Export Control & Sanctions

Regulation — Conflict Minerals

Trace Every Gram.

Comply with Confidence.

Ensuring mineral supply chains are free from conflict financing is a critical component of corporate responsibility and international security. ARTEM provides the digital traceability tools to master your due diligence obligations under the EU Conflict Minerals Regulation.

Understanding Conflict Minerals Due Diligence

1

What are "Conflict Minerals"

The regulation specifically targets the "3TG" minerals: tin, tantalum, tungsten, and their ores, plus gold. These are essential in producing many everyday goods, from electronics and jewellery to automotive and aerospace components.

2

Who is primarily affected

The regulation directly applies to all EU-based importers of 3TG minerals and metals above certain annual volume thresholds. It places the legal responsibility on them to ensure their supply chains are transparent and responsibly managed.

3

What is the core requirement?

The core requirement is to establish and implement a robust supply chain due diligence system. This is not a simple self-declaration; it must be aligned with the internationally recognised OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

The OECD 5-Step Due Diligence Framework

The EU Conflict Minerals Regulation requires importers to adopt a five-step framework to manage their mineral supply chains responsibly and ethically.

Establish Strong Company Management Systems

Adopt a supply chain policy for minerals and structure internal management to support due diligence.

Identify and Assess Risks

Trace the origin of minerals and identify the circumstances of their extraction, trade, and handling to assess risks.

Design and Implement a Strategy to Respond to Risks

Develop and execute a plan to prevent or mitigate identified risks, such as suspending trade or working with suppliers to improve practices.

Carry Out an Independent Third-Party Audit

Have the due diligence practices of smelters and refiners in your supply chain independently audited to verify compliance.

Report Annually on Supply Chain Due Diligence

Publicly report on your due diligence policies and practices, ensuring transparency across your supply chain.

Digital-First Due Diligence

Supply Chain Mapping

We integrate with your procurement systems to map your supply chain, identifying the smelters and refiners that are critical control points for due diligence.

Automated Risk Assessment

Our platform screens your suppliers against databases of conflict-affected and high-risk areas, flagging potential risks for immediate attention and mitigation.

Centralised Document Management

Securely collect, store, and manage all necessary documentation—from supplier declarations to third-party audit reports—creating a single, auditable repository.