Due diligence

Responsible sourcing

Buyers increasingly require supply-chain evidence as a condition of purchase, not as a courtesy. Requirements vary by buyer, material and route.

Malachite mineral specimen
MalachiteKelly Martin · CC BY-SA 2.5 · Source and licenceIllustrative specimen; not TGRALIN inventory.

What may be required

The following are the considerations that commonly arise in mineral supply-chain due diligence. Which of them apply to a given transaction depends on the buyer, the jurisdiction, the material and the destination market.

  • Know your customer

    Identity and standing of the counterparty, and of the people behind it.

  • Beneficial ownership

    Who ultimately owns or controls the entity.

  • Sanctions screening

    Against the regimes applicable to the parties and the route.

  • Legal source

    That the material was lawfully won and lawfully held.

  • Authority to sell

    That the seller may lawfully sell, market or export it.

  • Mineral title and source

    Verification of the origin of the material.

  • Chain of custody

    The documented path from source to the point of sale.

  • Royalty and regulatory evidence

    That applicable obligations have been met.

  • Labour and human rights

    Conditions at and around the point of extraction.

  • Environmental and regulatory

    Where relevant to the material and jurisdiction.

  • Conflict-affected and high-risk areas

    Where applicable to the origin in question.

  • Buyer-specific requirements

    Many industrial buyers impose their own additional standards.

Standards and alignment

TGRALIN's approach to supply-chain due diligence is informed by the OECD framework for responsible mineral supply chains, and by the requirements buyers themselves impose.

TGRALIN is not certified by the OECD, the Responsible Minerals Initiative, or any regulator, and does not act as a certification authority. Nothing on this site should be read as certification, accreditation or regulatory endorsement.

Where a buyer requires certification from an accredited scheme, that certification must come from the scheme itself. Mineral Radar's role is to establish what evidence exists and what is missing against that requirement.

Why this helps smaller participants

Responsible-sourcing requirements are often assumed to shut small operators out. In practice what shuts them out is not being told, early and specifically, what is expected.

A small trader who knows at the outset which five documents a buyer's compliance team will demand has a reasonable chance of assembling them. The same trader who discovers the requirement after agreeing a price usually does not.