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Human rights and the minerals supply chain

Gold mine

Human and labor rights violations, exploitation of people to make money to fund conflict, and even environmental abuses have for many years been linked to the minerals industry in the Democratic Republic of the Congo (DRC) and other conflict-affected, high-risk regions.

These high-risk regions are marked by the presence of armed conflict, widespread violence or other risks of harm to people. They are also rich in the minerals needed in many ICT and other products. The majority of the minerals extracted in these regions have to a certain extent brought some modest benefits to the local communities, infrastructure and people.

The term conflict minerals covers minerals from these regions known as the 3TGs - columbite-tantalite or its derivative tantalum, cassiterite or its derivative tin, gold and wolframite or its derivative tungsten. They are used in the design and manufacture of products and components such as those in the ICT industry. The nature of mining in these regions is often artisanal and small scale, often community based and happens using what could be considered basic manual methods. According to some studies 80-90% of mineral production in the DRC for example is being undertaken by between 1 and 2 million artisanal miners who, in turn, support a larger community of 4 -12 million people. (Source: World Bank Promines Project Appraisal)

Companies who work with these minerals are often challenged on their decision to work in these difficult regions. The supply chain between mine and final product owner can be 8-10 tiers deep, with challenges related to traceability of the minerals and supplier source, stability of the region and its government, institutional weaknesses and corruption, widespread violence, human rights abuses, child and forced labor, as well as violation of international law. 

The easiest choice for companies like our own would, in some minds, be to just ban minerals from these regions and inform our suppliers not to engage, and believe that simply by cascading the requirement, there would be no risk of these minerals entering the supply chain. We believe it is better to try to engender change from within by putting in place due diligence processes, collaboration, and training.   

We have chosen to engage in tackling this complex topic, rather than looking the other way. However, we also understand it does not guarantee immunity from the ingrained challenges in this industry and these regions. We also understand we cannot do this alone but through collaboration globally, and on the ground, we hope we can potentially contribute to a more secure and transparent, and fairer supply chain with improved governance that has a positive impact in the region and on its communities.

We use a collaborative and industry approach to tackle this complex issue. Responsible sourcing requires efforts from all stakeholders: governments, private companies, industry associations, non-governmental organizations, and civil society to secure and stabilize Conflict-Affected and High-Risk Areas (CAHRAs) worldwide. While we cannot address all causes of conflict and human rights issues, having in a place a strong due diligence framework helps to better understand and manage risks that link minerals and conflict as well as facilitate better decision making to support our responsible sourcing efforts.

Nokia conflict-free and responsible minerals sourcing process is designed according to the OECD 5-step framework (see link below).

Our core focus for the past ten years has been on ensuring the traceability of minerals so that we know where those minerals are refined and their origin (from which countries are they extracted). This has meant primarily working on the downstream part of the supply chain (our tier 1-2-3 suppliers down to the smelters and refiners of the metals). Today we can say that we have identified 96% of the smelters and refiners who refine tin, tantalum, tungsten and gold in the supply chain of our products.

We also published our latest Conflict Minerals Report in May 2020 in line with requirements. The below diagram shows an overview of our findings related to Conflict Free supply chain enquiry for 2019:

flow diagram

In parallel we have been working on the upstream part of the supply chain – from smelter to the mine and trying to ensure that all of the sources are validated as conflict free using third-party audits through documented evidence. Such efforts included contributing to the set up of an independent industry third-party mechanism with the aim to ensure that upstream sourcing (smelter – mine) is fully traceable and conducted in line with OECD due-diligence guidelines. Convincing smelters and refiners to go through independent third-party audits to prove non-conflict origin of their minerals has also been quite a challenge, as for smelters we are neither the direct or visible customers, nor do they see the direct benefits of getting engaged in the complexity of traceability and participation in responsible trading schemes for minerals further upstream.

Our principle remains to support minerals supply chains in the conflicted affected region as long as they are conducted in line with OECD guidelines and successfully pass the audits. For the upstream part, we have relied on industry collaborations such the Public Private Alliance to support empowerment of regional stakeholders and ensure the supply of traceable and conflict-free minerals sourcing from the affected region. On top of our supplier audits, if we find or become aware of potential human rights abuses, we conduct a thorough investigation, determine if the associated mines are part of our supply chain and put in place the necessary plan for correction, remediation and potential exclusion of the mine in question.

Although today we can claim that established traceability schemes on the ground are operating, the amount of such clean minerals going out from conflicted-affected countries, are small. Through the Public Private Alliance we participate in cross-sectoral collaboration to try to make conflict-free minerals the norm rather than the exception and to help local communities benefit from their minerals.

In December 2019 we were part of an industry delegation to the Great Lakes Region in Africa. Through mine site visits and meetings in Kinshasa, Goma, Bukavu, and Kigali, we engaged with a range of stakeholders, including national and provincial governments, upstream supply chain actors, due diligence systems, and local civil society organizations. Sustainable change in the region is required to ensure that responsible trade of minerals is not an isolated activity through some closed loop schemes facilitated by western ICT companies and interested stakeholders but becomes a mainstream activity. The latter requires systemic empowerment of local stakeholders and good collaboration from all.

More information:

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Elina Rääsk

About Elina Rääsk

Elina Rääsk works in the Nokia Supply Quality Department. She is the Sustainable Operations Manager overseeing sustainable supply chain and procurement strategy.

Elina joined Nokia Global Procurement Organization in 2009, and has been engaged in procurement related sustainability activities since then, including supplier audits, assessments, supplier learning and capability building, industry collaboration across a broad scope of topics such as labour rights, modern slavery, health and safety, climate change, and conflict minerals. Since then her role has evolved into strategic deployment and management of sustainability topics across supply chain organization.

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