The OECD Due Diligence Guidance for Minerals is the international benchmark framework for responsible sourcing of minerals from conflict-affected and high-risk areas. Published by the Organisation for Economic Co-operation and Development in 2010 and revised through subsequent editions (2013, 2016), the Guidance has been adopted by the United Nations, the European Union, and numerous industry bodies as the foundation for compliance with conflict-minerals legislation and voluntary certification schemes in the gem and jewellery sector.

Origins and purpose

The OECD framework emerged from international concern about the role of mineral revenues in financing armed conflict, particularly in the eastern Democratic Republic of Congo and adjacent Great Lakes region during the 2000s. Documentation by United Nations panels, civil-society organisations, and journalists demonstrated that the trade in tin, tantalum, tungsten, and gold (collectively the 3TG minerals) was contributing to the funding of armed groups and to widespread human-rights abuses in mining areas.

The U.S. Dodd-Frank Act of 2010, particularly Section 1502, was the first major legislative response, requiring U.S. publicly listed companies to report on their use of conflict minerals. The OECD Guidance, published the same year, provided the methodological framework that Dodd-Frank required and that subsequent regulation in other jurisdictions built upon.

The five-step framework

The OECD framework outlines a five-step due diligence process for companies sourcing minerals from potentially conflict-affected supply chains. Step 1 establishes strong management systems, including supply-chain policies and internal controls. Step 2 identifies and assesses risks in the supply chain through supplier mapping, red-flag identification, and risk evaluation. Step 3 designs and implements strategies to respond to identified risks, ranging from continued sourcing with mitigation through full disengagement from problematic suppliers. Step 4 conducts independent third-party audits of supply-chain due diligence at identified verification points. Step 5 publishes annual reports on supply-chain due diligence and outcomes.

The framework is structured as risk-based and sequential, with each step reinforcing the others. The depth of due diligence required is calibrated to the risk profile of the supply chain: routine sourcing from low-risk jurisdictions (such as Australia or Canada) requires less intensive verification than sourcing from conflict-affected or fragile-state contexts (such as the eastern DRC or parts of West Africa).

Adoption in gem and jewellery sector

The Responsible Jewellery Council adopted the OECD framework as the foundation for its Code of Practices and Chain-of-Custody Standard, both of which require RJC-certified members to demonstrate alignment with OECD principles. Major luxury houses — LVMH, Richemont, Kering, Tiffany & Co., Cartier, Van Cleef & Arpels — require their suppliers to operate under OECD-aligned due diligence, and most have published public reporting on their supply-chain practices in recent years.

Application to coloured stones (particularly ruby, sapphire, and emerald) has been more recent than to diamonds and 3TG minerals. The Coloured Stones Working Group within the OECD's broader process has worked since the mid-2010s on adaptation of the framework to the unique challenges of coloured-stone supply chains, including artisanal small-scale mining contexts and the historically opaque trading patterns of certain gem markets.

Regulatory landscape

The OECD Guidance is incorporated by reference into binding regulations in several jurisdictions. The EU Conflict Minerals Regulation (Regulation 2017/821, in force from 1 January 2021) requires Union importers of 3TG minerals to perform OECD-aligned due diligence. U.S. Dodd-Frank Section 1502 obligates publicly listed companies to file Conflict Minerals Reports with the Securities and Exchange Commission using OECD-aligned methodology. The UK, Canada, Australia, and several Asian jurisdictions have parallel or complementary requirements applicable to specific company categories or import routes.

For gem and jewellery companies, compliance increasingly requires not only OECD-aligned procurement of 3TG minerals (gold being the most directly relevant) but also analogous due-diligence approaches for coloured stones, given the rising scrutiny from regulators, NGOs, and consumers. Russian-diamond sanctions following the 2022 invasion of Ukraine have added a layer of country-of-origin tracking to the broader compliance picture.

Audit and certification

Third-party audit and certification programmes operationalise the OECD framework. The Responsible Minerals Assurance Process (RMAP) audits smelters and refiners of 3TG minerals against OECD criteria. Fairmined and Fairtrade gold certifications verify artisanal and small-scale mining operations. The RJC Code of Practices and Chain-of-Custody certifications cover broader segments of the jewellery supply chain. The Kimberley Process Certification Scheme covers rough diamonds, with its own certification regime separate from but compatible with OECD principles.

Limitations and critiques

The OECD framework, while widely adopted, has been the subject of substantive critique. Civil-society organisations have raised concerns about audit quality, transparency, and the framework's effectiveness in ending conflict financing. Industry critics point to compliance costs and to the unintended consequences of disengagement from artisanal mining communities, which can shift mining activity to less regulated channels. The framework continues to evolve in response to these challenges, with revisions and supplementary guidance published periodically.

Further reading

• OECD — Due Diligence Guidance for Minerals
• Responsible Jewellery Council
• Kimberley Process Certification Scheme
• GIA Gems & Gemology — responsible sourcing