In this first issue, Luca Maiotti from the OECD (Organisation for Economic Co-operation and Development), provides key insights into the topic of corruption.

What's happening at the LME?

A number of sustainability initiatives are currently underway at the LME. We’re continuing to work hard with the producers of LME-listed brands to ensure that our responsible sourcing rules will be effectively implemented, whilst also focusing efforts on delivering the next steps in our sustainability and LMEpassport strategies. Below is a snapshot of the key elements of the LME’s sustainability strategy. To learn more about the LME’s wider sustainability agenda, visit our sustainability section.

Watch our sustainability webinars

 LME Sustainability overview

There has been good progress since the feedback analysis papers for both sustainability and LMEpassport were published in December 2020. We’ve created an LMEpassport advisory group to ensure that we’re accounting for key stakeholder requirements and a variety of use cases. Our intention is also that this platform will support a broad range of metal sustainability certifications and disclosures electronically, and we’re thankful to those stakeholders who have already played an integral role in advising on the important sustainability categories listed on LMEpassport. In the next issue, we will provide further details on LMEpassport – in the meantime, read more about LMEpassport in our press release.

Responsible sourcing

We’re continuing to work closely with our listed brands, the OECD, auditors, alignment assessors and metals standards bodies in respect of LME responsible sourcing compliance. Currently, most of our brands are either working to ensure their internal systems and processes are set up, and many will already be in their first reporting period. The LME’s sustainability team has established a library of responsible sourcing related webinars covering the contents of our requirements. Most recently, we hosted a webinar on 20 May 2021 where we ran through some FAQs. In the coming months, we will also be releasing Chinese language educational resources. To learn more about the LME’s responsible sourcing requirements, visit our dedicated section.

Responsible sourcing

LME Responsible Sourcing tracks A B and C

New charity partnerships - Pact and the impact facility 

In addition to working with those involved on the compliance side of our responsible sourcing requirements, we have now partnered with charities Pact and The Impact Facility to fund two responsible sourcing projects. We have donated US$1.7 million to these two projects which have the aim of tackling child labour and children’s rights issues in mining communities directly affected by these responsible sourcing concerns. To find out more about these partnerships and the charities involved, please read our press release.

Press release: LME partners with charities Pact and The Impact Facility to fund two responsible sourcing projects

Insight from the market

This issue’s market insight offers a fascinating analysis of corruption in the extractives sector from the OECD’s Luca Maiotti.  Luca is a Policy Analyst in the Minerals Team of the OECD Centre for Responsible Business Conduct. He carries out research on human rights abuses, conflict financing, corruption and money laundering linked to selected mineral supply chains, provides technical policy advice on international legislative and industry-wide developments related to responsible business conduct, and designs capacity building programmes for industry, government and civil society organisations in producing countries.

Addressing corruption risks within the LME's responsible sourcing requirements

In line with the OECD and the EITI's (“Extractive Industries Transparency Initiative”) work in this area, we also prioritise work around managing bribery and corruption risks.  Producers using the LME’s Red Flag Assessment template are required to confirm whether they facilitate the disclosure of potential financial crime and corruption risks in line with the aims of the EITI. Brands using a standard to meet their LME compliance will also be obliged to meet the requirements of that standard in respect of EITI reporting, and the LME will monitor all associated reporting to ensure this issue is meaningfully addressed.

Importantly, the LME requirements urge producers to not only show compliance with EITI reporting requirements within EITI member countries, but also encourage transparency on payments in non-EITI member countries, and we’ll continue to work with the OECD and other stakeholders to ensure the industry-wide development of best practice in Step 5 reporting.

Guest author

Luca Maiotti

Luca Maiotti - Policy analyst, OECD centre for responsible business conduct

Luca carries out research on human rights abuses, conflict financing, corruption and money laundering linked to selected mineral supply chains, provides technical policy advice on international legislative and industry-wide developments related to responsible business conduct, and designs capacity building programmes for industry, government and civil society organisations in producing countries.

Corruption in the extractives industry

What is corruption and why does it matter?

Corruption is a common risk in the extractive sector. The extractives sector (mining, quarrying, oil and gas extraction and mining support services activities) has the potential to sustain livelihoods, foster local development through job creation and skills development, bring much needed tax revenue, and increase investment, particularly in conflict-affected and high-risk areas. However, the sector is prone to corruption; according to the OECD Foreign Bribery Report, one in five cases of foreign bribery occurs in extractives. Corruption, defined as “the abuse of entrusted power for private gain” can range from simple acts such as a cash payment to a border guard, or involve complex networks of enablers, corporate entities and sophisticated financial transactions across multiple jurisdictions. 


Corruption is an enabler of other crimes. Corruption has a wide range of corrosive effects, depriving countries of revenues, undermining the rule of law and hitting vulnerable populations the hardest. It may have disproportionate gendered impacts in the licensing phase, as women represent a higher share of the world’s poor. Furthermore, specific forms of corruption, such as sexual extortion, mostly affect women. The risk of solicitation of sexual extortion can be high in situations of stark power disparity, such as the ones that often accompany artisanal mining, which engages women for almost half its workforce across digging, washing, and trading functions. Beyond the economic impact, corruption in the mining sector causes harm to people and the environment, often as an enabler of serious human rights abuses and lack of enforcement of environmental and labour obligations.

Where and how does it happen?

Corruption may take different forms. Larger companies may be more exposed to grand corruption risks, involving larger sums of money – and the potential for greater harm – around how mining rights were acquired or negotiated, the role of middlemen and subcontractors. Smaller companies and artisanal small scale miners may be more vulnerable to petty corruption, solicitation, sexual exploitation and extortion by government officials and other companies present at mine sites or transport routes. 

According to the US Department of the Treasury’s Office of Foreign Assets Control between 2010 and 2012 alone, the DRC lost over $1.36 billion in revenues from the underpricing of mining assets that were sold to offshore companies linked to sanctioned Israeli businessman Dan Gertler. The Federal Institute for Geosciences and Natural Resources of Germany (BGR) found in a recent study that 40% of artisanal miners of cobalt in the DRC earned less than US$4.20 a day, the country’s minimum wage. Meanwhile, artisanal miners, sometimes working on sites for which Gertler still receives royalties, report they have to pay  unofficial fees amounting to up to 20% of the value of the minerals they produce.  

Why should I care?

Expectations on responsible business conduct are increasing. Regulatory requirements in responsible supply chains are on the rise, investors’ interest continues to grow, with consumers demanding more. Companies are expected to prevent and mitigate adverse impacts on people and the planet, beyond protecting themselves from reputational risks and lawsuits. The LME has introduced responsible sourcing requirements for all brands listed for good delivery on the LME based on the OECD Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance), which also covers aspects of bribery and corruption.

As a company, what can I do about it?  

Look beyond your Tier-1 supplier. The OECD Guidance expects companies to identify, prevent, mitigate, and report on risks of corruption deeper in the supply chain. This includes risks, potentially outside the scope of criminal liability, but nonetheless directly linked to company operations through their mineral and metal purchasing. All types of business relationships across the supply chain fall under this: sub-contractors, third parties, suppliers’ suppliers…  There is still a long way to go, with a Refinitiv survey finding that 43% of third parties are not subject to due diligence checks at onboarding, while 60% of respondents say they are not fully monitoring third parties for ongoing risks.

Don't disengage immediately, but disengage if appropriate. The due diligence approach of the OECD Guidance does not expect immediate disengagement for corruption risks, but encourages companies to drive improvements in the supply chain over time. This flexibility allows companies to tailor their mitigation measures to the complex reality of the ground, but cannot be used as an excuse to avoid taking action, and interrupting the business relationship is expected if there is no significant measurable improvement within six months from the adoption of the risk management plan.

A wealth of resources exist out there to help companies. The OECD Secretariat recently published a Frequently Asked Questions document, which walks users through common challenges that companies face when conducting anti-corruption due diligence in their supply chains. This details:

  • definitions and typologies of corruption risks
  • policies and processes companies should have to monitor corruption risks along their supply chains
  • how companies can prioritise, identify and mitigate corruption risks in their supply chain, and this includes cases of payment requests by traditional or customary institutions, when they are SMEs, or petty corruption
  • how to report on, and remediate, corruption risks

The document also contains a series of high-risk scenarios, lists of red flags and links to resources to conduct open source investigation.

Things to take away

  • Companies need to prioritise anti-corruption efforts in mineral supply chains to prevent and mitigate the impact both on people and the environment, as well as on companies' own reputation and legal liability.
  • Because of the scale, the complexity and the severity of grand corruption risks, specific attention should be paid to large-scale mining in the award of contract and licenses, in the negotiation of compensation and consent of affected communities, and around payment of taxes and fees.
  • The OECD Guidance and the related FAQ provide a progressive framework to complement and articulate compliance efforts that recognises the complexity of conditions of mineral production and trade.

Events and resources

We recently hosted a webinar to answer all the frequently asked questions from stakeholders involved in the responsible sourcing process.  You can watch this and all of our other responsible sourcing webinars by visiting our Responsible Sourcing webinar section.

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Get in touch and get involved!

If you are interested in contributing to a future LME Sustainability Spotlight newsletter please email the Sustainability team. If you have any questions for our team on sustainability or responsible sourcing please contact our team who will be happy to help.

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