyond OECD Due Diligence

Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as it aims to guide businesses in the assessment and improvement of their performance against environmental, social, occupational health & safety and governance criteria. The first pilot assessment against the standard was conducted in November 2021.

In addition to publication of the ESG standard, the RMI continued championing evaluation and revision of the Risk Readiness Assessment (RRA), widely used by RMI auditees as a self-assessment, and on which norms the ESG standard was based, reflecting an evolution of industry best-practices. The revision process for the RRA began in June 2021 and is an effort jointly led by the RMI and Copper Mark. The revision aims to strengthen the RRA criteria in line with the evolution of recognized standards and industry practices as it expands the criteria set where new requirements have emerged for mineral producers and processors. The revision process has been guided by expert inputs from a Technical Committee of industry representatives and will continue in 2022 with stakeholder consultations and the publication of the revised tool. The RRA continued to be utilized by downstream companies and upstream refiners and mining companies, with 366 RRA self-assessments completed as of 2021, compared with 341 completed as of 2020.

The endeavor to expand audit and assessment tools has been accompanied by the build-up of internal and external capacities. Auditor guidelines and workbooks have been developed for the All-Minerals standard, the ESG Standard and the Mica Standard.

In Q4 2021, nine new applicants were accepted into the pool of approved auditing firms, bringing the total of fully approved and provisionally approved audit firms to 15. The larger number will help ensure auditor availability to cover the growing geographical breadth of the audit program, facilitate assessment scheduling despite any continued pandemic-related international travel restrictions, and expand mineral scope as well as a new focus on ESG.

SUPPORTING DUE DILIGENCE ACROSS THE SUPPLY CHAIN

The RMI maintained active engagement with upstream partners and stakeholders in advisory and leadership roles, including in critically important programs that support the artisanal and small-scale mining (ASM) sector as a member of the OECD MultiStakeholder Group, a board member of the European Partnership on Responsible Minerals (EPRM), and as a member of the Public-Private Alliance for Responsible Minerals Trade (PPA).

IN-COUNTRY ENGAGEMENT

In 2021 the RMI continued its role as the Project Management Office (PMO) for the Global Battery Alliance’s (GBA) Cobalt Action Partnership (CAP). The CAP is a broad-based and multi-sectoral, public-private coalition of organizations working toward a common vision to immediately and urgently eliminate child and forced labor from the cobalt value chain, contribute to the sustainable development of communities, and respect the human rights of those affected by the value chain in the DRC. The CAP’s mission is to enable and support a global sustainable cobalt supply chain that integrates responsibly sourced materials in the battery value chain, harmonizing responsible sourcing projects and initiatives, especially but not exclusively in ASM, to eventually contribute to local broader sustainable developments.

Given the interconnected nature of large-scale and ASM mining in cobalt supply chains, and the importance of ASM to the economy of the DRC, the CAP engaged a range of stakeholders, including affected communities, relevant governments, industrial large-scale mining (LSM), and ASM, to bridge the gap between global, local, upstream, and downstream actors. As the lead organization coordinating the activities of the CAP, including the coordination of individual actors and organizations formally working as CAP implementing partners to advance its mission, the RMI led the development of in-country research, stakeholder and government engagement, and the development of responsible sourcing expectations. While travel limitations and restrictions continued in 2021 due to the pandemic, the RMI was able to work with in-country partners in the DRC through its in-country CAP implementing partner UNICEF and in-country consultant, IMPACT Transforming Natural Resource Management, for the in-country component of the consultation on the ASM Cobalt Framework, which was implemented from June-July 2021.

RISK MANAGEMENT

The RMI continued to enhance and maintain the Minerals Grievance Platform (MGP), which is a channel for the identification, review and resolution of grievances, offering a connected and efficient system that benefits a wide range of stakeholders and builds on existing mechanisms. The Minerals Grievance Platform scope includes OECD Annex II risks, as well as environmental and occupational health & safety risks (OHS). The MGP is not limited to the RMI but includes third-party audit programs such as the London Bullion Market Association (LBMA) and the Responsible Jewelry Council (RJC). As of 2021, the MGP included 65 downstream company users and 22 in-scope grievances.

In 2021, the RMI received no new notifications through the Minerals Grievance Platform (all MGP grievances are visible to RMI members) of grievances linked to RMAP-participating smelters’ or refiners’ supply chains. The five new grievances for 2021 were linked to SORs in cross-recognized programs. The grievances included complaints against SORs, upstream and downstream actors, and mining operations, with risks including human rights issues, 3TG from illegitimate sources, smuggling and other OECD Annex II risks. When a grievance is received, the RMI works with the parties in question to verify and mitigate the issues raised in accordance with the Grievance Mechanism, including reviewing corrective actions, commencing in-depth assessments, conducting legal reviews, facilitating stakeholder engagement, addressing the issues through the RMAP audit process, encouraging respondents to issue public statements, and referring to the grievance platform or partner mechanisms for resolution where appropriate.

For more information on the RMI,

visit ResponsibleMineralsInitiative.org