In this document, we present an overview of key improvement priorities for the years 2024-2025. Some of the listed actions have been completed in 2024 and are identified with an asterisk (*). Other actions have started in 2024 and are ongoing; these are identified with two asterisks (**).
We aim to complete all these actions in 2025, while taking into account that external factors, including actions from non-state armed groups such as M23, may negatively impact our progress. We will continue to provide updates on achievements in our public annual reports.
I. Improvements on ITSCI’s implementation of aligned standards to the OECD 5-step framework
Actions described in this section are part of a long-term plan to improve ITSCI implementation, including increasing capacity building, support and information available to ITSCI members to strengthen their own due diligence. Our current implementation aims are to accelerate initiation of new member companies, the timing of exchange between ITSCI and members on traceability, and the roll-out of traceability digitisation. We also continue to strengthen controls on reporting from mine sites and emphasise the importance of risk identification according to OECD Annex II risks via revised incident processes. These improvements combined with additional support for our member’s due diligence understanding, including of management systems, aim to improve performance overall.
1. Improving and accelerating ITSCI member processes
- Initiated a review of member preliminary audit processes to identify opportunities to increase internal and external efficiencies and reduce processing time. **
- Drafting a revised preliminary audit report template re-formatted to explicitly reference OECD Steps to add clarity. **
- Formally incorporating ITSCI field team support and inputs into preliminary audit communication and information review.
- Providing clear and actionable guidance to applicant members on how to complete their applications, including the structure and content of a company management plan.
2. Facilitating improved company management systems
- Increasing capacity building for applicant company’s understanding of the OECD Guidance and associated ITSCI membership expectations.
- Developing dedicated training on due diligence practices for every new member, including to support company implementation of ITSCI recommendations.
- Initiated a review of ITSCI on-site audit purpose and processes to evaluate potential for more regular in-house control checks. **
3. Building capacities of ITSCI members and stakeholders
- Developing and sharing factsheets clarifying the scope of the ITSCI Programme, the qualification of ITSCI teams, and how ITSCI information may be used as part of companies’ due diligence. **
- Initiating detailed mapping of ITSCI information against OECD Steps, and against external smelter audit system requirements, to clarify ITSCI’s role in company due diligence. **
- Adapted an existing DRC exporter training manual to the Rwandan context and distributed the manual to all Rwandan exporters during a dedicated training. *
4. Rolling-out improved digitised traceability tools
- Rolling out electronic and digitised data collection in Rwanda at mine, processor, and exporter level, following final discussion and agreement with the Rwandan government. **
- Rolling out automated reports for traceability of each export shipment provided to ITSCI smelter members to more rapidly inform their due diligence to all mines of origin. While traceability has always been provided to smelters, the complexity of ASM supply chains has previously required a portion of manual data processing and verification. **
5. Accelerating information exchange by clarifying ITSCI member reporting requirements
- Clarified shipment delivery reporting requirements for exporters, traders and smelters to reduce delays in member’s information sharing with ITSCI. **
- Introduced explicit timelines for shipment delivery reporting and levy payments by members to reduce information gaps for smelter’s due diligence. **
6. Improving on-the-ground monitoring and reporting processes
- Strengthened the programme-level oversight and planning of mine visits, with the set-up of a centralised database to record every visit to all ITSCI-monitored sites and exporters. *
- Revised mine baseline assessment template explicitly formatted to Annex II risks and removing the need for redaction enabling smelters to more easily relate this information to ITSCI incidents. *
- Updated the induction and training for the ITSCI reporting team to improve and accelerate onboarding of new staff members and strengthen team consistency and coordination. *
7. Improved support to company risk identification and mitigation
- Updating our incident matrix to incorporate lessons learned from recent experiences and improve consistency of incident classification and reporting. **
- Improving communication of the incident matrix summary to ITSCI members in incident alerts, monthly reports and during induction training.
- Improving our high-risk incident alerts to better explain incident categories and how these correspond to OECD Annex II risks as well as using more action-oriented language.
- Adding a confidential summary of every new member’s public preliminary audit to share non-public ownership and other details with other ITSCI members.
- Facilitating improved Know-Your-Supplier (KYS) information sharing between ITSCI exporters, international traders and smelters as relevant to their own supply chains. **
II. Improvement on the governance of the ITSCI Programme
Both the 2018 and 2023 Alignment Assessments of ITSCI have recommended the development of a formal organisational structure adapted to the programme’s scale, including for instance by transitioning to a stand-alone organisation. The AA further recommended ITSCI to strengthen the programme’s governance and improve formal oversight through a supervisory board structure. To achieve these recommendations, it is necessary to establish ITSCI as a legal entity and actions have been taken to progress that. Internal and external communication is evaluated as part of any AA and ITSCI is making broader efforts to enhance communication, aiming to better explain the ITSCI Programme activities as well as members companies’ responsibilities and clearly convey both our challenges and strengths.
1. Establishing ITSCI as a stand-alone, not-for-profit Company Limited by Guarantee
- Engaged a legal firm to provide advice on corporate structure and the ongoing process. *
- Evaluated a range of legal entity types with the resulting choice to move to a stand-alone, not-for-profit Company Limited by Guarantee (CLG). *
- Developed a transition plan mapping out necessary legal, financial and logistical steps and actions to achieve such transition. *
- Contracting expert firms to provide support in relevant areas including human resources.
- Drafting a document outlining the role and responsibilities of a future Board of Directors (BoD), to which the current ITSCI Governance Committee is expected to transition. **
- Initiating consultation on the future BoD, which both ITA and T.I.C. will have the opportunity to join, with the aim to appoint additional representatives to broaden the expertise and strengthen the oversight of the Programme. **
- Looking for financial support to speed-up the implementation of the legal entity transition.
- Completing all necessary tasks during 2025 to enable transition to a CLG in January 2026.
2. Improving ITSCI communications
- Appointed a senior ITSCI staff expert in communication to drive ITSCI communications and engagement strategy. *
- Standardising all ITSCI reporting to explicitly follow the OECD-5 step Framework, including our public ITSCI quarterly overviews and annual reports as well as ITSCI members confidential monthly reports. *
- Increasing engagement with ITSCI Associate downstream members through quarterly webinars including deep dives in specific ITSCI topics, projects, challenges, etc. **
- Developing new ITSCI visual communication tools to improve general understanding of how the ITSCI Programme works. **
- Re-confirmed to all stakeholders that ITSCI is not a certification system but a facilitation initiative. *
3. Raising funding to underpin existing and improved ITSCI activities
- Developing thematic overviews of funding opportunities to support ITSCI programme activities covering different topics (ESG, due diligence, women’s and human rights, gender, digitisation, etc.). **
- Secured funding from an ITSCI Associate Member for a 2-year project on Occupational Health and Safety, mining rights, gender, and women’s rights. *
Concluding remarks
Since 2010, ITSCI has grown, from one pilot site to large-scale implementation with the monitoring of approximately 3,000 mine sites over four countries in the Great Lakes Region and the support to company members across 47 countries. In the past 15 years, ITSCI has helped to drive significant improvements in mineral supply chains in Conflict-Affected and High-Risk Areas (CAHRA) including Dodd-Frank Countries. We have shown that facilitating effective due diligence on minerals from CAHRA leads to long-term and lasting change at scale. We are proud to continue our work, with our member companies, partners and stakeholders, in maintaining standards in due diligence and deliver real and positive outcomes on the ground.
Given the very dynamic and rapidly evolving nature of our work and complex local contexts in CAHRA, our plan can be disrupted by other events, for instance by extensive presence of non-state armed groups as currently seen in North and South Kivu Provinces. Such events require immediate and dedicated focus and resources and may therefore impact current progress and result in adjustments in our priorities or actions. The non-exhaustive list of planned improvements and actions presented in this document is therefore subject to ongoing review and adjustments.
We will regularly review our progress and update, based on the programme’s overall strategy and theory of change, practicalities, and cost/benefit.
Useful links
- First Alignment Assessment of the ITSCI Programme (2018)
- Second Alignment Assessment of the ITSCI Programme (2023)
- ITSCI 2023 annual report with an overview of improvements achieved in 2019-2023
- ITSCI Theory of change
Contact
Contact us at [email protected]
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