The OECD Due Diligence Guidance is a five-step framework published by the Organisation for Economic Co-operation and Development in 2010 (with major revisions in 2013 and 2016) to help companies establish responsible mineral supply chains from conflict-affected and high-risk areas. The full title — OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas — sets out a risk-based due diligence process applicable to gold, tin, tantalum, tungsten, and, by extension, other minerals where supply-chain ethics matter. The framework underpins the Responsible Jewellery Council's certification standards, the Responsible Minerals Initiative's audit protocols, and the EU Conflict Minerals Regulation and U.S. Dodd-Frank Act Section 1502, both of which reference the OECD Guidance directly.

The five steps

The Guidance organises due diligence around five sequential and reinforcing steps. Step 1 requires companies to establish strong company management systems, including supply-chain policies, internal controls, complaint mechanisms, and business engagement with suppliers. Step 2 requires risk identification and assessment in the supply chain, including mapping of suppliers, identification of red flags, and evaluation of the risk of contributing to conflict or human-rights abuses. Step 3 requires the design and implementation of risk-mitigation strategies, ranging from supplier engagement to disengagement from problematic sources. Step 4 requires independent third-party audits of the supply-chain due diligence at identified points in the chain. Step 5 requires public reporting on the company's due diligence activities and the outcomes of the process.

The framework is risk-based rather than prescriptive: the depth and intensity of due diligence are calibrated to the risk profile of the supply chain. Sourcing from low-risk jurisdictions requires less intensive verification than sourcing from conflict-affected or fragile-state contexts.

Sectoral application

The OECD Guidance was originally developed with a focus on the so-called 3TG minerals — tin, tantalum, tungsten, and gold — in response to widespread documentation of conflict financing through these minerals in the eastern Democratic Republic of Congo and adjacent regions during the 2000s. The Dodd-Frank Act of 2010 in the United States, which preceded the OECD Guidance and to which the Guidance was partly a response, mandated supply-chain due-diligence reporting for U.S. publicly listed companies sourcing 3TG minerals.

The framework has since been adopted and adapted for other minerals, including coloured gemstones (notably ruby, sapphire, and emerald), industrial minerals, and certain rare earths. The Responsible Jewellery Council's Code of Practices and Chain-of-Custody standards both reference the OECD Guidance, and most major luxury and jewellery brands now require their suppliers to demonstrate alignment with OECD principles.

Practical implementation in jewellery

For jewellery brands and retailers, OECD-aligned due diligence typically involves a combination of supplier risk assessments, contractual requirements for supplier compliance, audits of high-risk suppliers, and public reporting on due-diligence outcomes. Major audit programmes — the Responsible Minerals Assurance Process (RMAP), Fairmined and Fairtrade gold certifications, and various RJC certifications — provide third-party verification of supplier compliance, simplifying brand-level due diligence.

Smaller jewellers and retailers face challenges in implementing full OECD due diligence given limited supply-chain visibility and bargaining power. Industry initiatives provide tiered approaches that allow smaller participants to engage with the framework through traceable-source programmes, certified suppliers, and public commitments.

Position in the regulatory landscape

The OECD Guidance is voluntary at the OECD level, but it has been incorporated into binding regulations in several jurisdictions. The EU Conflict Minerals Regulation (2017, in force 2021) requires Union importers of 3TG minerals to perform due diligence consistent with the OECD framework. U.S. Dodd-Frank Section 1502 obligates publicly listed companies to file Conflict Minerals Reports referencing OECD-aligned methodology. The UK, Canada, and several Asian jurisdictions have parallel or complementary requirements.

Further reading

• OECD — Due Diligence Guidance for Responsible Supply Chains of Minerals
• Responsible Jewellery Council
• GIA Gems & Gemology — supply-chain ethics in the gem trade