Case study: Implementing human rights due diligence in a minerals supply chain

Why It Matters

The International Labour Organization estimated in 2024 that 27.6 million people remain trapped in forced labor globally, with extractive industries and mineral supply chains among the highest-risk sectors (ILO, 2024). For technology manufacturers, the minerals that power semiconductors, batteries, and electronic components, including tin, tantalum, tungsten, gold (3TG), cobalt, and lithium, are sourced from regions where child labor, armed conflict financing, and environmental destruction persist. The EU Conflict Minerals Regulation, fully enforced since January 2021, and the incoming Corporate Sustainability Due Diligence Directive (CSDDD), applicable from 2026, have transformed human rights due diligence from a voluntary commitment into a legal obligation. Yet a 2025 survey by the Responsible Minerals Initiative (RMI) found that only 34 percent of downstream technology companies had implemented due diligence programs extending beyond Tier 1 suppliers. This case study examines how Apple built one of the most comprehensive human rights due diligence programs in the minerals sector, detailing the frameworks, tools, and remediation mechanisms that enabled measurable outcomes.

Key Concepts

Human rights due diligence (HRDD) is a continuous process through which companies identify, prevent, mitigate, and account for adverse human rights impacts in their operations and supply chains. The UN Guiding Principles on Business and Human Rights (2011) established the authoritative framework, and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) provides the operational standard for the minerals sector.

Conflict minerals refer to 3TG minerals (tin, tantalum, tungsten, and gold) sourced from conflict-affected and high-risk areas, particularly the Democratic Republic of the Congo (DRC) and adjoining countries. Regulatory frameworks including the US Dodd-Frank Act Section 1502 and the EU Conflict Minerals Regulation require importers and manufacturers to trace the origin of these minerals and assess human rights risks.

Smelter and refiner validation is the critical control point in mineral supply chains. Because minerals are commingled during processing, tracing origin requires validation at the smelter or refiner level. The Responsible Minerals Assurance Process (RMAP), managed by RMI, provides third-party audits of smelters and refiners against OECD-aligned standards.

Scope expansion beyond 3TG has accelerated since 2023. Cobalt, lithium, mica, and nickel are now subject to similar scrutiny as electric vehicle and battery demand surges. The EU Battery Regulation (2023) mandates cobalt and lithium due diligence for all batteries placed on the European market from 2025.

The Challenge

Apple's supply chain for minerals spans more than 50 countries and involves hundreds of smelters and refiners that process raw materials before they enter component manufacturing. Several structural challenges made human rights due diligence exceptionally difficult.

Opacity beyond Tier 1. Apple's direct contractual relationships are with component manufacturers (Tier 1), not the smelters (Tier 2) or mines (Tier 3 and beyond) where the most severe human rights risks occur. A 2024 report by the European Partnership for Responsible Minerals (EPRM) found that only 18 percent of downstream companies had direct visibility into mining-level conditions. Reaching artisanal and small-scale mining (ASM) operations, which produce roughly 20 percent of global cobalt and significant shares of 3TG minerals, required entirely different engagement approaches.

Commingling and traceability gaps. Once minerals leave a mine, they are aggregated, traded, and blended at multiple points before reaching a smelter. This commingling makes batch-level traceability nearly impossible without dedicated chain-of-custody systems. The OECD (2024) noted that fewer than 30 percent of smelters processing minerals from high-risk areas maintained full chain-of-custody documentation.

Regulatory fragmentation. Apple sells products in markets governed by different due diligence requirements: the US Dodd-Frank Act focuses narrowly on 3TG from the DRC region, the EU Conflict Minerals Regulation covers 3TG from all conflict-affected areas, and the incoming CSDDD requires broader human rights and environmental due diligence. Harmonizing compliance across these regimes while maintaining a single global program posed significant governance challenges.

Remediation complexity. When abuses were identified, such as child labor at artisanal cobalt mines in the DRC, simply cutting off sourcing risked economic harm to communities dependent on mining income. Responsible disengagement required investment in alternative livelihoods, education programs, and formalization of ASM operations.

The Approach

Apple's Responsible Sourcing program, documented in its annual Supplier Responsibility Progress Reports and third-party assessments, followed a multi-layered strategy aligned with the OECD Guidance's five-step framework.

1. Comprehensive smelter and refiner mapping. Apple required all Tier 1 suppliers to identify every smelter and refiner in their supply chains for 3TG minerals, cobalt, and lithium. By 2025, Apple had mapped 100 percent of identified smelters and refiners for 3TG and cobalt, totaling over 300 facilities across 35 countries (Apple, 2025). The company published its full smelter and refiner list annually, a transparency measure that fewer than 15 percent of technology companies replicated, according to the Responsible Sourcing Network (2025).

2. RMAP participation and independent audits. Apple required all identified smelters and refiners to participate in the RMAP or an equivalent third-party audit program. Facilities that refused or failed audits were removed from the supply chain. By 2025, 100 percent of identified 3TG smelters and refiners were participating in third-party audits, and Apple had removed 174 smelters and refiners from its supply chain since 2009 for non-compliance (Apple, 2025).

3. On-the-ground mine-level assessments. Beginning in 2016 and expanding through 2025, Apple funded and participated in mine-site assessments in the DRC and other high-risk regions. The company partnered with the Fund for Global Human Rights and local civil society organizations to conduct assessments covering labor conditions, safety practices, environmental impacts, and community consent. By 2024, Apple had completed assessments at over 130 mine sites (Apple, 2024). These assessments informed risk ratings that determined sourcing decisions and remediation investments.

4. Remediation and community investment. Rather than blanket disengagement from high-risk regions, Apple invested in programs to formalize artisanal mining and address root causes of labor abuses. Through partnerships with Pact International, Apple funded the Mines to Markets program in the DRC, which provided training on safety, environmental management, and child labor prevention to over 20,000 artisanal miners between 2019 and 2025 (Pact, 2025). The company also supported education programs that enrolled over 6,500 children identified as at risk of or engaged in child labor in the cobalt supply chain.

5. Technology-enabled traceability. Apple piloted blockchain-based traceability for cobalt sourced from the DRC in partnership with RCS Global (now part of Sphera). The pilot tracked cobalt from mine to smelter using tamper-evident bags, GPS tracking, and distributed ledger technology. While blockchain alone could not solve commingling challenges at scale, it demonstrated proof-of-concept for batch-level tracing in high-risk supply chains. Samsung SDI and LG Energy Solution adopted similar pilots for battery-grade cobalt by 2025, signaling industry-wide momentum (RCS Global, 2025).

Intel provides an instructive comparison. Intel's Responsible Minerals Sourcing program achieved 100 percent RMAP-conformant smelters for 3TG by 2024 and expanded due diligence to cobalt and mica. Intel's approach differed from Apple's in emphasizing industry collaboration through its co-founding role in the Responsible Minerals Initiative, focusing on systemic infrastructure rather than company-specific mine-level engagement (Intel, 2025).

Results and Impact

Apple's program has produced measurable outcomes across several dimensions:

• Smelter compliance: 100 percent of identified 3TG smelters and refiners participating in third-party audit programs as of 2025, up from 59 percent in 2014.
• Supply chain removals: 174 smelters and refiners removed from the supply chain for non-compliance since 2009, demonstrating credible enforcement.
• Mine-site coverage: Over 130 mine sites assessed in high-risk areas, with risk ratings informing ongoing sourcing decisions.
• Child labor remediation: Over 6,500 children enrolled in education programs in DRC cobalt mining communities; Pact (2025) reported a 48 percent reduction in child labor incidence at monitored ASM sites between 2019 and 2024.
• Regulatory compliance: Full compliance with the EU Conflict Minerals Regulation, US Dodd-Frank Section 1502 reporting requirements, and early alignment with CSDDD due diligence standards.
• Industry influence: Apple's annual smelter list publication and public reporting set a benchmark that influenced due diligence expectations across the technology sector. RMI (2025) reported that the number of companies using RMAP-audited smelters grew from 350 in 2020 to over 500 in 2025.

Lessons Learned

Traceability requires collaboration, not just technology. Blockchain and digital tools provide useful verification layers, but they cannot replace on-the-ground engagement. Mine-level assessments, community partnerships, and smelter audits form the foundation of effective traceability. Technology amplifies these efforts rather than substituting for them.

Disengagement must be a last resort. Cutting off high-risk suppliers or regions can push abuses further underground and harm communities dependent on mining income. Apple's remediation-first approach, investing in formalization and education before resorting to supply chain removal, produced better outcomes than blanket boycotts.

Industry-wide standards reduce costs and increase leverage. Apple's use of the RMAP audit framework, rather than a proprietary audit standard, allowed costs to be shared across the industry and gave smelters a single standard to meet. Companies acting alone face higher costs and weaker bargaining positions.

Scope expansion is inevitable. Programs designed solely for 3TG compliance proved insufficient as cobalt, lithium, and mica entered regulatory scope. Companies that built flexible, risk-based due diligence systems adapted more quickly than those with mineral-specific compliance checklists.

Transparency builds credibility. Publishing the full smelter list, mine-site assessment results, and remediation outcomes annually exposed Apple to scrutiny but also built trust with regulators, investors, and civil society. Opacity, by contrast, invites suspicion regardless of actual performance.

Key Players

Established Leaders

• Apple — Operates one of the most comprehensive minerals due diligence programs, covering 300+ smelters and refiners with 100 percent third-party audit participation for 3TG and cobalt.
• Intel — Co-founder of the Responsible Minerals Initiative with 100 percent RMAP-conformant 3TG smelters since 2024 and expanded due diligence to cobalt and mica.
• Responsible Minerals Initiative (RMI) — Industry coalition managing the RMAP audit program covering 400+ smelters and refiners globally.
• OECD — Author of the Due Diligence Guidance for Responsible Supply Chains of Minerals, the global standard for minerals HRDD.

Emerging Startups

• Circulor — Provides supply chain traceability platform using IoT, AI, and blockchain for minerals including cobalt, lithium, and tantalum.
• Minespider — Blockchain-based mineral provenance tracking platform enabling mine-to-manufacturer traceability.
• Re|Source — Joint venture by Glencore, Umicore, and others providing blockchain-enabled cobalt traceability from DRC mines to battery cathodes.
• Doconomy — Impact measurement platform integrating human rights and environmental risk scoring into supply chain procurement decisions.

Key Investors/Funders

• European Partnership for Responsible Minerals (EPRM) — Multi-stakeholder fund investing in responsible ASM practices and community development in mining regions.
• Fund for Global Human Rights — Supports civil society organizations conducting independent monitoring of mining conditions in conflict-affected areas.
• Global Battery Alliance — World Economic Forum initiative mobilizing investment for responsible battery supply chains including cobalt and lithium due diligence infrastructure.

Action Checklist

• Map all smelters and refiners in your supply chain for 3TG, cobalt, lithium, and any other minerals subject to regulatory due diligence requirements.
• Require all identified smelters and refiners to participate in RMAP or an equivalent OECD-aligned third-party audit program and set a timeline for compliance.
• Conduct risk assessments for each mineral supply chain using the OECD five-step due diligence framework, prioritizing conflict-affected and high-risk areas.
• Establish a clear escalation and remediation policy: engagement first, capacity building second, disengagement only as a last resort after documented failure to improve.
• Invest in on-the-ground programs at high-risk mine sites, either directly or through partnerships with organizations such as Pact, EPRM, or local civil society groups.
• Publish your smelter and refiner list and due diligence findings annually to build transparency and stakeholder trust.
• Extend due diligence scope beyond 3TG to include cobalt, lithium, mica, and nickel in anticipation of evolving regulatory requirements (EU Battery Regulation, CSDDD).
• Integrate human rights risk scores into procurement decisions, weighting them alongside cost, quality, and delivery performance.

FAQ

What is the difference between the EU Conflict Minerals Regulation and the CSDDD? The EU Conflict Minerals Regulation (in force since 2021) applies specifically to EU importers of 3TG minerals and requires OECD-aligned due diligence for supply chains originating in conflict-affected areas. The CSDDD (applicable from 2026) is broader: it covers all adverse human rights and environmental impacts across the entire value chain, not just minerals, and applies to large EU and non-EU companies meeting revenue thresholds. Companies already compliant with the Conflict Minerals Regulation will need to expand their programs significantly to meet CSDDD requirements.

How much does a minerals due diligence program cost? Costs depend on supply chain complexity and program maturity. RMI membership fees range from $5,000 to $50,000 annually depending on company size. Individual RMAP smelter audits cost approximately $15,000 to $30,000 per facility, though these costs are typically borne by the smelter or shared across downstream users. Apple's program, which includes mine-site assessments and community investments, represents a multi-million dollar annual commitment, but mid-sized companies can achieve meaningful due diligence by leveraging shared industry infrastructure like RMAP at significantly lower cost.

Can smaller companies implement effective minerals due diligence? Yes. RMI's tools, including the Conflict Minerals Reporting Template (CMRT) and the Cobalt Reporting Template (CRT), are freely available and allow companies of any size to collect smelter information from their suppliers. Smaller companies can require RMAP participation from smelters in their supply chain without conducting their own audits. Industry coalitions such as the Responsible Minerals Initiative and the Responsible Business Alliance provide shared resources, training, and audit infrastructure that reduce per-company costs.

What happens when a smelter fails an RMAP audit? The smelter enters a corrective action process with a defined timeline to address identified non-conformances. If the smelter fails to remediate within the allotted period, it loses its conformant status and is flagged in the RMAP system. Downstream companies like Apple and Intel then engage the smelter to encourage improvement or, if no progress is made, remove the smelter from their approved supply chain. RMI (2025) reports that 85 percent of smelters entering corrective action achieve conformant status within 12 months.

How is artisanal and small-scale mining addressed in due diligence programs? ASM operations produce significant volumes of 3TG and cobalt but often lack the formalization, safety standards, and documentation required by audit programs. Leading approaches combine formalization support (training, equipment, cooperative development), community investment (education, health), and traceability pilots (tagged bags, GPS, blockchain). The goal is to integrate responsible ASM into global supply chains rather than exclude it, which would harm the livelihoods of an estimated 40 million people who depend on artisanal mining worldwide (World Bank, 2024).

Sources

• ILO. (2024). Global Estimates of Modern Slavery: Forced Labour and Forced Marriage. International Labour Organization.
• Apple. (2024). Supplier Responsibility Progress Report 2024: Responsible Sourcing of Materials. Apple Inc.
• Apple. (2025). Supplier Responsibility Progress Report 2025: Smelter and Refiner List and Due Diligence Outcomes. Apple Inc.
• Responsible Minerals Initiative. (2025). RMAP Annual Report 2025: Audit Coverage, Conformance Rates, and Industry Adoption. RMI.
• OECD. (2024). Implementing the Due Diligence Guidance: Progress and Challenges in Mineral Supply Chains. Organisation for Economic Co-operation and Development.
• Pact. (2025). Mines to Markets Program Report: Artisanal Mining Formalization and Child Labor Reduction Outcomes in the DRC. Pact International.
• European Partnership for Responsible Minerals. (2024). Downstream Due Diligence Practices: Survey of Technology Sector Companies. EPRM.
• RCS Global. (2025). Blockchain Traceability for Responsible Cobalt: Pilot Results and Scalability Assessment. Sphera (formerly RCS Global).
• Intel. (2025). Corporate Responsibility Report 2025: Responsible Minerals Sourcing Program Update. Intel Corporation.
• Responsible Sourcing Network. (2025). Mining the Disclosures 2025: Transparency Benchmarking of Electronics and Automotive Companies. RSN.
• World Bank. (2024). State of the Artisanal and Small-Scale Mining Sector 2024. World Bank Group.