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ARM CRAFT: A Due-Diligence Framework for Artisanal and Small-Scale Mining

ARM CRAFT: A Due-Diligence Framework for Artisanal and Small-Scale Mining

How the Alliance for Responsible Mining's Code of Risk-Mitigation supports conflict-free sourcing and supply-chain formalisation in ASM contexts

International jewellery standardsView in dictionary · 1,090 words

ARM CRAFT — an acronym for Code of Risk-Mitigation for ASM Engaging in Formal Trade — is a structured due-diligence framework developed by the Alliance for Responsible Mining (ARM) to assist artisanal and small-scale mining (ASM) organisations in meeting international supply-chain compliance standards. Designed as a practical instrument for miners, traders, refiners, and brands, it addresses the requirements set out in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, providing a documented pathway through which ASM operations can demonstrate responsible sourcing credentials even before attaining full Fairmined certification.

Context and Purpose

Artisanal and small-scale mining accounts for a significant proportion of global coloured-gemstone and gold production, yet ASM operators have historically faced substantial barriers to entering formal, compliance-oriented supply chains. Large institutional buyers — refiners, jewellery brands, and commodity traders — are increasingly required by legislation and voluntary frameworks to conduct supply-chain due diligence, identifying and mitigating risks of conflict financing, human rights abuses, environmental harm, and corruption. For many ASM cooperatives and associations, particularly those operating in lower-income countries, the administrative, financial, and technical demands of full third-party certification can be prohibitive in the short term.

ARM CRAFT was developed to bridge this gap. Rather than functioning as a certification mark in its own right, it operates as a risk-assessment and risk-mitigation tool: a codified set of criteria and procedures that an ASM organisation can adopt to demonstrate that it is actively identifying and managing supply-chain risks in a manner consistent with internationally recognised standards. The framework thereby enables ASM operators to engage with formal trade relationships while working progressively toward full Fairmined certification or equivalent recognised standards.

Relationship to the OECD Due Diligence Guidance

The OECD Due Diligence Guidance, first published in 2010 and subsequently updated, establishes a five-step framework for companies to identify and address risks in mineral supply chains originating from conflict-affected and high-risk areas (CAHRAs). These steps encompass establishing strong company management systems, identifying and assessing risks in the supply chain, designing and implementing strategies to respond to identified risks, carrying out independent third-party audits, and reporting annually on supply-chain due diligence. ARM CRAFT maps directly onto this architecture, translating its requirements into practical tools accessible to ASM-scale operations that may lack the institutional infrastructure of large mining companies.

By aligning with the OECD Guidance, ARM CRAFT allows downstream buyers to reference ASM participation in the framework as part of their own due-diligence documentation — a commercially significant function as regulatory environments in the European Union, United States, and other major markets continue to tighten supply-chain disclosure requirements.

Core Components of the Framework

ARM CRAFT addresses several interconnected areas of supply-chain risk and responsibility:

  • Conflict-free sourcing: Criteria to identify and exclude minerals that may finance armed groups or be associated with serious human rights violations, consistent with OECD Guidance Annex II red flags.
  • Traceability systems: Tools and documentation protocols enabling ASM organisations to establish and maintain chain-of-custody records, linking extracted material to its point of origin and through successive stages of trade.
  • Risk assessment: Structured methodologies for identifying operational, geographic, and governance-related risks specific to the ASM context, including land tenure disputes, child labour, mercury use, and the presence of non-state armed actors.
  • Mitigation planning: Guidance on designing and implementing corrective action plans where risks are identified, with provisions for monitoring progress over time.
  • Stakeholder engagement: Frameworks for meaningful consultation with affected communities, workers, and local authorities.

ARM CRAFT and Fairmined Certification

ARM CRAFT is best understood not as an alternative to Fairmined certification but as a preparatory and complementary instrument. Fairmined, also administered by ARM, is a full third-party certification standard covering responsible mining practices, environmental management, labour rights, and community development, with independent auditing by accredited bodies. It carries a recognised mark that downstream buyers and consumers can identify.

ARM CRAFT is explicitly positioned as a stepping stone: an ASM organisation that has implemented the CRAFT framework has begun the organisational, documentary, and procedural work that Fairmined certification will later require in more rigorous form. For buyers sourcing from ASM operations that are not yet Fairmined-certified, CRAFT participation provides documented evidence of due-diligence effort — a meaningful distinction in compliance terms from entirely unverified sourcing.

This graduated approach reflects a pragmatic understanding of ASM realities. Many artisanal mining communities operate in remote areas with limited access to banking, legal services, or technical expertise. Demanding immediate full certification as a condition of market access can inadvertently exclude the most vulnerable producers and push trade toward informal, entirely unmonitored channels. ARM CRAFT is designed to maintain a commercial relationship with such communities while creating structured incentives and support for progressive improvement.

Adoption and Use in the Trade

ARM CRAFT has been adopted in supply chains involving gold and, to a lesser extent, coloured gemstones and other minerals. Refiners seeking to demonstrate OECD-aligned due diligence for ASM-sourced gold have referenced CRAFT participation as part of their responsible sourcing programmes. Jewellery brands with commitments to responsible sourcing — particularly those operating under frameworks such as the Responsible Jewellery Council's Code of Practices or the World Gold Council's Responsible Gold Mining Principles — may accept CRAFT documentation from suppliers as evidence of due-diligence effort at the mine level.

In the coloured-gemstone sector, where supply chains are often highly fragmented and traceability is technically and logistically challenging, the CRAFT framework's emphasis on documentation and risk mapping is particularly relevant. The gemstone trade has historically operated with limited transparency at the mine-to-market level, and frameworks such as ARM CRAFT represent part of a broader industry movement — alongside laboratory origin determination, blockchain-based provenance systems, and voluntary disclosure initiatives — toward greater accountability.

Limitations and Criticisms

As a self-assessment and risk-mitigation tool rather than a third-party certification, ARM CRAFT carries inherent limitations. The rigour of its implementation depends substantially on the capacity and good faith of the ASM organisation adopting it, and on the diligence of buyers in reviewing documentation. Critics of due-diligence frameworks more broadly have noted that paper-based compliance systems can be gamed or may fail to capture on-the-ground realities in high-risk contexts. ARM and its partners have acknowledged these limitations and have emphasised that CRAFT is intended as a transitional instrument, not a permanent substitute for independent verification.

Furthermore, the framework's primary development and uptake has been in gold supply chains; its application to coloured gemstones, which present distinct traceability challenges owing to the diversity of species, localities, and trading intermediaries involved, remains less systematically developed.

Significance for the Jewellery Industry

For gemmologists, jewellers, and supply-chain professionals, ARM CRAFT represents one of the more practically oriented responses to the long-standing challenge of responsible sourcing from artisanal mining communities. Its alignment with the OECD Due Diligence Guidance gives it credibility within regulatory and institutional compliance frameworks, while its graduated, capacity-building approach reflects an understanding that supply-chain formalisation is a process rather than a binary state. As legislative requirements for mineral supply-chain disclosure continue to expand globally, familiarity with frameworks such as ARM CRAFT is increasingly relevant to professional practice in the gemstone and jewellery trade.

Further Reading