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The Cobalt Industry Risk Assessment Framework, CIRAF: A joint NGO statement

We are a group of non-governmental organisations with a focus on business and human rights, and specifically the impact of the mining industry. Members of our group formed the first OECD working group on responsible mineral supply chains and were members of the tripartite drafting committee of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and its gold and tin, tantalum and tungsten supplements. We have also helped frame the OECD Guidelines for Multinational Enterprises and have filed complaints on non-compliance.

We are writing with respect to the proposed Cobalt Industry Risk Assessment Framework (CIRAF), on the understanding that there is not going to be a formal public consultation.

Given the influence of Cobalt Institute (CI) members within the cobalt market, and the continued documentation of abuses and other supply chain red-flags within cobalt supply chains, we write to ensure that the CIRAF adopts all elements of the UN Guiding Principles on Business and Human Rights (UNGPs) - as operationalised in the mining sector by the OECD Guidance. This is the established international standard for responsible business conduct throughout globalised supply chains.

Failure to adopt this standard, in full, will prevent CIRAF from being effective in identifying, preventing and addressing human rights risks and abuses in the cobalt supply chain, which will severely undermine its credibility. The impact of industrial and artisanal cobalt extraction and trading on the human rights and livelihoods of thousands of miners and their communities has been identified and is well-documented.