Due diligence for conflict minerals.

Responsible supply chains for tin, tantalum, tungsten and gold

Due diligence for conflict minerals.

An enhanced measure of due diligence is required for so-called “conflict minerals” tin, tantalum, tungsten and gold (known as 3TG by their initials), because the mining and trading of these raw materials is associated with financing conflict in the Democratic Republic of the Congo and neighbouring countries.

The majority of 3TG used in our vehicles are contained in complex, already processed parts, such as electronics. We nonetheless take our responsibility as an automobile manufacturer seriously and promote responsible 3TG supply chains. With the Human Rights Respect System (HRRS), Mercedes-Benz has developed its own, systematic approach to preventing human rights violations in our supply chains.

Due to our position as downstream actor with limited leverage on actors in the deeper 3TG supply chain, we regard cross-industry collaborations as vital for addressing human rights and environmental risks in the 3TG supply chain. Accordingly, Mercedes-Benz is a member of the “Responsible Minerals Initiative (RMI) ”, which is committed to maintaining sustainable due diligence along the supply chains for 3TG and other minerals that are critical regarding human rights.

One of the central programs of RMI is the “Responsible Minerals Assurance Process” (RMAP). RMAP uses independent third-party assessments of management systems and sourcing practices of supply chain “pinch points” such as smelter or refiner. “Pinch points" are critical nodes in the value chain because of the material transformation taking place in this stage from raw materials into materials and products for the downstream industry. Due to their position between upstream and downstream industry, they represent a suitable basis to identify the origin of raw materials before they are commingled and processed. In addition, the number of these actors are small relative to the number of upstream and downstream players. With the help of this program, smelters and refineries are assessed to validate conformance with RMAP standards.

Our "Responsible Sourcing Standards (RSS) " define our requirements on sustainable procurement for suppliers of 3TG, as well as for suppliers who use these raw materials in their products. With our procurement contracts we commit our suppliers to disclose all of their smelters and refineries of these raw materials and to ensure that sourcing of these raw materials only comes from refineries and smelters conforming with the RMAP.

Monitoring of our due diligence requirements

As part of our supplier screening process and following a risk-based approach, we invite direct suppliers to respond to the industry-wide Sustainability Assessment Questionnaire (SAQ) , developed and maintained by Drive Sustainability. If a supplier indicates that it uses 3TGs, Cobalt or Mica in its products, the supplier is required to fill in the RMI “Conflict Minerals Reporting Template (CMRT)” for 3TGs or the “Extended Minerals Reporting Template (EMRT)” for Mica and Cobalt. With the CMRTs and EMRTs, the supplier identifies the smelters and refineries of these raw materials in its supply chain in the best possible way.

On a yearly basis, we monitor the information provided by our suppliers and assess the conformity of the listed smelters and refineries with the RMAP standard or other OECD-aligned assessments. If a smelter or refiner does not comply with the requested standard or is not yet participating in these programs, Mercedes-Benz may require their removal from the supply chain in the long term. In principle, however, we pursue the approach of working towards improvement in the first step through participation in the RMAP.

While our leverage is restricted, as participant in one of RMI’s smelter engagement working group, we directly outreach to eligible smelters and refineries. This proactive effort aims to educate operators about RMAP and guide them on their way to a RMAP audit. The overall goal is to gradually increase the number of conformant smelters and refineries.

Complaint mechanisms

Grievances on smelters or refineries or other actors in the Mercedes Benz supply chain, can be reported to Mercedes Benz whistleblower system (BPO) which is also accessible for any external whistleblowers worldwide. Suppliers also find a link to the company-wide complaint mechanism in our Supplier Portal .

Insofar as the misconduct or grievance lies within the supplier’s sphere of responsibility, the supplier is instructed to investigate the complaint and take corrective action, if necessary. The supplier is furthermore obligated to inform about available opportunities to lodge a complaint within its supply chain and to ensure that this information is passed on to the deeper supply chain. At the same time, Mercedes-Benz requires its suppliers to establish an equivalent complaint format for their own supply chains.

In addition, the Mercedes-Benz Group is a founding member of the "Mécanismo de Reclamación de Derechos Humanos" (MRDH), a pilot project for a cross-company grievance mechanism in Mexico. The multi-stakeholder based MRDH has been jointly developed by company representatives and representatives of potentially affected parties, like associations and trade unions. The MRDH provides a common and standardized grievance platform for the entire supply chain of its member companies. This will improve access to remedy and the identification of systemic risks.

Additionally, stakeholders may use the non-judicial grievance mechanism operated by the Organization for Economic Cooperation and Development—the OECD National Contact Points for Responsible Business Conduct .

This article was last updated in June 2024.

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