Conflict Mineral Supply Chains
A development finance institution needed to assess responsible-sourcing exposure beyond periodic certification. Reporting established armed control, failures of field verification and cross-border diversion within the supply chain. The client engaged investees on exposures that the certification had masked.
A development finance institution with exposure to certified supply chains in a conflict-affected extraction zone faced questions on responsible sourcing. Portfolio holdings passed periodic audits.
Armed groups controlled extraction sites, yet certification continued uninterrupted. The state's own enforcement commander acknowledged that all production qualified as conflict minerals and that international standards were no longer met. No suspension came. Permits arrived from provincial capitals without field verification. Inspectors received no salary and survived on payments from the trading houses they regulated: twenty dollars to look away. A regional executive reduced fraud penalties from full seizure to thirty per cent; with prices across the border running higher, smuggling became rational. No scales existed at customs; the declared tonnage was the tonnage. The insurgency operated customs that traders found more predictable; a neighbouring military secured corridors for a fee. Production crossed borders into transit-state statistics. The producing state stationed agents at a foreign port to verify that goods transiting the neighbour arrived. Sovereignty ended at the frontier.
The client engaged investees on the exposures that certification had masked.
The mandates below are drawn from hundreds of engagements over fifteen years, including work predating Periplus. Specific parties, jurisdictions and instructing firms are protected by confidentiality.
