EU Conflict Minerals Regulation term for a supply-chain policy conforming to OECD Due Diligence Guidance Annex II risk language.
Model supply chain policy is a policy-basis term. It should identify the OECD Annex II risk categories and sourcing scope, then connect policy commitments to controls such as custody records, grievance mechanisms, risk-management plans, and disclosures.
Regulation (EU) 2017/821 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas
a supply chain policy that conforms to Annex II to the OECD Due Diligence Guidance outlining the risks of significant adverse impacts which may be associated with the extraction, trade, and handling of minerals in and export of minerals from conflict-affected and high-risk areas
Article 2 definitions for EU conflict-minerals due diligence. Source-specific to tin, tantalum, tungsten, their ores, and gold.
Reference: Article 2, point (q)
Implementation records should capture the policy document, OECD Annex II risk, sourcing-activity scope, adopted version, covered minerals/metals, supplier or smelter/refiner expectations, grievance route, escalation rules, and links to risk-management or disclosure records.
A model supply chain policy is a policy-control anchor: it gives due-diligence risk language a documented home, but it still needs evidence that the policy is adopted, communicated, applied, and connected to actual risk decisions.