Risk identification in the chain

Risk identification is the process of finding red flags in the supply chain, gathering facts about the circumstances behind each flag, and assessing the risk before choosing a response. A risk register that lists only general concerns does not identify risk, because it gives no facts that can be tested. The record must name the flag, the source of the information, the facts found, the severity and likelihood assessment, and the leverage available to the operator. Risks in battery chains include serious human rights impacts, environmental harm, and governance failures such as bribery or non payment of taxes, fees, and royalties. Each risk needs its own entry.

Risk identification means the structured review of supply chain information to detect indicators of adverse social or environmental impacts linked to covered raw materials. The scope is the chain mapped for a battery model, including places, actors, and routes that carry a red flag.

What is the legal frame for this record?

Risk identification in the mineral supply chain sits inside that sequence, so a record that shows only one step leaves the chain of reasoning incomplete. A due diligence lead reviewing refiner and mine origin data therefore needs a file that shows the policy, the owner of the policy, the date of adoption, and the review cycle. A sudden change of refiner for cobalt, with no explanation and a new transit route, should be entered as a red flag and investigated, not accepted as a routine commercial change.

How is the chain mapped?

The map should name each tier that handles risk identification in the mineral supply chain, record the function of each actor, and note where material changes form, such as refining, precursor production, cathode production, cell production, and pack assembly. The risk register, source notes, and assessment record should be tied to a named tier, a named site where that information is known, and a date. A due diligence lead reviewing refiner and mine origin data should record gaps on the map itself, with the reason for each gap and the next step planned. Conflict affected and high risk areas require heightened attention under the OECD framework, and the record should state the basis for treating an area as high risk, with the source and date of that assessment.

How is evidence judged?

A supplier statement, a contract clause, a third party audit summary, a mass balance record, and a chain of custody document do not carry equal weight, and the record should say which type supports each claim about risk identification in the mineral supply chain. The risk register, source notes, and assessment record needs a source name, a collection date, a coverage period, and a statement of what was actually checked. A due diligence lead reviewing refiner and mine origin data should separate facts received from conclusions drawn, so a later reviewer can test the conclusion. A sudden change of refiner for cobalt, with no explanation and a new transit route, should be entered as a red flag and investigated, not accepted as a routine commercial change.

How is risk identified and assessed?

A red flag can be a place of origin, a processing route, a supplier practice, a change of ownership, or a gap in records for risk identification in the mineral supply chain. Conflict affected and high risk areas require heightened attention under the OECD framework, and the record should state the basis for treating an area as high risk, with the source and date of that assessment. A due diligence lead reviewing refiner and mine origin data should date each assessment and name the person or function responsible for the next review.

How is mitigation planned and followed up?

For risk identification in the mineral supply chain, the plan should state the risk addressed, the action chosen, the supplier or site involved, the support offered, and the evidence that will show whether the action worked. The risk register, source notes, and assessment record collected after the action should be compared with the position before the action, using the same measure where possible. A sudden change of refiner for cobalt, with no explanation and a new transit route, should be entered as a red flag and investigated, not accepted as a routine commercial change.

How is reporting checked?

The due diligence report should summarise the policy, the management system, the risks found, the actions taken, and the verification arranged for risk identification in the mineral supply chain, without disclosing confidential commercial detail that the Regulation does not require to be published. A due diligence lead reviewing refiner and mine origin data should check that every public claim can be traced to an internal record, and that the report date, coverage period, and scope match the internal file. Conflict affected and high risk areas require heightened attention under the OECD framework, and the record should state the basis for treating an area as high risk, with the source and date of that assessment.

How is one red flag worked through to a decision?

Take a single red flag, such as a report of unsafe working conditions at a graphite processing site, and work it as a case. The case file records the source, the date, and the exact claim, then lists the facts sought: site identity, operator, workforce, permits, and inspection history. The operator seeks those facts from the supplier, from the processor, and from independent sources, and records what each source said. The assessment then grades severity and likelihood separately, states the leverage available, and records a decision: engage with a corrective plan, suspend, or disengage. The case closes only when the decision is recorded and a review date is set.

Identification without a dated assessment leaves the next decision without a basis, and a risk that is noted but never assessed remains an open item in the file.