March 10, 2022
In light of the government sanctions against Russia, the Responsible Business Alliance (RBA) and its Responsible Minerals Initiative (RMI) are consulting with legal counsel and evaluating impacts on their respective audit programs. The list of the RMI smelters and refiners participating in the Responsible Minerals Assurance Process (RMAP) audit program, including those based in Russia, is available here. Currently there are not any VAP audits scheduled in Russia.
As part of auditee onboarding, the RBA and RMI collect information on auditees’ company structures and direct and beneficial ownership. The RBA and RMI are also now asking all Russia-based auditees participating in the RBA VAP or RMI RMAP to provide current information on structure and direct and beneficial ownership to verify any potential impacts of the new sanctions on conformant status or eligibility.
Furthermore, the RMAP Standard requires auditees to conduct know-your-customer (KYC) sanctions checks on their suppliers, and not meeting those requirements or completing required corrective actions will result in removal from the RMI’s public Conformant list.
The RBA and RMI will continue to monitor this situation as it evolves and will communicate with its members, auditees, and auditors about any developments impacting the RBA’s or RMI’s operations and audit programs. The RBA and RMI recommend that companies consult with their legal counsel for the direct impacts on their operations and supply chains.
In addition, given the context, members should also prioritize applying enhanced supply chain due diligence in line with international standards to ensure they are:
- Protecting physical safety and mental well-being of your employees to the extent possible
- Complying with international sanctions
- Not causing or, through their business relationships, contributing to adverse human rights impacts
- Following internationally accepted principles for responsible disengagement to mitigate unintended consequences, if suspending operations temporarily or permanently
- Participating in remediation where appropriate, including where directly linked to adverse human rights impact through business relationships
The UN Guiding Principles on Business and Human Rights, OECD Due Diligence Guidance for Responsible Business Conduct and OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provide the foundational principles and expectations for member review.
