Due Diligence Management Plan for Mineral Traders
Aligned with ITSCI & OECD Due Diligence Guidance
Date: 12/04/2025
Company: Atlas G Enterprise Ltd
1. Introduction
This Due Diligence Management Plan Outlines Atlas G Enterprise’s policies and procedures for
the responsible sourcing and trading of 3T minerals (tin, tantalum, tungsten). It aligns with the
International Tin Supply Chain Initiative (ITSCI) and the OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
As a mineral trader, Atlas G Enterprise Ltd plays a critical role in the upstream mineral supply
chain. This plan ensures compliance with industry standards, promotes traceability, and helps
prevent the financing of conflict and human rights abuses.
2. Objectives
Source and trade 3T minerals in a responsible, transparent, and traceable manner.
Comply with ITSCI and OECD due diligence requirements.
Build trust with suppliers, buyers, regulators, and industry stakeholders.
Identify, assess, and mitigate risks associated with the mineral trade.
3. ITSCI Overview for Traders
ITSCI provides due diligence tools and traceability for the upstream 3T mineral supply chain, especially in Central Africa. For traders, ITSCI offers:
A tagging system for traceability (from mine to export)
Incident reporting and risk alerts
Access to verified supply chain actors (e.g., mine sites, cooperatives, exporters)
Guidance on risk mitigation procedures
4. Due Diligence Framework (OECD 5-Step Approach for Traders)
Step 1: Establish Strong Company Management Systems
Key Actions:
Develop and publish a Responsible Sourcing Policy specific to mineral trading.
Appoint a Compliance Officer or team responsible for due diligence implementation.
Integrate responsible sourcing clauses into supplier agreements.
Establish and communicate a grievance mechanism for stakeholders (e.g., suppliers, employees, civil society).
Maintain organized and accessible documentation (tags, purchase logs, transport records, export data).
Step 2: Identify and Assess Risks in the Supply Chain
Key Actions:
Map the origin of all sourced minerals (down to mine site level).
Verify all suppliers (mine sites, cooperatives, transporters, and exporters) are ITSCI participants or otherwise validated.
Review ITSCI incident reports and alerts involving suppliers.
Assess:
o Location risks (conflict zones, high-risk transit routes)
o Supplier behavior (e.g., illegal taxation, human rights concerns)
o Chain-of-custody integrity
Step 3: Design and Implement a Risk Management Plan
Key Actions:
Flag any supplier or transaction identified as high risk.
Notify suppliers of identified risks and require a Corrective Action Plan (CAP).
Work collaboratively with suppliers to implement CAPs, using ITSCI guidance where applicable.
Suspend or disengage with suppliers who do not remediate risks in an acceptable timeframe.
Provide regular training to procurement staff on responsible sourcing.
Step 4: Support Third-Party Audits
Key Actions:
Cooperate with third-party audits of upstream supply chains.
Provide access to ITSCI tags, transport logs, and purchase records.
Respond to any findings with remediation plans and internal improvements.
Engage only with smelters/refiners that are part of audit-verified programs (e.g., RMI, ITSCI-affiliated).
Step 5: Report Annually on Due Diligence
Key Actions:
Publish or provide annual due diligence reports including:
o Responsible sourcing policy;
o Risk identification and mitigation activities;
o ITSCI participation details;
o Countries of origin and key actors in the supply chain.
Be prepared to submit documentation to buyers, industry groups, or regulators upon request.
5. Ongoing Monitoring and Continuous Improvement
Monitor ITSCI incident reports and risk alerts monthly.
Periodically review supplier performance and compliance.
Update the company’s due diligence procedures annually.
Stay informed through industry networks and ITSCI communications.
Engage in multi-stakeholder dialogues to improve sourcing practices.
6. Summary
As a mineral trader, Atlas G Enterprise Ltd commits to conducting robust due diligence and
complying with ITSCI and OECD requirements. This plan ensures our trading activities support
ethical sourcing, transparency, and responsible mineral supply chains from mine to market.
7. Contact Information
Compliance Department
Atlas G Enterprise Ltd
info@atlasgenterprise.com
www.atlasgenterprise.com
+250782469711