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{"sheet":"Introduction","index":0,"n_rows":44,"n_cols":8,"rows_kept":44,"cut":false,"hidden":false,"merged":[[34,1,34,14],[22,1,22,14],[25,1,25,14],[28,4,28,14],[1,1,1,14],[4,1,4,14],[7,1,7,14],[13,1,13,14],[16,4,16,14],[20,4,20,14],[19,4,19,14],[21,4,21,14],[8,1,8,14],[2,1,2,9]]}
[null,"Alignment Assessment Tool"]
[null,"This workbook is the Alignment Assessment Tool that the Organisation for Economic Cooperation and Development (OECD) recommends is used to evaluate programmes against the recommendations of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). Prior to using the Alignment Assessment Tool it is recommended that users familiarise themselves with the Alignment Assessment Methodology, which provides details of the design and execution of an Alignment Assessment project and is available on:"]
[null,"http://mneguidelines.oecd.org/industry-initiatives-alignment-assessment.htm "]
[]
[null,"There are four main components to the Alignment Assessment Tool:\nTab 1 - Programme scope: This provides a tool to help the evaluator define the scope of the assessment against the activities of the Programme. \nTab 2 - Alignment Assessment: This provides the detailed criteria against which a programme's 'alignment' with the OECD Guidance is assessed\nTab 3 - Programme governance review: This provides the criteria for assessing the management and governance of a programme, beyond the specific recommendations of the Guidance\nTab 4 - Results and charts: This provides the overall rating from the Alignment Assessment and charts providing a more detailed breakdown of how a programme scored across the different aspects of the Alignment Assessment, including the Programme governance review\nIn addition, there is a hidden data collation worksheet that provides the underlying data for the Results and Charts worksheet."]
[]
[null,"Key definitions"]
[null,"Industry programme: An initiative that has been established to support responsible mineral sourcing, requiring companies operating within or sourcing from mineral supply chains to meet certain standards, including (but not necessarily exclusively) the due diligence standards set out in the OECD Guidance. The term ‘programme’ includes supply chain due diligence schemes or initiatives established by industry bodies, independent or multi-stakeholder certification mechanisms, government schemes or any other organisations established to support the responsible production and sourcing of minerals."]
[null,"Company: The company subject to an audit under the requirements of the programme or that is otherwise associated to or participates in the programme in such a way that it is expected by the programme to meet its standards and policies."]
[null,"Auditor: The firm or individual appointed to audit a company against the requirements of the programme."]
[null,"Further definitions of terms used are provided in the Alignment Assessment Methodology."]
[]
[null,"Completing the Alignment Assessment section"]
[null,"For each criterion there is a drop-down menu from which the evaluator selects one rating for the extent to which the criterion is addressed in policies and standards, and another for the extent to which that criterion is addressed in implementation. The different ratings are defined as follows:"]
[null,"Rating for policies and standards"]
[null,null,"Fully Aligned",null,"The criterion is fully and explicitly addressed in the programme's policies, standards, procedures or other formal documentation."]
[null,null,"Partially Aligned",null,"The criterion is only partially addressed in the programme's policies, standards, procedures or other formal documentation; and / or the criterion is addressed but informally or inconsistently."]
[null,null,"Not Aligned",null,"The criterion is not addressed in the programme's policies, standards, procedures or other formal documentation."]
[null,"Rating for implementation"]
[null,null,"Fully Aligned",null,"There is sufficient evidence, based upon the assessment activities undertaken, to reasonably conclude that the criterion is implemented by the programme, including by deploying the necessary measures to ensure compliance and securing adequate remedial action in cases where companies participating in the Programme and/or auditors do not adhere to its policies and standards."]
[null,null,"Partially Aligned",null,"There is sufficient evidence, based upon the assessment activities undertaken, to reasonably conclude that the criterion is partially implemented by the Programme, including by undertaking some but not fully adequate measures to ensure compliance by companies."]
[null,null,"Not Aligned",null,"There is sufficient evidence, based upon the assessment activities undertaken, to reasonably conclude that the criterion is not implemented by the Programme, for example by undertaking no or inadequate measures to implement the Programme."]
[null,"In addition to the above ratings, there is also the option of Not Applicable ('N/A'). This option should be selected only where the criterion is not relevant due to the mineral type or the stage of the supply chain that is covered by the programme. Where the option of 'N/A' is selected, this must be the case for both 'Policies and standards' and 'Implementation' for the criterion under question (an error message will appear if this is not done).  "]
[]
[null,"Completing the Programme governance review section"]
[null,"As with the Alignment Assessment section, for each criterion there is a drop-down menu from which the evaluator selects one rating for the extent to which the criterion is addressed. The different ratings are defined as follows:"]
[]
[null,null,"Fully addressed",null,"The criterion is fully and explicitly addressed in the programme's policies, standards, procedures or management activities."]
[null,null,"Improvement opportunity",null,"The criterion is partially addressed or inconsistently applied in the programme's policies, standards, procedures or management activities."]
[null,null,"Not Aligned",null,"The criterion is not addressed in the programme's policies, standards, procedures or management activities."]
[]
[null,"For further guidance please refer to the Alignment Assessment Methodology document. "]
[]
[null,"Assessment results and overall conclusion"]
[null,"The results of the Alignment Assessment and Programme governance review are provided in the 'results and charts' tab. The overall conclusion of the Alignment Assessment is calculated as follows:"]
[]
[null,null,"Fully Aligned",null,"(Section A = 100%) + (Sections B and C = 80% or higher) + (no 'Not Aligned' criteria)"]
[null,null,"Partially Aligned",null,"All other combinations between Fully Aligned and Not Aligned"]
[null,null,"Not Aligned",null,"(Section A = <50%) OR (Sections B and C = 20% or higher of criteria are 'Not Aligned')"]
[]
[]
[]
[]
[null,null,null,null,null,null,"The Alignment Assessment Tool and Methodology were developed with the OECD by","Kumi Consulting. Co-funded by the European Union."]

{"sheet":"1. Programme scope","index":1,"n_rows":20,"n_cols":7,"rows_kept":20,"cut":false,"hidden":false,"merged":[[6,1,6,8],[16,1,16,8],[20,1,20,3]]}
[null,null,"Programme scope"]
[null,null,"Approved 3rd party"]
[null,null,"Out of scope"]
[null,"Scope of the programme being evaluated"]
[null,"Information about the programme being evaluated is to be recorded in this sheet within the Alignment Assessment tool, encompassing the following:"]
[null,"1. Scope of programme"]
[null,"Using the drop-down menus, complete the table below to indicate the scope of the programme that is being evaluated, both in terms of its applicability through the stages of the minerals value chain and its applicability across the five step due diligence framework set out in the Guidance. The following definitions apply:\n• Programme scope: this stage of the value chain or five-step due diligence framework is covered by the requirements the programme sets for companies and the activities it undertakes to support companies.\n• Programme-approved 3rd party: this stage of the value chain or five-step due diligence framework is not directly addressed by the programme's own requirements or activities, but the Programme formally recognises a third party initiative that does address the stage.\n• Out of scope: this stage of the value chain or five-step due diligence framework is outside of the scope of the programme's requirements and activities."]
[null,null,"Mine site","Transport/ trading","Export","Smelting/refining","Downstream"]
[null,"Step 1: Establish strong management systems","Approved 3rd party","Approved 3rd party","Approved 3rd party","Programme scope","Out of scope"]
[null,"Step 2: Identify and assess risks in the supply chain"]
[null,"Step 3: Design and implement a strategy to respond to identified risks"]
[null,"Step 4: Independent third party audit of due diligence"]
[null,"Step 5: Report on supply chain due diligence"]
[]
[null,"2. Programme description"]
[null,"Evaluator to provide a concise narrative description of the programme that is being evaluated in the assessment, including if the programme has a specific geographic scope:"]
[]
[]
[null,"3. Assessment period covered"]
[null,"Assessor to describe the time period to which the assessment applies:"]

{"sheet":"2. Alignment Assessment","index":2,"n_rows":128,"n_cols":10,"rows_kept":128,"cut":false,"hidden":false,"merged":[[1,3,2,3],[1,5,2,5],[1,7,2,7],[1,8,2,8],[1,6,2,6],[1,4,2,4]]}
[null,"OECD Due Diligence Alignment Assessment Tool"]
[null,null,null,"Mineral","Upstream / downstream","Reference in Guidance","RATING","Rating for policies and standards","Rating for Implementation","Evaluator comments on policies, standards and implementation"]
[null,"A","Overarching due diligence principles within Programme standards and guidance"]
[null,null,"Due diligence is an on-going, proactive and reactive process"]
[null,"A.1","The Programme explicitly recognises due diligence as an ongoing process to be undertaken by companies.","All","All","Introduction p13, Step 1.c footnote 4 p 37, Step 3.D p46, p63, Step 3.I/II.E p102/105",{"$f":"IF(AND(H5=\"Fully Aligned\",I5=\"Fully Aligned\"),\"Fully Aligned\",IF(AND(H5=\"Not Aligned\",I5=\"Not Aligned\"),\"Not Aligned\",IF(AND(H5=\"Partially Aligned\",I5=\"Not Aligned\"),\"Not Aligned\",IF(AND(H5=\"Not Aligned\",I5=\"Partially Aligned\"),\"Not Aligned\",IF(AND(H5=\"N/A\",I5=\"N/A\"),\"N/A\",IF(AND(H5=\"N/A\",I5<>\"N/A\"),\"ERROR\",IF(AND(I5=\"N/A\",H5<>\"N/A\"),\"ERROR\",IF(OR(H5=\"\",I5=\"\"),\"\",\"Partially Aligned\"))))))))","v":"Not Aligned"},"Partially Aligned","Not Aligned","[Evaluator to provide brief comments on the extent to which the criteria is addressed in the Programme's policies, procedures and/or implementation activities in order to justify the ratings given]"]
[null,"A.2","The Programme expects companies to proactively carry out due diligence and to react to changes of circumstances and risks in the supply chain.","All","All","Introduction p13, Step 3.I/II.E p46, p102/105",{"$f":"IF(AND(H6=\"Fully Aligned\",I6=\"Fully Aligned\"),\"Fully Aligned\",IF(AND(H6=\"Not Aligned\",I6=\"Not Aligned\"),\"Not Aligned\",IF(AND(H6=\"Partially Aligned\",I6=\"Not Aligned\"),\"Not Aligned\",IF(AND(H6=\"Not Aligned\",I6=\"Partially Aligned\"),\"Not Aligned\",IF(AND(H6=\"N/A\",I6=\"N/A\"),\"N/A\",IF(AND(H6=\"N/A\",I6<>\"N/A\"),\"ERROR\",IF(AND(I6=\"N/A\",H6<>\"N/A\"),\"ERROR\",IF(OR(H6=\"\",I6=\"\"),\"\",\"Partially Aligned\"))))))))","v":"Partially Aligned"},"Partially Aligned","Partially Aligned"]
[null,null,"Due diligence is dynamic and improves over time"]
[null,"A.3","If a programme choses to make a final determination on a company or its products, such determination should be based on the conformity of the companies’ due diligence or sourcing practices with the OECD due diligence guidance.","All","All","Introduction p12, p15, p63","Not Aligned","Partially Aligned","Not Aligned"]
[null,"A.4","The Programme expects companies to progressively improve their due diligence activities and risk management performance over time.","All","All","Annex I Step 3 p18, p64","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"A.5","The Programme encourages companies to source responsibly from conflict-affected or high-risk areas and, where relevant, from artisanal and small-scale mineral producers.","All","All","Introduction p12, p15, p63, Appendix p114-118","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,null,"Due diligence is risk-based"]
[null,"A.6","The Programme expects companies' due diligence activities to be guided by their own risk assessments.","All","All","Introduction p13, Annex I Step 3 pp18,44, 99","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"A.7","The Programme expects companies' due diligence activities to consider at least all risks covered in Annex II (serious abuses associated with the extraction, transport or trade of minerals, direct or indirect support to non-state armed groups, public or private security forces, bribery and fraudulent misrepresentation of the origin of minerals, money laundering, payment of taxes, fees and royalties due to governments and bribery).","All","All","Annex I Step 1.A p18, Step 2.B p18, p20, p41, p86","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"A.8","The programme expects that  the measures that a company takes to conduct due diligence should be commensurate to the severity and likelihood of the identified risks.","All","All","Annex I, Step 3.B p18","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"A.9","The programme includes in the definition of red flags considerations of location of mineral origin and transit, supplier characteristics and trade-related circumstances. ","All","All","Introduction p14/15, p33/34, Step 2.B p79/80","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"A.10","The Programme expects that due diligence activities on red-flagged supply chains should involve on-the-ground assessments, to be undertaken by upstream companies. Upstream companies may cooperate through joint initiatives but retain individual responsibility for their due diligence and should ensure that all joint work duly takes into consideration circumstances specific to the individual company.","All","All","Introduction p14/15, Step 2.A p18, p32, Step 2.I.B p41, Step 2.I.C p80, Step 2.II.C p89","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,null,"Due diligence is undertaken in good faith"]
[null,"A.11","The Programme explicitly recognizes that companies should use good faith and reasonable efforts in their due diligence, taking into account factors such as the size of the enterprise, the location of the activities, the situation in a particular country, the sector and nature of the products or services involved.","All","All","Introduction p14, p64, p69, Step 2 pp78,79,86,97, Step 3.II.C.1 p103,p116","Partially Aligned","Fully Aligned","Not Aligned"]
[null,null,"Companies are responsible for ensuring that appropriate due diligence is undertaken"]
[null,"A.12","Responsibility for determining the actions that a company undertakes in response to identified risks rests with the company's management.","All","All","p63, Step 3 p44/99","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"A.13","The Programme states clearly that the use of Industry Programmes, Institutionalised Mechanisms or multi-stakeholder initiatives does not release companies from being responsible for the scope and quality of due diligence in their own supply chains and for reporting on the due diligence that is undertaken in their supply chains.","All","All","Introduction p15, Step 2.I and II p41/42, Step 3 p44/99, Step 2 p78, Step 3 p99","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,null,"Due diligence is global in scope"]
[null,"A.14","Due diligence should be global in scope unless a programme is designed to cover a specific geography or region only. In particular any programme designed to implement step 4 should be global in scope. ","All","All","Introduction p12, Annex II p20","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B","Alignment of Programme requirements with the five-step due diligence framework"]
[null,null,"Step 1: Establish strong company management systems"]
[null,null,"Requirements set by Programmes for those companies subject to audit under the Programme:"]
[null,"B.1","Adopt, and clearly communicate to suppliers and the public, a policy, applicable to the company and its suppliers, providing the principles and standards for identifying and managing the risks in the supply chain of minerals potentially from conflict-affected or high risk areas, against which the company will assess itself and the activities and relationships of suppliers.","All","All","Annex I Step 1.A p17, Step 1.A.1 p36, Step 1.A.1 p72","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.2","Ensure that the supply chain policy is consistent with the standards provided in Annex II of the Guidance.","All","All","Annex I Step 1.A p17, Step 1.A.1 p36, Step 1.A.1 p72","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.3","Within the supply chain policy, set out a clear and coherent management process for risk management. Commit to the due diligence steps as described in Annex I and, where relevant, the Supplement. ","All","All","Annex I Step 1 p17, Step 1.A.2 p36, Step 1.A.2 p72","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.4","Structure internal management to support supply chain due diligence and assign authority and responsibility to senior staff with the necessary competence, knowledge and experience to oversee supply chain due diligence.","All","All","Annex I, 1.B p17, Step 1.B.1 p36, Step 1.B.1 p72","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.5","Ensure that sufficient resources are made available  to support the operation and monitoring of supply chain due diligence processes, taking into account company size, location and circumstances. ","All","All","Step 1.B.2 p36, Step 1.B.2 p72","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.6","Establish the necessary organisational structure and communication processes that will ensure critical information about supply chain due diligence, including the company's policy, reaches relevant employees and suppliers.","All","All","Annex I 1 B-D p 17, Step 1.B.3 p36, Step 1.B.3 p72","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.7","Assist suppliers in building due diligence capacities and provide training as appropriate to employees and suppliers on the policy and its practical application.","All","All","Annex I.1.D p17, Step 1.D.3 p 40, Step 1.D.3 p74","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.8","Ensure internal accountability with respect to the implementation of the supply chain due diligence process.","All","All","Annex I Step 1 p17, Step 1.B.4 p36, Step 1.B.4 p72","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.9","Establish a system of controls and transparency over the mineral supply chain, including a chain of custody or traceability system or the identification of upstream actors in the supply chain. Create and maintain internal documentation and records of supply chain due diligence processes, findings and resulting decisions.","All","All","Annex I.1.C p17, Step 1.C pp37-39, Step 1.C.1 p73","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.10","For all upstream companies: Support the implementation of the principles and criteria of the Extractive Industry Transparency Initiative (EITI).","3T + Gold","Upstream","Annex II para13, Step 1.C.4.4 p39, Step 1.II.A.3 p75","N/A","N/A","N/A"]
[null,"B.11","For local mineral exporters: Collect and disclose information on taxes/payments and details of mineral origin and transportation as set out in the 3T Supplement (taking account of business confidentiality and competitive concerns). ","3T only","Upstream","Step 1.C.1.1 p37, Footnote 12 p40","N/A","N/A","N/A"]
[null,"B.12","For international concentrate traders, mineral reprocessors and smelters/refiners: Incorporate disclosure requirements into commercial contracts and contractually require local exporters to provide the taxes/payments and origin information set out in the Supplements (information can be disclosed to and held by an Institutionalised Mechanism with a mandate to collect and process information on minerals from conflict-affected and high risk areas).","3T only","Upstream","Step 1.C.3.1 p37, Step 1.C.2.1 p38,Footnote 12 p40","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.13","For international concentrate traders and mineral reprocessors: Collect and disclose to downstream purchasers and relevant Institutionalised Mechanisms all export, import and re-export documentation including records of all taxes and any other payments made to public or private security forces or other armed groups, the identification of local exporters and the information provided by local exporters (information can be disclosed to and held by an Institutionalised Mechanism with a mandate to collect and process information on minerals from conflict-affected and high risk areas).","3T only","Upstream","Step 1.C.2.2 p38, Footnote 12 p40","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.14","For all upstream companies: For minerals from a red-flagged location generate, on a disaggregated basis,  information on taxes/payments and details of mineral origin and transportation as set out in the 3T Supplement. Make this information available to downstream purchasers and relevant Institutionalised Mechanisms (information can be disclosed to and held by an Institutionalised Mechanism with a mandate to collect and process information on minerals from conflict-affected and high risk areas).","3T only","Upstream","Step 1.C.4.1/2 p38/39, Footnote 12 p40","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.15","For all downstream companies: Introduce a supply chain transparency system that allows the identification of smelters/refiners in the mineral supply chain and, for minerals from red-flagged locations, provides the identification of all countries of origin, transport and transit for the minerals in the supply chains of each smelter/refiner.","3T + Gold","Downstream","Step 1.C.5.1 p39, Step 1.C.5.1 p39, Step 1.III pp97-98","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.16","For all upstream companies: Avoid cash transactions were practicable and ensure cash transactions are supported by verifiable information.","3T + Gold","Upstream","Step 1.C.4.3 p39, Step 1.I.C.3 p73","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.17","Assign a unique reference number to each input and output and adopt tamper proof physical security measures as set out in the Gold Supplement. ","Gold only","Upstream","Step 1.II.A p75, Step 1.II.B p75, Step 1.II.C p76","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.18","For gold exporters, recyclers and traders: Seek to deal directly with legitimate ASM producers or their representatives where possible.","Gold only","Upstream","Step 1.II.B.5 p76","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.19","For gold exporters, recyclers, traders and refiners: Inspect all shipments for conformity to the information provided by the supplier on the type of gold, weight and quality. Report any inconsistency to management responsible for due diligence, with no further action taken until the inconsistency is resolved, and physically segregate and secure any shipments with unresolved inconsistencies.","Gold only","Upstream","Step 1.II.B.3/4 p75, Step 1.II.C.3/4 p76","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.20","Maintain inventory and transaction documentation that can be retrieved and should include the physical descriptions set out in the Gold Supplement, supplier details including KYC information and unique references for processing, purchases and sales.","Gold only","All","Step 1.C.2 p73","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.21","Cooperate fully and transparently with law enforcement agencies regarding gold transactions. Provide customs officials with access to complete information on all international shipments.","Gold only","All","Step 1.C.4 p73","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.22","Maintain due diligence information for a minimum of five years, preferably on a computerised database. For 3T supply chains, smelters/refiners and downstream purchasers should also make due diligence information available to downstream purchasers and relevant Institutionalised Mechanisms. ","3T + Gold","All","Step 1.C.3.2 p38, Step 1.C.5.2-3 p39, Step 1.C.5 p73","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.23","Aim to establish long-term relationships with suppliers in order to build responsible sourcing relationships with them.","3T + Gold","All","Step 1.D.1 p40 & 74","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.24","Communicate to suppliers the company's expectation that suppliers will undertake mineral supply chain due diligence and risk management consistent with the standards defined in Annex II of the Guidance. ","All","All","Annex I Step 1.D p17, Step 1.D.2 p40, Step 1.D.2 p74","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.25","Incorporate the company's supply chain policy into contracts or written agreements with suppliers which can be applied and monitored. ","All","All","Annex I Step 1.D p17, Step 1.D.2 p40, Step 1.D.3 p74","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.26","Seek to support and build capacities of suppliers to improve risk management performance and comply with the company's supply chain policy.","All","All","Annex I Step 1.D p17, Step 1.D.3 p40, Step 1.D.4 p74","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.27","Commit to designing measureable improvement plans with suppliers, involving external stakeholders such as government or civil society as appropriate.","3T + Gold","All","Step 1.D.4 p40, Step 1.D.5 p74","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.28","Establish a grievance mechanism that enables any affected stakeholders or whistle-blowers to voice concerns regarding  the circumstances of extraction, trade, handling and export of minerals. The grievance mechanism may be provided directly, through collaboration with other companies, or through an industry programme or institutionalised mechanism.","All","All","Annex I Step 1.E p17, Step 1.E.1 p40, Step 1.E.1 p74","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.29","Bullion banks should maintain inventories in such a way that gold from refineries with due diligence practices verified to be consistent with the Guidance can be identified and provided to downstream companies.  ","Gold only","Downstream","Step 1.II.D p76/77","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.30","Downstream companies should request suppliers to identify the gold refiners in the supply chain and provide verification that the refiner(s) has conducted due diligence in accordance with the Guidance. ","Gold only","Downstream","Step 1.II.E p77","Not Aligned","Not Aligned","Not Aligned"]
[null,null,"Step 2: Identify and assess risks in the supply chain"]
[null,null,"Requirements set by Programmes for those companies subject to audit under the Programme:"]
[null,"B.31","Identify risks in supply chains taking into consideration that the scope fo the risk assessment will depend on the position in the supply chain (e.g. upstream, downstream). ","All","All","Annex I.2.A-B p18","Not Aligned","Not Aligned","Partially Aligned"]
[null,"B.32","Ensure that the scope of risk identification and assessment extends to all of the risks set out in Annex II and the recommendations in the Due Diligence Guidance.","All","All","Annex I.2.A-B p18","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.33","Identify and assess whether the locations of mineral origin and transit, the nature of suppliers or the circumstances within the supply chain may trigger 'red flags' as defined by their policy and the relevant Supplement of the Guidance.","3T + Gold","All","Step 2.I/II.A p41/43, Step 2.1.A p78, Step 2.II.B p87","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.34","For local exporters, recyclers, traders and refiners: Using reasonable and good faith efforts and steps proportional to risk, determine whether gold is mined gold, recyclable gold or grandfathered stocks as set out in the gold supplement.","Gold only","Upstream","Step 2.II.A p86-87","N/A","N/A","N/A"]
[null,"B.35","For gold producers: Determine whether upstream gold producers also purchase gold (including ASM gold) and, through the steps described in the Supplement, determine whether this may trigger 'red flags'.","Gold only","Upstream","Step 2.I.B p79","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.36","For all upstream companies: Map the factual circumstances of the supply chain, including the origin of minerals and the activities/relationships of suppliers.","3T + Gold","Upstream","Step 2.I.B p41, Appendix p54/57/58, Step 2.I.C p80, Step 2.II.C p89","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.37","For gold mined by or purchased from medium and large-scale mining operations determine risk through evidence gathered with reference to the criteria set out in the Supplement.","Gold only","Upstream","Step 2.I.C.3 p82-84","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.38","For ASM gold mined by ASM mining enterprises in red-flagged operations or purchased by medium and large-scale mining companies, determine risk through evidence gathered with reference to the criteria set out in the Supplement.","Gold only","Upstream","Step 2.I.C.4 p84/85","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.39","For all upstream companies: Undertake an in-depth review of the context of all red-flagged locations and the due diligence practices of any red-flagged suppliers, covering all of the aspects referenced in the Supplements.","3T + Gold","Upstream","Step 2.I/II.B/C p41/42/43, Step 2.I.C.1 p80","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.40","For all upstream companies: Undertake on-the-ground assessments, performed by suitably qualified and independent assessors, of red-flagged sources of mined minerals. Provide this information to downstream companies in the supply chain.","3T + Gold","Upstream","Step 2.I.B p41, Step 2.I.C.2 p80, Step 2.II.C.2 p89","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.41","For mined gold, obtain evidence of the factual circumstances of gold extraction, trade, handling and export, having regard to the differences between LSM and ASM gold and the relevant criteria for each provided in the Supplement.","Gold only","Upstream","Step 2.II.C.3 p90-94","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.42","For recyclable gold, collect additional information from red flagged supply chains, prioritising higher risk persons, places and transactions with regard to the risk factors and testing activities described in the Supplement.","Gold only","Upstream","Step 2.II.C.4/5 p94-96",{"$f":"IF(AND(H70=\"Fully Aligned\",I70=\"Fully Aligned\"),\"Fully Aligned\",IF(AND(H70=\"Not Aligned\",I70=\"Not Aligned\"),\"Not Aligned\",IF(AND(H70=\"Partially Aligned\",I70=\"Not Aligned\"),\"Not Aligned\",IF(AND(H70=\"Not Aligned\",I70=\"Partially Aligned\"),\"Not Aligned\",IF(AND(H70=\"N/A\",I70=\"N/A\"),\"N/A\",IF(AND(H70=\"N/A\",I70<>\"N/A\"),\"ERROR\",IF(AND(I70=\"N/A\",H70<>\"N/A\"),\"ERROR\",IF(OR(H70=\"\",I70=\"\"),\"\",\"Partially Aligned\"))))))))","v":"Partially Aligned"},"Fully Aligned","Partially Aligned"]
[null,"B.43","For downstream companies: Use best efforts to identify the smelters/refiners in their supply chains.","3T + Gold","Downstream","Step 2.II.A p43, Step 2.III.A p97","N/A","N/A","N/A"]
[null,"B.44","For downstream companies: Obtain from smelters/refiners in their supply chains details of countries of mineral origin, transit and transportation routes from the mine to the smelter/refiner.","3T only","Downstream","Step 2.II.B p43","N/A","N/A","N/A"]
[null,"B.45","For downstream companies: Determine whether refiners have, or reasonably should have, identified red flags in their supply chain.","Gold only","Downstream","Step 2.III.B p97-98","N/A","N/A","N/A"]
[null,"B.46","For downstream companies: Obtain evidence on the due diligence practices of the smelter/refiner, including information generated from on the ground assessments, and review this against the due diligence processes of the Guidance ","3T + Gold","Downstream","Step 2.II.C p43, Step 2.III.C p98","N/A","N/A","N/A"]
[null,"B.47","For downstream companies: Where necessary, undertake spot checks at the smelter/refiner's facilities.","3T only","Downstream","Step 2.II.D p43","N/A","N/A","N/A"]
[null,"B.48","Assess risks against the requirements of the company's supply chain policy (consistent with Annex II), the relevant Supplement of the Guidance, national laws and other relevant legal instruments. Any reasonable inconsistency between these requirements and the information obtained through due diligence should constitute a risk.","3T + Gold","All","Step 2.I.C p42, Step 2.I/II.D pp85-86/96-97","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,null,"Step 3: Design and implement a strategy to respond to identified risks"]
[null,null,"Requirements set by Programmes for those companies subject to audit under the Programme:"]
[null,"B.49","Report findings of risk assessment to designated senior management, outlining the information gathered and the actual and potential risks identified in the supply chain risk assessment.","All","All","Annex I Step 3.A p18, Step 3.A p44, Step 3.I.A p99","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.50","Enhance engagement with suppliers and strengthen internal controls, having regard to the specific measures for upstream and downstream companies provided in the Supplement.","Gold only","All","Step 3.I/II.B p99/103","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.51","For downstream companies:  Companies that have been unable to identify refiners in their supply chain(s) should devise a risk management plan that will enable them to demonstrate significant measureable improvement in doing so.","Gold only","Downstream","Step 3.II.C.1 p103","N/A","N/A","N/A"]
[null,"B.52","Manage the identified risks by either: (i) continuing to trade but with measurable risk mitigation, (ii) temporarily suspending trade while mitigation is put in place, or (iii) ceasing trade with the relevant supplier. In doing so have regard to the specific recommendations of the relevant Supplements. ","All","All","Annex I Step 3.B p18, Step 3.B p44, Step 3.I/II.C p100/103","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.53","For downstream companies: Companies should take immediate steps to disengage with a refiner if the refiner has not immediately suspended or discontinued engagement with its suppliers where reasonable risks of serious abuses or direct or indirect support to non-state armed groups exist.","Gold only","Downstream","Step 3.II.C.2.A p104","N/A","N/A","N/A"]
[null,"B.54","Measurable risk mitigation should result in significant and measureable improvement towards eliminating the identified risks, other than serious abuses, within six months from the adoption of the risk management plan. If there no such measurable improvement within six months, companies should suspend or discontinue engagement with the supplier for a minimum of three months. ","All","All","Annex II footnote 8/10 p23/24, Step 3.I/II.C p101/104","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.55","Build and/or exercise leverage over the actors in the supply chain who can most effectively and most directly prevent and mitigate the risks of adverse impacts. ","All","All","Annex I Step 3.B p18, Step 3.B.2a p44, Step 3.I/II.C.2 p101/104","Not Aligned","Partially Aligned","Not Aligned"]
[null,"B.56","Consult with suppliers and affected stakeholders to agree on the strategy for measurable risk mitigation in the risk management plan.","All","All","Annex I Step 3.B p18, Step 3.B.2b p45, Step 3.I/II.C.2 p101/104","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.57","For upstream companies: Publish the supply chain risk assessment and the supply chain management plan, with due regard to business confidentiality and other competitive concerns, and make them available to external stakeholders as set out in the relevant Supplement.","3T only","Upstream","Step 3.B.2b p45","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.58","For upstream companies: Gold producers with red flagged operations and other upstream companies sourcing ASM gold should assist and enable legitimate ASM producers to build supply chains consistent with the Guidance.","Gold only","Upstream","Step 3.I.C.2c p102, Appendix p114-118","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.59","Implement the risk management plan, monitor risk mitigation and report performance to designated senior management, and consider suspending or discontinuing trade with a supplier after failed attempts at mitigation.","All","All","Annex I Step 3.C p18, Step 3.C p46, Step 3.I/II.D p102/105","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.60","For upstream companies: Implement, monitor and track performance of risk mitigation in cooperation/consultation with local and central authorities and other relevant stakeholders. Consider establishing or supporting community-based networks to monitor risk mitigation. ","3T + Gold","Upstream","Step 3.C.1 p46, Step 3.I.D p102","Not Aligned","Not Aligned","Not Aligned"]
[null,"B.61","Maintain ongoing risk monitoring, evaluate the effectiveness of risk mitigation efforts and undertake additional fact and risk assessments as required, for example following changes to the supply chain. ","All","All","Annex I Step 3.D p18, Step 3.D p46, Step 3.I/II.E p102/105","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,null,"Step 4: Carry out independent third party audit of supply chain due diligence at identified points in the supply chain"]
[null,null,"Requirements set by Programmes for those companies subject to audit under the Programme:"]
[null,"B.62","Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.","All","Upstream","Annex I Step 4 p19","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.63","Facilitate auditor access to company sites, documentation, records and, as appropriate, access to suppliers and other relevant stakeholders, such as on-the-ground assessment teams. ","3T + Gold","Upstream","Step 4.B.1 p50, Step 4.B.5 p110","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,null,"Requirements that Programmes set for auditors"]
[null,"B.64","Audit scope covers all of the smelter/refiner's business activities and management processes related to mineral supply chain due diligence.","3T + Gold","All","Step 4.A.1 p47, Step 4.A.1 p106","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.65","The audit criteria assess the conformity of the smelter/refiner's due diligence practices against the requirements of a standard based on the Guidance.","3T + Gold","All","Step 4.A.2 p47, Step 4.A.2 p107","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.66","Auditors are required to be independent of the smelter/refiner and its supply chain, both with respect to business or financial relationships and with any services provided to the auditee company or its supply chain relating to due diligence practices.","3T + Gold","All","Step 4.A.3 p47, Step 4.A.3 p107","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"B.67","Auditors should be technically competent with appropriate mineral supply chain knowledge, as described in the Supplements. ","3T + Gold","All","Step 4.A.4 p48, Step 4.A.4 p107","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.68","Audit activities should include audit preparation, document review, in-site investigations, risk-based sampling of due diligence records and data, and audit conclusions, as described in the Guidance.","3T + Gold","All","Step 4.A.4 p48, Step 4.A.4 p108 ","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,null,"Step 5: Report on supply chain due diligence"]
[null,null,"Requirements set by Programmes for those companies subject to audit under the Programme:"]
[null,"B.69","Annually report, or integrate into annual sustainability or corporate responsibility reports, information on supply chain due diligence.","All","All","Annex I.5 p19, Step 5.A p52, Step 5.A p111","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.70","For all upstream companies (including smelters/refiners): The report should describe the company's management systems, the methodology and results of the risk assessment and the steps taken to manage risks, consistent with the specific content described in the Guidance. The report should be published.","3T + Gold","Upstream","Step 5.A.1 p52, Step 5.A.1 p111","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"B.71","For smelters/refiners: The audit reports should be published.","3T only","Upstream","Step 5.A.2 p53","Partially Aligned","Partially Aligned","Fully Aligned"]
[null,"B.72","For gold refiners: In addition to reporting on management systems, risk assessment and risk management as defined in the Supplement, refiners should publish the summary audit reports including details of audit dates, activities, methodology and conclusions (either directly or through cooperation with an Industry Programme or Institutionalised Mechanism).","Gold only","Upstream","Step 5.A.2 p112","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"B.73","For downstream companies: The report should describe the company's management systems, the methodology and results of the risk assessment and the steps taken to manage risks, consistent with the specific content described in the Supplement.","3T + Gold","Downstream","Step 5.A.3 p53/p113","Fully Aligned","Fully Aligned","Fully Aligned"]
[null,"C","Specific responsibilities of Programmes"]
[null,null,"Step 1: Establish strong company management systems"]
[null,"C.1","Undertake due diligence on the ownership (including beneficial ownership) and corporate structure of refiners/smelters seeking accreditation/certification or membership status under the Programme.","3T + Gold","All","Step 1.C.1 p37, Step 1.C.2/3 p38, Step 1.C.2c and footnote 14, p73","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"C.2","Provide training to companies and/or their suppliers on due diligence management systems and processes.","3T + Gold","All","Step 4.B.2 p51, Step 1.B.3 p72","Partially Aligned","Partially Aligned","Partially Aligned"]
[null,"C.3","Programmes that provide support for downstream companies should collect and process information from suppliers, including smelters/refiners, on due diligence in the supply chains of minerals from conflict-affected or high risk areas.","3T only","Downstream","Step 1.C.5.3 p39","Not Aligned","Partially Aligned","Not Aligned"]
[null,"C.4","Provide or facilitate access to a grievance mechanism that allows any impacted stakeholder to voice concerns relating to the extraction and supply chain activities of the relevant mineral(s) covered by the Programme.","3T + Gold","All","Step 1.E.2 p40, Step 4.B.2 p51, Step 1.E.2 p74","Not Aligned","Not Aligned","Not Aligned"]
[null,null,"Step 2: Identify and assess risks in the supply chain"]
[null,"C.5","Support companies sourcing minerals from red flagged operations in establishing on-the-ground assessment teams with appropriate capabilities and access rights as set out in the Guidance.","3T + Gold","All","Step 2.A p18, p32, Step 2.I.B p41, Step 2.I.C p80, Step 2.C.2 p81, Step 2.II.C p89","Not Aligned","Not Aligned","Not Aligned"]
[null,null,"Step 3: Design and implement a strategy to respond to identified risks"]
[null,"C.6","Demonstrate an understanding, gained through some form of impact analysis or qualitative or quantitative evaluation, of the social and economic impacts that the Programme's requirements may have on developing countries and the Programme's relevance to or linkages with other existing internationally recognised standards.","Gold only","All","Step 3.I.C.2c p101","Not Aligned","Not Aligned","Not Aligned"]
[null,null,"Step 4: Carry out independent third party audit of supply chain due diligence at identified points in the supply chain"]
[null,"C.7","Draft Audit Standards in accordance with the recommendations of the Guidance.","Gold only","All","Step 4.B.1 p109","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"C.8","Accredit the auditors who may perform audits under the Programme.","3T + Gold","All","Step 4.B.2 p50, Step 4.B.2 p109","Partially Aligned","Fully Aligned","Partially Aligned"]
[null,"C.9","Oversee, periodically review and monitor the ability of auditors to carry out audits in conformity with the Programme's requirements, based on the objectives, scope and criteria of the audit and judged against audit programme records.","3T + Gold","All","Step 4.B.2 p50, Step 4.A.3c p107, Step 4.B.3 p109","Not Aligned","Partially Aligned","Not Aligned"]
[null,"C.10","Publish summary audit reports of smelters/refiners that include: (a) Smelter/refiner details, date of the audit and the audit period, (b) Audit activities and methodology and (c) Audit conclusions.","3T + Gold","All","Step 4.B.2 p51, Step 4.B.4 p109","Fully Aligned","Fully Aligned","Fully Aligned"]
[]
[null,null,null,null,null,null,"Fully Aligned","Fully Aligned","Fully Aligned"]
[null,null,null,null,null,null,"Partially Aligned","Partially Aligned","Partially Aligned"]
[null,null,null,null,null,null,"Not Aligned","Not Aligned","Not Aligned"]
[null,null,null,null,null,null,"N/A","N/A","N/A"]

{"sheet":"3. Programme governance review","index":3,"n_rows":54,"n_cols":5,"rows_kept":54,"cut":false,"hidden":false,"merged":[[1,1,1,4],[49,1,49,4]]}
[null,"Review of Programme governance and management"]
[null,"The following questions assess the governance and management of the Programme. They do not inform judgements on alignment of Programmes with the OECD Due Diligence Guidance. The questions will, however, form the basis for providing feedback within the report on the extent to which the intentions, spirit and principles of the Guidance - beyond the formal recommendations - have been incorporated into the ways in which industry programmes have been established and are managed. This Programme governance review section also includes a number of questions relating to good practice in organisational governance and in audit programmes."]
[]
[null,"Implementation aspect",null,"Rating","Evaluator comments"]
[null,null,"Stakeholder engagement"]
[null,1,"The Programme involves/has involved external stakeholders (e.g. civil society, regulators) in the development and oversight of the due diligence, reporting and auditing requirements, including in risk mitigation efforts as set out in Step 3 of the Guidance.","Fully addressed"]
[null,2,"The Programme regularly participates in relevant public forums (whether through media or events such as conferences) where it provides information about its responsible supply chain programme, including the risks it identifies in the supply chains of companies within the Programme and on mitigation strategies that are being effectively deployed to address these risks. ","Improvement opportunity"]
[null,3,"The Programme has established a functioning and accessible grievance mechanism that enables stakeholders to raise concerns relating to the Programme itself (i.e. not just issues in companies' supply chains).","Not addressed"]
[null,null,"Responsiveness"]
[null,4,"The Programme has a mechanism for monitoring, tracking and sharing information - including between programmes, if appropriate - on incidents or emerging risks identified from company's risk assessments and other relevant sources that could create red flags for companies participating in the Programme. ","Improvement opportunity"]
[null,5,"The Programme has an effective process for communicating details of incidents or emerging risks to companies, auditors and other relevant stakeholders in a timely manner in order to support companies in performing their own supply chain due diligence activities. ","Not addressed"]
[null,6,"The Programme has a process for regular review and, as necessary, updating of its guidance and requirements for companies and auditors.","Fully addressed"]
[null,7,"The Programme has defined its expectations for the timeliness and completion of corrective actions or non-conformance findings that are identified through a company's audit against the Programme requirements. ","Improvement opportunity"]
[null,8,"The Programme has a regular communications programme through which it informs companies and other relevant stakeholders of relevant developments in its responsible sourcing scheme, including updates to standards or guidance documents.","Not addressed"]
[null,9,"The Programme has procedures in place to follow up and address grievances brought to it in a timely manner (whether relating to supply chain issues or the Programme itself). ","Not addressed"]
[null,null,"Membership requirements and/or conditions of certification/accreditation"]
[null,10,"All organisations that are considered members of the Programme (regardless of whether they are subject to audit) are required by the Programme to commit to implementing the OECD Due Diligence Guidance. ","Fully addressed"]
[null,11,"A third party audit that verifies a company's conformance with all of the requirements of the Programme's responsible sourcing scheme is required for companies at identified points in the supply chain (as determined by the Guidance) to be considered accredited or certified by the Programme.","Fully addressed"]
[null,12,"Where an audit finds non-conformance issues, the Programme requires companies to submit an action plan to the Programme. Actions to address major non-conformance findings are monitored by the Programme and sanctions applied (e.g. delisting/exclusion) if such issues are not addressed to the Programme's satisfaction within 6 months of the date of the finding. ","Improvement opportunity"]
[null,13,"Programme communications (whether private with individual companies or public) demonstrate that the Programme does not have unrealistic expectations in relation to the due diligence activities and performance of companies within the Programme (e.g. an acceptance of failings/challenges following good faith and reasonable efforts, provided there is commitment to improve within an agreed timeframe).","Improvement opportunity"]
[null,null,"Audit governance"]
[null,14,"The Programme has a process for validating the credentials and suitability of auditors. Only auditors that have been approved by the Programme can undertake audits of company conformance with the Programme's responsible sourcing requirements.","Fully addressed"]
[null,15,"The Programme maintains an up-to-date list of approved auditors.","Fully addressed"]
[null,16,"The Programme requires auditors to be independent of auditees and has defined its definition of independence with reference to recognised global standards (e.g. ISO 19011, ISAE 3000)","Fully addressed"]
[null,17,"Where the Programme has a process for review and approval of company's audits or their audited reports, mechanisms have been established to ensure that the Programme's review/approval activities are transparent and free of any potential conflicts of interest.","Improvement opportunity"]
[null,18,"Where the Programme has a process for review and approval of company's audits or their audited reports, mechanisms have been established to ensure that the Programme's review/approval activities are undertaken in a timely fashion.","Improvement opportunity"]
[null,null,"Audit standards and guidance"]
[null,19,"The Programme requires audits to be undertaken in accordance with recognised global standards (e.g. ISO19011, ISAE 3000).","Fully addressed"]
[null,20,"The Programme requires auditors to develop an understanding of the auditee company's business and supply chain.","Fully addressed"]
[null,21,"The Programme requires auditors to develop risk-based audit testing/sampling strategies that consider: (a) inherent risks, (b) control risks and (c) detection risks.*","Not addressed"]
[null,22,"The Programme requires auditors to apply materiality in the design and execution of their audit testing/sampling strategies.","Not addressed"]
[null,23,"The Programme requires auditors to utilise sufficient and appropriate evidence to form their conclusions.","Not addressed"]
[null,24,"The Programme provides guidance to auditors and companies on the identification and handling of non-conformance findings. This includes guidance - without impairing auditors' professional judgement - on the distinction between major and minor non-conformance (or high, medium or low risks). ","Improvement opportunity"]
[null,null,"Programme internal governance"]
[null,25,"The Programme has given consideration to where there could be actual or perceived conflicts of interest between Programme management personnel and companies, and has established processes to manage potential conflicts of interest. ","Not addressed"]
[null,26,"The Programme has documented internal procedures for the vetting of prospective companies and auditors wishing to join or be accredited by the Programme.","Not addressed"]
[null,27,"Key decisions relating to the management of the Programme, particularly decisions relating to the performance of companies or auditors within the Programme, are internally documented. ","Improvement opportunity"]
[null,null,"Transparency"]
[null,28,"The Programme publicly provides details of its own internal governance structure, staffing, resources and oversight mechanisms.","Not addressed"]
[null,29,"The Programme maintains an up-to-date, publicly available, list of companies who are currently in conformance with the Programme's requirements.","Improvement opportunity"]
[null,30,"The Programme maintains an up-to-date, publicly available, list of companies who have been disqualified/suspended for failure to meet the Programme's requirements.","Not addressed"]
[null,31,"Programmes proactively encourage transparent disclosure by companies of challenges, identified risks and mitigation plans.  ","Improvement opportunity"]
[null,32,"The Programme encourages companies to provide sufficient details within their reports to enable performance over time to be measured by external stakeholders.","Improvement opportunity"]
[null,null,"Programme aims and objectives"]
[null,33,"The Programme has established processes for monitoring and evaluating whether the Programme itself is meeting its own aims and objectives in relation to responsible sourcing practices within the industry sector in which it operates.","Not addressed"]
[null,34,"The Programme publicly reports on its evaluations of whether it is meeting its own aims and objectives in relation to responsible sourcing practices.","Not addressed"]
[null,35,"The Programme encourages mutual recognition - subject to appropriate quality control - of other responsible sourcing Programmes, both vertically (at different stages of the supply chain) and horizontally (with the same or similar scope).","Improvement opportunity"]
[null,36,"The Programme actively supports implementation the Appendix on 'Suggested measures to create economic and development opportunities for artisanal and small-scale miners'.","Not addressed"]
[]
[null,"* These are the three components of audit risk. Inherent risk is the risk involved in a particular type of business activity or transaction (for example, there is more inherent risk that the production of a mineral may be linked to the financing of non-state armed groups if that mineral is being sourced from a region where non-state armed groups are known to be operating). Control risk is the risk that an entity's internal control mechanism may have failed and therefore not detected or prevented the issue in question from occurring (for example, there would be a control risk if a company's vetting of suppliers was poorly or inconsistently documented). Detection risk is the probability that the audit activities may fail to detect a significant error or fraudulent reporting (for example, there would be a detection risk if an auditor only has a limited amount of time in which to conclude whether due diligence procedures have been correctly followed when there are a high volume of transactions, or if important data/facts/evidence have been intentionally hidden from the auditor). "]
[]
[null,null,null,"Fully addressed"]
[null,null,null,"Improvement opportunity"]
[null,null,null,"Not addressed"]

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[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[null,"Step 1: Establish strong company management systems",null,null,null,null,null,null,null,null,null,null,null,"Number of assessment criteria",{"$f":"'Scoring data'!K24","v":0}]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[null,"Step 2: Identify and assess risks in the supply chain",null,null,null,null,null,null,null,null,null,null,null,"Number of assessment criteria",{"$f":"'Scoring data'!K33","v":0}]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[null,"Step 3: Design and implement a strategy to respond to identified risks",null,null,null,null,null,null,null,null,null,null,null,"Number of assessment criteria",{"$f":"'Scoring data'!K42","v":0}]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[null,"Step 4: Carry out an independent audit at identified points in the supply chain",null,null,null,null,null,null,null,null,null,null,null,"Number of assessment criteria",{"$f":"'Scoring data'!K51","v":0}]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[null,"Step 5: Report on supply chain due diligence",null,null,null,null,null,null,null,null,null,null,null,"Number of assessment criteria",{"$f":"'Scoring data'!K60","v":0}]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[null,"Specific responsibilities of Programmes",null,null,null,null,null,null,null,null,null,null,null,"Number of assessment criteria",{"$f":"'Scoring data'!K69","v":0}]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[null,"Programme governance review",null,null,null,null,null,null,null,null,null,null,null,"Number of assessment criteria",{"$f":"'Scoring data'!K78","v":0}]

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[null,{"$f":"'2. Alignment Assessment'!C4","v":"Due diligence is an on-going, proactive and reactive process"}]
[{"$f":"'2. Alignment Assessment'!B5","v":"A.1"},{"$f":"'2. Alignment Assessment'!C5","v":"The Programme explicitly recognises due diligence as an ongoing process to be undertaken by companies."},{"$f":"'2. Alignment Assessment'!G5","v":"Not Aligned"},{"$f":"_xlfn.IFS(C4=\"Fully Aligned\",2,C4=\"Partially Aligned\",1,C4=\"Not Aligned\",0,C4=\"N/A\",\"\")","v":{"$error":"#NAME?"}},{"$f":"'2. Alignment Assessment'!H5","v":"Partially Aligned"},{"$f":"_xlfn.IFS(E4=\"Fully Aligned\",2,E4=\"Partially Aligned\",1,E4=\"Not Aligned\",0,E4=\"N/A\",\"\")","v":{"$error":"#NAME?"}},{"$f":"'2. Alignment Assessment'!I5","v":"Not Aligned"},{"$f":"_xlfn.IFS(G4=\"Fully Aligned\",2,G4=\"Partially Aligned\",1,G4=\"Not Aligned\",0,G4=\"N/A\",\"\")","v":{"$error":"#NAME?"}},null,"Overarching due diligence principles"]
[{"$f":"'2. Alignment Assessment'!B6","v":"A.2"},{"$f":"'2. Alignment Assessment'!C6","v":"The Programme expects companies to proactively carry out due diligence and to react to changes of circumstances and risks in the supply chain."},{"$f":"'2. Alignment Assessment'!G6","v":"Partially Aligned"},{"$f":"_xlfn.IFS(C5=\"Fully Aligned\",2,C5=\"Partially Aligned\",1,C5=\"Not Aligned\",0,C5=\"N/A\",\"\")","v":{"$error":"#NAME?"}},{"$f":"'2. Alignment Assessment'!H6","v":"Partially Aligned"},{"$f":"_xlfn.IFS(E5=\"Fully Aligned\",2,E5=\"Partially Aligned\",1,E5=\"Not Aligned\",0,E5=\"N/A\",\"\")","v":{"$error":"#NAME?"}},{"$f":"'2. Alignment Assessment'!I6","v":"Partially Aligned"},{"$f":"_xlfn.IFS(G5=\"Fully Aligned\",2,G5=\"Partially Aligned\",1,G5=\"Not Aligned\",0,G5=\"N/A\",\"\")","v":{"$error":"#NAME?"}},null,"Overall ",null,null,null,null,"Standards","Implement"]
[null,{"$f":"'2. Alignment Assessment'!C7","v":"Due diligence is dynamic and improves over time"},null,null,null,null,null,null,null,"Count",{"$f":"COUNT(D4:D5,D7:D9,D11:D15,D17,D19:D20,D22)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D4:D22,2)","v":0},{"$f":"COUNTIF(F4:F22,2)","v":0},{"$f":"COUNTIF(H4:H22,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[{"$f":"'2. Alignment Assessment'!B8","v":"A.3"},{"$f":"'2. Alignment Assessment'!C8","v":"If a programme choses to make a final determination on a company or its products, such determination should be based on the conformity of the companies’ due diligence or sourcing practices with the OECD due diligence guidance."},{"$f":"'2. Alignment Assessment'!G8","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H8","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I8","v":"Not Aligned"},{"$error":"#NAME?"},null,"Max",{"$f":"K6*2","v":0},null,"% of Fully Aligned",{"$f":"N6/$K6","v":{"$error":"#DIV/0!"}},{"$f":"O6/$K6","v":{"$error":"#DIV/0!"}},{"$f":"P6/$K6","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K9","v":{"$error":"#NAME?"}},{"$f":"N7","v":{"$error":"#DIV/0!"}},{"$f":"N9","v":{"$error":"#DIV/0!"}},{"$f":"N11","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B9","v":"A.4"},{"$f":"'2. Alignment Assessment'!C9","v":"The Programme expects companies to progressively improve their due diligence activities and risk management performance over time."},{"$f":"'2. Alignment Assessment'!G9","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H9","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I9","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D4:D5,D7:D9,D11:D15,D17,D19:D20,D22)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D4:D22,1)","v":0},{"$f":"COUNTIF(F4:F22,1)","v":0},{"$f":"COUNTIF(H4:H22,1)","v":0},null,null,{"$f":"100%-S7","v":{"$error":"#NAME?"}},{"$f":"100%-T7","v":{"$error":"#DIV/0!"}},{"$f":"100%-U7","v":{"$error":"#DIV/0!"}},{"$f":"100%-V7","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B10","v":"A.5"},{"$f":"'2. Alignment Assessment'!C10","v":"The Programme encourages companies to source responsibly from conflict-affected or high-risk areas and, where relevant, from artisanal and small-scale mineral producers."},{"$f":"'2. Alignment Assessment'!G10","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H10","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I10","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Score",{"$f":"K8/K7","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N8/$K6","v":{"$error":"#DIV/0!"}},{"$f":"O8/$K6","v":{"$error":"#DIV/0!"}},{"$f":"P8/$K6","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O6+O8)/K7","v":{"$error":"#DIV/0!"}},{"$f":"O7","v":{"$error":"#DIV/0!"}},{"$f":"O9","v":{"$error":"#DIV/0!"}},{"$f":"O11","v":{"$error":"#DIV/0!"}}]
[null,{"$f":"'2. Alignment Assessment'!C11","v":"Due diligence is risk-based"},null,null,null,null,null,null,null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D4:D22,0)","v":0},{"$f":"COUNTIF(F4:F22,0)","v":0},{"$f":"COUNTIF(H4:H22,0)","v":0},null,"Implementation",{"$f":"(P6+P8)/K7","v":{"$error":"#DIV/0!"}},{"$f":"P7","v":{"$error":"#DIV/0!"}},{"$f":"P9","v":{"$error":"#DIV/0!"}},{"$f":"P11","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B12","v":"A.6"},{"$f":"'2. Alignment Assessment'!C12","v":"The Programme expects companies' due diligence activities to be guided by their own risk assessments."},{"$f":"'2. Alignment Assessment'!G12","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H12","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I12","v":"Fully Aligned"},{"$error":"#NAME?"},null,null,null,null,"% of Not Aligned",{"$f":"N10/$K6","v":{"$error":"#DIV/0!"}},{"$f":"O10/$K6","v":{"$error":"#DIV/0!"}},{"$f":"P10/$K6","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B13","v":"A.7"},{"$f":"'2. Alignment Assessment'!C13","v":"The Programme expects companies' due diligence activities to consider at least all risks covered in Annex II (serious abuses associated with the extraction, transport or trade of minerals, direct or indirect support to non-state armed groups, public or private security forces, bribery and fraudulent misrepresentation of the origin of minerals, money laundering, payment of taxes, fees and royalties due to governments and bribery)."},{"$f":"'2. Alignment Assessment'!G13","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H13","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I13","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B14","v":"A.8"},{"$f":"'2. Alignment Assessment'!C14","v":"The programme expects that  the measures that a company takes to conduct due diligence should be commensurate to the severity and likelihood of the identified risks."},{"$f":"'2. Alignment Assessment'!G14","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H14","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I14","v":"Fully Aligned"},{"$error":"#NAME?"},null,"Overall alignment with five-step framework"]
[{"$f":"'2. Alignment Assessment'!B15","v":"A.9"},{"$f":"'2. Alignment Assessment'!C15","v":"The programme includes in the definition of red flags considerations of location of mineral origin and transit, supplier characteristics and trade-related circumstances. "},{"$f":"'2. Alignment Assessment'!G15","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H15","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I15","v":"Fully Aligned"},{"$error":"#NAME?"},null,"Overall ",null,null,null,null,"Standards","Implement"]
[{"$f":"'2. Alignment Assessment'!B16","v":"A.10"},{"$f":"'2. Alignment Assessment'!C16","v":"The Programme expects that due diligence activities on red-flagged supply chains should involve on-the-ground assessments, to be undertaken by upstream companies. Upstream companies may cooperate through joint initiatives but retain individual responsibility for their due diligence and should ensure that all joint work duly takes into consideration circumstances specific to the individual company."},{"$f":"'2. Alignment Assessment'!G16","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H16","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I16","v":"Fully Aligned"},{"$error":"#NAME?"},null,"Count",{"$f":"COUNT(D26:D55,D58:D75,D78:D90,D93:D94,D96:D100,D103:D107,D110:D113,D115,D117,D119:D122)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D26:D122,2)","v":0},{"$f":"COUNTIF(F26:F122,2)","v":0},{"$f":"COUNTIF(H26:H122,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[null,{"$f":"'2. Alignment Assessment'!C17","v":"Due diligence is undertaken in good faith"},null,null,null,null,null,null,null,"Max",{"$f":"K15*2","v":0},null,"% of Fully Aligned",{"$f":"N15/K15","v":{"$error":"#DIV/0!"}},{"$f":"O15/$K15","v":{"$error":"#DIV/0!"}},{"$f":"P15/$K15","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K18","v":{"$error":"#NAME?"}},{"$f":"N16","v":{"$error":"#DIV/0!"}},{"$f":"N18","v":{"$error":"#DIV/0!"}},{"$f":"N20","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B18","v":"A.11"},{"$f":"'2. Alignment Assessment'!C18","v":"The Programme explicitly recognizes that companies should use good faith and reasonable efforts in their due diligence, taking into account factors such as the size of the enterprise, the location of the activities, the situation in a particular country, the sector and nature of the products or services involved."},{"$f":"'2. Alignment Assessment'!G18","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H18","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I18","v":"Not Aligned"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D26:D55,D58:D75,D78:D90,D93:D94,D96:D100,D103:D107,D110:D113,D115,D117,D119:D122)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D26:D122,1)","v":0},{"$f":"COUNTIF(F26:F122,1)","v":0},{"$f":"COUNTIF(H26:H122,1)","v":0},null,null,{"$f":"100%-S16","v":{"$error":"#NAME?"}},{"$f":"100%-T16","v":{"$error":"#DIV/0!"}},{"$f":"100%-U16","v":{"$error":"#DIV/0!"}},{"$f":"100%-V16","v":{"$error":"#DIV/0!"}}]
[null,{"$f":"'2. Alignment Assessment'!C19","v":"Companies are responsible for ensuring that appropriate due diligence is undertaken"},null,null,null,null,null,null,null,"Score",{"$f":"K17/K16","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N17/K15","v":{"$error":"#DIV/0!"}},{"$f":"O17/$K15","v":{"$error":"#DIV/0!"}},{"$f":"P17/$K15","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O15+O17)/K16","v":{"$error":"#DIV/0!"}},{"$f":"O16","v":{"$error":"#DIV/0!"}},{"$f":"O18","v":{"$error":"#DIV/0!"}},{"$f":"O20","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B20","v":"A.12"},{"$f":"'2. Alignment Assessment'!C20","v":"Responsibility for determining the actions that a company undertakes in response to identified risks rests with the company's management."},{"$f":"'2. Alignment Assessment'!G20","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H20","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I20","v":"Partially Aligned"},{"$error":"#NAME?"},null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D26:D122,0)","v":0},{"$f":"COUNTIF(F26:F122,0)","v":0},{"$f":"COUNTIF(H26:H122,0)","v":0},null,"Implementation",{"$f":"(P15+P17)/K16","v":{"$error":"#DIV/0!"}},{"$f":"P16","v":{"$error":"#DIV/0!"}},{"$f":"P18","v":{"$error":"#DIV/0!"}},{"$f":"P20","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B21","v":"A.13"},{"$f":"'2. Alignment Assessment'!C21","v":"The Programme states clearly that the use of Industry Programmes, Institutionalised Mechanisms or multi-stakeholder initiatives does not release companies from being responsible for the scope and quality of due diligence in their own supply chains and for reporting on the due diligence that is undertaken in their supply chains."},{"$f":"'2. Alignment Assessment'!G21","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H21","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I21","v":"Partially Aligned"},{"$error":"#NAME?"},null,null,null,null,"% of Not Aligned",{"$f":"N19/K15","v":{"$error":"#DIV/0!"}},{"$f":"O19/$K15","v":{"$error":"#DIV/0!"}},{"$f":"P19/$K15","v":{"$error":"#DIV/0!"}}]
[null,{"$f":"'2. Alignment Assessment'!C22","v":"Due diligence is global in scope"}]
[{"$f":"'2. Alignment Assessment'!B23","v":"A.14"},{"$f":"'2. Alignment Assessment'!C23","v":"Due diligence should be global in scope unless a programme is designed to cover a specific geography or region only. In particular any programme designed to implement step 4 should be global in scope. "},{"$f":"'2. Alignment Assessment'!G23","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H23","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I23","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Step 1: Establish strong company management systems"]
[{"$f":"'2. Alignment Assessment'!B24","v":"B"},{"$f":"'2. Alignment Assessment'!C24","v":"Alignment of Programme requirements with the five-step due diligence framework"},null,null,null,null,null,null,null,"Overall ",null,null,null,null,"Standards","Implement"]
[null,{"$f":"'2. Alignment Assessment'!C25","v":"Step 1: Establish strong company management systems"},null,null,null,null,null,null,null,"Count",{"$f":"COUNT(D26:D55)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D26:D55,2)","v":0},{"$f":"COUNTIF(F26:F55,2)","v":0},{"$f":"COUNTIF(H26:H55,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[null,{"$f":"'2. Alignment Assessment'!C26","v":"Requirements set by Programmes for those companies subject to audit under the Programme:"},null,null,null,null,null,null,null,"Max",{"$f":"K24*2","v":0},null,"% of Fully Aligned",{"$f":"N24/K24","v":{"$error":"#DIV/0!"}},{"$f":"O24/$K24","v":{"$error":"#DIV/0!"}},{"$f":"P24/$K24","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K27","v":{"$error":"#NAME?"}},{"$f":"N25","v":{"$error":"#DIV/0!"}},{"$f":"N27","v":{"$error":"#DIV/0!"}},{"$f":"N29","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B27","v":"B.1"},{"$f":"'2. Alignment Assessment'!C27","v":"Adopt, and clearly communicate to suppliers and the public, a policy, applicable to the company and its suppliers, providing the principles and standards for identifying and managing the risks in the supply chain of minerals potentially from conflict-affected or high risk areas, against which the company will assess itself and the activities and relationships of suppliers."},{"$f":"'2. Alignment Assessment'!G27","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H27","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I27","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D26:D55)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D26:D55,1)","v":0},{"$f":"COUNTIF(F26:F55,1)","v":0},{"$f":"COUNTIF(H26:H55,1)","v":0},null,null,{"$f":"100%-S25","v":{"$error":"#NAME?"}},{"$f":"100%-T25","v":{"$error":"#DIV/0!"}},{"$f":"100%-U25","v":{"$error":"#DIV/0!"}},{"$f":"100%-V25","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B28","v":"B.2"},{"$f":"'2. Alignment Assessment'!C28","v":"Ensure that the supply chain policy is consistent with the standards provided in Annex II of the Guidance."},{"$f":"'2. Alignment Assessment'!G28","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H28","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I28","v":"Not Aligned"},{"$error":"#NAME?"},null,"Score",{"$f":"K26/K25","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N26/K24","v":{"$error":"#DIV/0!"}},{"$f":"O26/$K24","v":{"$error":"#DIV/0!"}},{"$f":"P26/$K24","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O24+O26)/K25","v":{"$error":"#DIV/0!"}},{"$f":"O25","v":{"$error":"#DIV/0!"}},{"$f":"O27","v":{"$error":"#DIV/0!"}},{"$f":"O29","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B29","v":"B.3"},{"$f":"'2. Alignment Assessment'!C29","v":"Within the supply chain policy, set out a clear and coherent management process for risk management. Commit to the due diligence steps as described in Annex I and, where relevant, the Supplement. "},{"$f":"'2. Alignment Assessment'!G29","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H29","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I29","v":"Not Aligned"},{"$error":"#NAME?"},null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D26:D55,0)","v":0},{"$f":"COUNTIF(F26:F55,0)","v":0},{"$f":"COUNTIF(H26:H55,0)","v":0},null,"Implementation",{"$f":"(P24+P26)/K25","v":{"$error":"#DIV/0!"}},{"$f":"P25","v":{"$error":"#DIV/0!"}},{"$f":"P27","v":{"$error":"#DIV/0!"}},{"$f":"P29","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B30","v":"B.4"},{"$f":"'2. Alignment Assessment'!C30","v":"Structure internal management to support supply chain due diligence and assign authority and responsibility to senior staff with the necessary competence, knowledge and experience to oversee supply chain due diligence."},{"$f":"'2. Alignment Assessment'!G30","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H30","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I30","v":"Not Aligned"},{"$error":"#NAME?"},null,null,null,null,"% of Not Aligned",{"$f":"N28/K24","v":{"$error":"#DIV/0!"}},{"$f":"O28/$K24","v":{"$error":"#DIV/0!"}},{"$f":"P28/$K24","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B31","v":"B.5"},{"$f":"'2. Alignment Assessment'!C31","v":"Ensure that sufficient resources are made available  to support the operation and monitoring of supply chain due diligence processes, taking into account company size, location and circumstances. "},{"$f":"'2. Alignment Assessment'!G31","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H31","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I31","v":"Not Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B32","v":"B.6"},{"$f":"'2. Alignment Assessment'!C32","v":"Establish the necessary organisational structure and communication processes that will ensure critical information about supply chain due diligence, including the company's policy, reaches relevant employees and suppliers."},{"$f":"'2. Alignment Assessment'!G32","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H32","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I32","v":"Not Aligned"},{"$error":"#NAME?"},null,"Step 2: Identify and assess risks in the supply chain"]
[{"$f":"'2. Alignment Assessment'!B33","v":"B.7"},{"$f":"'2. Alignment Assessment'!C33","v":"Assist suppliers in building due diligence capacities and provide training as appropriate to employees and suppliers on the policy and its practical application."},{"$f":"'2. Alignment Assessment'!G33","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H33","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I33","v":"Not Aligned"},{"$error":"#NAME?"},null,"Overall ",null,null,null,null,"Standards","Implement"]
[{"$f":"'2. Alignment Assessment'!B34","v":"B.8"},{"$f":"'2. Alignment Assessment'!C34","v":"Ensure internal accountability with respect to the implementation of the supply chain due diligence process."},{"$f":"'2. Alignment Assessment'!G34","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H34","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I34","v":"Not Aligned"},{"$error":"#NAME?"},null,"Count",{"$f":"COUNT(D58:D75)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D58:D75,2)","v":0},{"$f":"COUNTIF(F58:F75,2)","v":0},{"$f":"COUNTIF(H58:H75,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[{"$f":"'2. Alignment Assessment'!B35","v":"B.9"},{"$f":"'2. Alignment Assessment'!C35","v":"Establish a system of controls and transparency over the mineral supply chain, including a chain of custody or traceability system or the identification of upstream actors in the supply chain. Create and maintain internal documentation and records of supply chain due diligence processes, findings and resulting decisions."},{"$f":"'2. Alignment Assessment'!G35","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H35","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I35","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Max",{"$f":"K33*2","v":0},null,"% of Fully Aligned",{"$f":"N33/K33","v":{"$error":"#DIV/0!"}},{"$f":"O33/$K33","v":{"$error":"#DIV/0!"}},{"$f":"P33/$K33","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K36","v":{"$error":"#NAME?"}},{"$f":"N34","v":{"$error":"#DIV/0!"}},{"$f":"N36","v":{"$error":"#DIV/0!"}},{"$f":"N38","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B36","v":"B.10"},{"$f":"'2. Alignment Assessment'!C36","v":"For all upstream companies: Support the implementation of the principles and criteria of the Extractive Industry Transparency Initiative (EITI)."},{"$f":"'2. Alignment Assessment'!G36","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H36","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I36","v":"N/A"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D58:D75)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D58:D75,1)","v":0},{"$f":"COUNTIF(F58:F75,1)","v":0},{"$f":"COUNTIF(H58:H75,1)","v":0},null,null,{"$f":"100%-S34","v":{"$error":"#NAME?"}},{"$f":"100%-T34","v":{"$error":"#DIV/0!"}},{"$f":"100%-U34","v":{"$error":"#DIV/0!"}},{"$f":"100%-V34","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B37","v":"B.11"},{"$f":"'2. Alignment Assessment'!C37","v":"For local mineral exporters: Collect and disclose information on taxes/payments and details of mineral origin and transportation as set out in the 3T Supplement (taking account of business confidentiality and competitive concerns). "},{"$f":"'2. Alignment Assessment'!G37","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H37","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I37","v":"N/A"},{"$error":"#NAME?"},null,"Score",{"$f":"K35/K34","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N35/K33","v":{"$error":"#DIV/0!"}},{"$f":"O35/$K33","v":{"$error":"#DIV/0!"}},{"$f":"P35/$K33","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O33+O35)/K34","v":{"$error":"#DIV/0!"}},{"$f":"O34","v":{"$error":"#DIV/0!"}},{"$f":"O36","v":{"$error":"#DIV/0!"}},{"$f":"O38","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B38","v":"B.12"},{"$f":"'2. Alignment Assessment'!C38","v":"For international concentrate traders, mineral reprocessors and smelters/refiners: Incorporate disclosure requirements into commercial contracts and contractually require local exporters to provide the taxes/payments and origin information set out in the Supplements (information can be disclosed to and held by an Institutionalised Mechanism with a mandate to collect and process information on minerals from conflict-affected and high risk areas)."},{"$f":"'2. Alignment Assessment'!G38","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H38","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I38","v":"Fully Aligned"},{"$error":"#NAME?"},null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D58:D75,0)","v":0},{"$f":"COUNTIF(F58:F75,0)","v":0},{"$f":"COUNTIF(H58:H75,0)","v":0},null,"Implementation",{"$f":"(P33+P35)/K34","v":{"$error":"#DIV/0!"}},{"$f":"P34","v":{"$error":"#DIV/0!"}},{"$f":"P36","v":{"$error":"#DIV/0!"}},{"$f":"P38","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B39","v":"B.13"},{"$f":"'2. Alignment Assessment'!C39","v":"For international concentrate traders and mineral reprocessors: Collect and disclose to downstream purchasers and relevant Institutionalised Mechanisms all export, import and re-export documentation including records of all taxes and any other payments made to public or private security forces or other armed groups, the identification of local exporters and the information provided by local exporters (information can be disclosed to and held by an Institutionalised Mechanism with a mandate to collect and process information on minerals from conflict-affected and high risk areas)."},{"$f":"'2. Alignment Assessment'!G39","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H39","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I39","v":"Fully Aligned"},{"$error":"#NAME?"},null,null,null,null,"% of Not Aligned",{"$f":"N37/K33","v":{"$error":"#DIV/0!"}},{"$f":"O37/$K33","v":{"$error":"#DIV/0!"}},{"$f":"P37/$K33","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B40","v":"B.14"},{"$f":"'2. Alignment Assessment'!C40","v":"For all upstream companies: For minerals from a red-flagged location generate, on a disaggregated basis,  information on taxes/payments and details of mineral origin and transportation as set out in the 3T Supplement. Make this information available to downstream purchasers and relevant Institutionalised Mechanisms (information can be disclosed to and held by an Institutionalised Mechanism with a mandate to collect and process information on minerals from conflict-affected and high risk areas)."},{"$f":"'2. Alignment Assessment'!G40","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H40","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I40","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B41","v":"B.15"},{"$f":"'2. Alignment Assessment'!C41","v":"For all downstream companies: Introduce a supply chain transparency system that allows the identification of smelters/refiners in the mineral supply chain and, for minerals from red-flagged locations, provides the identification of all countries of origin, transport and transit for the minerals in the supply chains of each smelter/refiner."},{"$f":"'2. Alignment Assessment'!G41","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H41","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I41","v":"Fully Aligned"},{"$error":"#NAME?"},null,"Step 3: Design and implement a strategy to respond to identified risks"]
[{"$f":"'2. Alignment Assessment'!B42","v":"B.16"},{"$f":"'2. Alignment Assessment'!C42","v":"For all upstream companies: Avoid cash transactions were practicable and ensure cash transactions are supported by verifiable information."},{"$f":"'2. Alignment Assessment'!G42","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H42","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I42","v":"Fully Aligned"},{"$error":"#NAME?"},null,"Overall ",null,null,null,null,"Standards","Implement"]
[{"$f":"'2. Alignment Assessment'!B43","v":"B.17"},{"$f":"'2. Alignment Assessment'!C43","v":"Assign a unique reference number to each input and output and adopt tamper proof physical security measures as set out in the Gold Supplement. "},{"$f":"'2. Alignment Assessment'!G43","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H43","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I43","v":"Not Aligned"},{"$error":"#NAME?"},null,"Count",{"$f":"COUNT(D78:D90)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D78:D90,2)","v":0},{"$f":"COUNTIF(F78:F90,2)","v":0},{"$f":"COUNTIF(H78:H90,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[{"$f":"'2. Alignment Assessment'!B44","v":"B.18"},{"$f":"'2. Alignment Assessment'!C44","v":"For gold exporters, recyclers and traders: Seek to deal directly with legitimate ASM producers or their representatives where possible."},{"$f":"'2. Alignment Assessment'!G44","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H44","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I44","v":"Not Aligned"},{"$error":"#NAME?"},null,"Max",{"$f":"K42*2","v":0},null,"% of Fully Aligned",{"$f":"N42/K42","v":{"$error":"#DIV/0!"}},{"$f":"O42/$K42","v":{"$error":"#DIV/0!"}},{"$f":"P42/$K42","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K45","v":{"$error":"#NAME?"}},{"$f":"N43","v":{"$error":"#DIV/0!"}},{"$f":"N45","v":{"$error":"#DIV/0!"}},{"$f":"N47","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B45","v":"B.19"},{"$f":"'2. Alignment Assessment'!C45","v":"For gold exporters, recyclers, traders and refiners: Inspect all shipments for conformity to the information provided by the supplier on the type of gold, weight and quality. Report any inconsistency to management responsible for due diligence, with no further action taken until the inconsistency is resolved, and physically segregate and secure any shipments with unresolved inconsistencies."},{"$f":"'2. Alignment Assessment'!G45","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H45","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I45","v":"Not Aligned"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D78:D90)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D78:D90,1)","v":0},{"$f":"COUNTIF(F78:F90,1)","v":0},{"$f":"COUNTIF(H78:H90,1)","v":0},null,null,{"$f":"100%-S43","v":{"$error":"#NAME?"}},{"$f":"100%-T43","v":{"$error":"#DIV/0!"}},{"$f":"100%-U43","v":{"$error":"#DIV/0!"}},{"$f":"100%-V43","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B46","v":"B.20"},{"$f":"'2. Alignment Assessment'!C46","v":"Maintain inventory and transaction documentation that can be retrieved and should include the physical descriptions set out in the Gold Supplement, supplier details including KYC information and unique references for processing, purchases and sales."},{"$f":"'2. Alignment Assessment'!G46","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H46","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I46","v":"Not Aligned"},{"$error":"#NAME?"},null,"Score",{"$f":"K44/K43","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N44/K42","v":{"$error":"#DIV/0!"}},{"$f":"O44/$K42","v":{"$error":"#DIV/0!"}},{"$f":"P44/$K42","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O42+O44)/K43","v":{"$error":"#DIV/0!"}},{"$f":"O43","v":{"$error":"#DIV/0!"}},{"$f":"O45","v":{"$error":"#DIV/0!"}},{"$f":"O47","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B47","v":"B.21"},{"$f":"'2. Alignment Assessment'!C47","v":"Cooperate fully and transparently with law enforcement agencies regarding gold transactions. Provide customs officials with access to complete information on all international shipments."},{"$f":"'2. Alignment Assessment'!G47","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H47","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I47","v":"Not Aligned"},{"$error":"#NAME?"},null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D78:D90,0)","v":0},{"$f":"COUNTIF(F78:F90,0)","v":0},{"$f":"COUNTIF(H78:H90,0)","v":0},null,"Implementation",{"$f":"(P42+P44)/K43","v":{"$error":"#DIV/0!"}},{"$f":"P43","v":{"$error":"#DIV/0!"}},{"$f":"P45","v":{"$error":"#DIV/0!"}},{"$f":"P47","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B48","v":"B.22"},{"$f":"'2. Alignment Assessment'!C48","v":"Maintain due diligence information for a minimum of five years, preferably on a computerised database. For 3T supply chains, smelters/refiners and downstream purchasers should also make due diligence information available to downstream purchasers and relevant Institutionalised Mechanisms. "},{"$f":"'2. Alignment Assessment'!G48","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H48","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I48","v":"Not Aligned"},{"$error":"#NAME?"},null,null,null,null,"% of Not Aligned",{"$f":"N46/K42","v":{"$error":"#DIV/0!"}},{"$f":"O46/$K42","v":{"$error":"#DIV/0!"}},{"$f":"P46/$K42","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B49","v":"B.23"},{"$f":"'2. Alignment Assessment'!C49","v":"Aim to establish long-term relationships with suppliers in order to build responsible sourcing relationships with them."},{"$f":"'2. Alignment Assessment'!G49","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H49","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I49","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B50","v":"B.24"},{"$f":"'2. Alignment Assessment'!C50","v":"Communicate to suppliers the company's expectation that suppliers will undertake mineral supply chain due diligence and risk management consistent with the standards defined in Annex II of the Guidance. "},{"$f":"'2. Alignment Assessment'!G50","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H50","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I50","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Step 4: Carry out an independent audit at identified points in the supply chain"]
[{"$f":"'2. Alignment Assessment'!B51","v":"B.25"},{"$f":"'2. Alignment Assessment'!C51","v":"Incorporate the company's supply chain policy into contracts or written agreements with suppliers which can be applied and monitored. "},{"$f":"'2. Alignment Assessment'!G51","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H51","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I51","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Overall ",null,null,null,null,"Standards","Implement"]
[{"$f":"'2. Alignment Assessment'!B52","v":"B.26"},{"$f":"'2. Alignment Assessment'!C52","v":"Seek to support and build capacities of suppliers to improve risk management performance and comply with the company's supply chain policy."},{"$f":"'2. Alignment Assessment'!G52","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H52","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I52","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Count",{"$f":"COUNT(D93:D100)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D93:D100,2)","v":0},{"$f":"COUNTIF(F93:F100,2)","v":0},{"$f":"COUNTIF(H93:H100,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[{"$f":"'2. Alignment Assessment'!B53","v":"B.27"},{"$f":"'2. Alignment Assessment'!C53","v":"Commit to designing measureable improvement plans with suppliers, involving external stakeholders such as government or civil society as appropriate."},{"$f":"'2. Alignment Assessment'!G53","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H53","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I53","v":"Not Aligned"},{"$error":"#NAME?"},null,"Max",{"$f":"K51*2","v":0},null,"% of Fully Aligned",{"$f":"N51/K51","v":{"$error":"#DIV/0!"}},{"$f":"O51/$K51","v":{"$error":"#DIV/0!"}},{"$f":"P51/$K51","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K54","v":{"$error":"#NAME?"}},{"$f":"N52","v":{"$error":"#DIV/0!"}},{"$f":"N54","v":{"$error":"#DIV/0!"}},{"$f":"N56","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B54","v":"B.28"},{"$f":"'2. Alignment Assessment'!C54","v":"Establish a grievance mechanism that enables any affected stakeholders or whistle-blowers to voice concerns regarding  the circumstances of extraction, trade, handling and export of minerals. The grievance mechanism may be provided directly, through collaboration with other companies, or through an industry programme or institutionalised mechanism."},{"$f":"'2. Alignment Assessment'!G54","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H54","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I54","v":"Not Aligned"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D93:D100)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D93:D100,1)","v":0},{"$f":"COUNTIF(F93:F100,1)","v":0},{"$f":"COUNTIF(H93:H100,1)","v":0},null,null,{"$f":"100%-S52","v":{"$error":"#NAME?"}},{"$f":"100%-T52","v":{"$error":"#DIV/0!"}},{"$f":"100%-U52","v":{"$error":"#DIV/0!"}},{"$f":"100%-V52","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B55","v":"B.29"},{"$f":"'2. Alignment Assessment'!C55","v":"Bullion banks should maintain inventories in such a way that gold from refineries with due diligence practices verified to be consistent with the Guidance can be identified and provided to downstream companies.  "},{"$f":"'2. Alignment Assessment'!G55","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H55","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I55","v":"Not Aligned"},{"$error":"#NAME?"},null,"Score",{"$f":"K53/K52","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N53/K51","v":{"$error":"#DIV/0!"}},{"$f":"O53/$K51","v":{"$error":"#DIV/0!"}},{"$f":"P53/$K51","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O51+O53)/K52","v":{"$error":"#DIV/0!"}},{"$f":"O52","v":{"$error":"#DIV/0!"}},{"$f":"O54","v":{"$error":"#DIV/0!"}},{"$f":"O56","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B56","v":"B.30"},{"$f":"'2. Alignment Assessment'!C56","v":"Downstream companies should request suppliers to identify the gold refiners in the supply chain and provide verification that the refiner(s) has conducted due diligence in accordance with the Guidance. "},{"$f":"'2. Alignment Assessment'!G56","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H56","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I56","v":"Not Aligned"},{"$error":"#NAME?"},null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D93:D100,0)","v":0},{"$f":"COUNTIF(F93:F100,0)","v":0},{"$f":"COUNTIF(H93:H100,0)","v":0},null,"Implementation",{"$f":"(P51+P53)/K52","v":{"$error":"#DIV/0!"}},{"$f":"P52","v":{"$error":"#DIV/0!"}},{"$f":"P54","v":{"$error":"#DIV/0!"}},{"$f":"P56","v":{"$error":"#DIV/0!"}}]
[null,{"$f":"'2. Alignment Assessment'!C57","v":"Step 2: Identify and assess risks in the supply chain"},null,null,null,null,null,null,null,null,null,null,"% of Not Aligned",{"$f":"N55/K51","v":{"$error":"#DIV/0!"}},{"$f":"O55/$K51","v":{"$error":"#DIV/0!"}},{"$f":"P55/$K51","v":{"$error":"#DIV/0!"}}]
[null,{"$f":"'2. Alignment Assessment'!C58","v":"Requirements set by Programmes for those companies subject to audit under the Programme:"}]
[{"$f":"'2. Alignment Assessment'!B59","v":"B.31"},{"$f":"'2. Alignment Assessment'!C59","v":"Identify risks in supply chains taking into consideration that the scope fo the risk assessment will depend on the position in the supply chain (e.g. upstream, downstream). "},{"$f":"'2. Alignment Assessment'!G59","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H59","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I59","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Step 5: Report on supply chain due diligence"]
[{"$f":"'2. Alignment Assessment'!B60","v":"B.32"},{"$f":"'2. Alignment Assessment'!C60","v":"Ensure that the scope of risk identification and assessment extends to all of the risks set out in Annex II and the recommendations in the Due Diligence Guidance."},{"$f":"'2. Alignment Assessment'!G60","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H60","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I60","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Overall ",null,null,null,null,"Standards","Implement"]
[{"$f":"'2. Alignment Assessment'!B61","v":"B.33"},{"$f":"'2. Alignment Assessment'!C61","v":"Identify and assess whether the locations of mineral origin and transit, the nature of suppliers or the circumstances within the supply chain may trigger 'red flags' as defined by their policy and the relevant Supplement of the Guidance."},{"$f":"'2. Alignment Assessment'!G61","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H61","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I61","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Count",{"$f":"COUNT(D103:D107)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D103:D107,2)","v":0},{"$f":"COUNTIF(F103:F107,2)","v":0},{"$f":"COUNTIF(H103:H107,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[{"$f":"'2. Alignment Assessment'!B62","v":"B.34"},{"$f":"'2. Alignment Assessment'!C62","v":"For local exporters, recyclers, traders and refiners: Using reasonable and good faith efforts and steps proportional to risk, determine whether gold is mined gold, recyclable gold or grandfathered stocks as set out in the gold supplement."},{"$f":"'2. Alignment Assessment'!G62","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H62","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I62","v":"N/A"},{"$error":"#NAME?"},null,"Max",{"$f":"K60*2","v":0},null,"% of Fully Aligned",{"$f":"N60/K60","v":{"$error":"#DIV/0!"}},{"$f":"O60/$K60","v":{"$error":"#DIV/0!"}},{"$f":"P60/$K60","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K63","v":{"$error":"#NAME?"}},{"$f":"N61","v":{"$error":"#DIV/0!"}},{"$f":"N63","v":{"$error":"#DIV/0!"}},{"$f":"N65","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B63","v":"B.35"},{"$f":"'2. Alignment Assessment'!C63","v":"For gold producers: Determine whether upstream gold producers also purchase gold (including ASM gold) and, through the steps described in the Supplement, determine whether this may trigger 'red flags'."},{"$f":"'2. Alignment Assessment'!G63","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H63","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I63","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D103:D107)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D103:D107,1)","v":0},{"$f":"COUNTIF(F103:F107,1)","v":0},{"$f":"COUNTIF(H103:H107,1)","v":0},null,null,{"$f":"100%-S61","v":{"$error":"#NAME?"}},{"$f":"100%-T61","v":{"$error":"#DIV/0!"}},{"$f":"100%-U61","v":{"$error":"#DIV/0!"}},{"$f":"100%-V61","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B64","v":"B.36"},{"$f":"'2. Alignment Assessment'!C64","v":"For all upstream companies: Map the factual circumstances of the supply chain, including the origin of minerals and the activities/relationships of suppliers."},{"$f":"'2. Alignment Assessment'!G64","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H64","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I64","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Score",{"$f":"K62/K61","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N62/K60","v":{"$error":"#DIV/0!"}},{"$f":"O62/$K60","v":{"$error":"#DIV/0!"}},{"$f":"P62/$K60","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O60+O62)/K61","v":{"$error":"#DIV/0!"}},{"$f":"O61","v":{"$error":"#DIV/0!"}},{"$f":"O63","v":{"$error":"#DIV/0!"}},{"$f":"O65","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B65","v":"B.37"},{"$f":"'2. Alignment Assessment'!C65","v":"For gold mined by or purchased from medium and large-scale mining operations determine risk through evidence gathered with reference to the criteria set out in the Supplement."},{"$f":"'2. Alignment Assessment'!G65","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H65","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I65","v":"Partially Aligned"},{"$error":"#NAME?"},null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D103:D107,0)","v":0},{"$f":"COUNTIF(F103:F107,0)","v":0},{"$f":"COUNTIF(H103:H107,0)","v":0},null,"Implementation",{"$f":"(P60+P62)/K61","v":{"$error":"#DIV/0!"}},{"$f":"P61","v":{"$error":"#DIV/0!"}},{"$f":"P63","v":{"$error":"#DIV/0!"}},{"$f":"P65","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B66","v":"B.38"},{"$f":"'2. Alignment Assessment'!C66","v":"For ASM gold mined by ASM mining enterprises in red-flagged operations or purchased by medium and large-scale mining companies, determine risk through evidence gathered with reference to the criteria set out in the Supplement."},{"$f":"'2. Alignment Assessment'!G66","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H66","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I66","v":"Partially Aligned"},{"$error":"#NAME?"},null,null,null,null,"% of Not Aligned",{"$f":"N64/K60","v":{"$error":"#DIV/0!"}},{"$f":"O64/$K60","v":{"$error":"#DIV/0!"}},{"$f":"P64/$K60","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B67","v":"B.39"},{"$f":"'2. Alignment Assessment'!C67","v":"For all upstream companies: Undertake an in-depth review of the context of all red-flagged locations and the due diligence practices of any red-flagged suppliers, covering all of the aspects referenced in the Supplements."},{"$f":"'2. Alignment Assessment'!G67","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H67","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I67","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B68","v":"B.40"},{"$f":"'2. Alignment Assessment'!C68","v":"For all upstream companies: Undertake on-the-ground assessments, performed by suitably qualified and independent assessors, of red-flagged sources of mined minerals. Provide this information to downstream companies in the supply chain."},{"$f":"'2. Alignment Assessment'!G68","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H68","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I68","v":"Not Aligned"},{"$error":"#NAME?"},null,"Specific responsibilities of Programmes"]
[{"$f":"'2. Alignment Assessment'!B69","v":"B.41"},{"$f":"'2. Alignment Assessment'!C69","v":"For mined gold, obtain evidence of the factual circumstances of gold extraction, trade, handling and export, having regard to the differences between LSM and ASM gold and the relevant criteria for each provided in the Supplement."},{"$f":"'2. Alignment Assessment'!G69","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H69","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I69","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Overall ",null,null,null,null,"Standards","Implement"]
[{"$f":"'2. Alignment Assessment'!B70","v":"B.42"},{"$f":"'2. Alignment Assessment'!C70","v":"For recyclable gold, collect additional information from red flagged supply chains, prioritising higher risk persons, places and transactions with regard to the risk factors and testing activities described in the Supplement."},{"$f":"'2. Alignment Assessment'!G70","v":"Partially Aligned"},{"$f":"_xlfn.IFS(C69=\"Fully Aligned\",2,C69=\"Partially Aligned\",1,C69=\"Not Aligned\",0,C69=\"N/A\",\"\")","v":{"$error":"#NAME?"}},{"$f":"'2. Alignment Assessment'!H70","v":"Fully Aligned"},{"$f":"_xlfn.IFS(E69=\"Fully Aligned\",2,E69=\"Partially Aligned\",1,E69=\"Not Aligned\",0,E69=\"N/A\",\"\")","v":{"$error":"#NAME?"}},{"$f":"'2. Alignment Assessment'!I70","v":"Partially Aligned"},{"$f":"_xlfn.IFS(G69=\"Fully Aligned\",2,G69=\"Partially Aligned\",1,G69=\"Not Aligned\",0,G69=\"N/A\",\"\")","v":{"$error":"#NAME?"}},null,"Count",{"$f":"COUNT(D110:D122)","v":0},null,"No. of Fully Aligned",{"$f":"COUNTIF(D110:D122,2)","v":0},{"$f":"COUNTIF(F110:F122,2)","v":0},{"$f":"COUNTIF(H110:H122,2)","v":0},null,null,"Overall","Fully Aligned","Partially Aligned","Not Aligned"]
[{"$f":"'2. Alignment Assessment'!B71","v":"B.43"},{"$f":"'2. Alignment Assessment'!C71","v":"For downstream companies: Use best efforts to identify the smelters/refiners in their supply chains."},{"$f":"'2. Alignment Assessment'!G71","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H71","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I71","v":"N/A"},{"$error":"#NAME?"},null,"Max",{"$f":"K69*2","v":0},null,"% of Fully Aligned",{"$f":"N69/K69","v":{"$error":"#DIV/0!"}},{"$f":"O69/$K69","v":{"$error":"#DIV/0!"}},{"$f":"P69/$K69","v":{"$error":"#DIV/0!"}},null,null,{"$f":"K72","v":{"$error":"#NAME?"}},{"$f":"N70","v":{"$error":"#DIV/0!"}},{"$f":"N72","v":{"$error":"#DIV/0!"}},{"$f":"N74","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B72","v":"B.44"},{"$f":"'2. Alignment Assessment'!C72","v":"For downstream companies: Obtain from smelters/refiners in their supply chains details of countries of mineral origin, transit and transportation routes from the mine to the smelter/refiner."},{"$f":"'2. Alignment Assessment'!G72","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H72","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I72","v":"N/A"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D110:D122)","v":{"$error":"#NAME?"}},null,"No. of Partially Aligned",{"$f":"COUNTIF(D110:D122,1)","v":0},{"$f":"COUNTIF(F110:F122,1)","v":0},{"$f":"COUNTIF(H110:H122,1)","v":0},null,null,{"$f":"100%-S70","v":{"$error":"#NAME?"}},{"$f":"100%-T70","v":{"$error":"#DIV/0!"}},{"$f":"100%-U70","v":{"$error":"#DIV/0!"}},{"$f":"100%-V70","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B73","v":"B.45"},{"$f":"'2. Alignment Assessment'!C73","v":"For downstream companies: Determine whether refiners have, or reasonably should have, identified red flags in their supply chain."},{"$f":"'2. Alignment Assessment'!G73","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H73","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I73","v":"N/A"},{"$error":"#NAME?"},null,"Score",{"$f":"K71/K70","v":{"$error":"#NAME?"}},null,"% of Partially Aligned",{"$f":"N71/K69","v":{"$error":"#DIV/0!"}},{"$f":"O71/$K69","v":{"$error":"#DIV/0!"}},{"$f":"P71/$K69","v":{"$error":"#DIV/0!"}},null,"Standards",{"$f":"(O69+O71)/K70","v":{"$error":"#DIV/0!"}},{"$f":"O70","v":{"$error":"#DIV/0!"}},{"$f":"O72","v":{"$error":"#DIV/0!"}},{"$f":"O74","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B74","v":"B.46"},{"$f":"'2. Alignment Assessment'!C74","v":"For downstream companies: Obtain evidence on the due diligence practices of the smelter/refiner, including information generated from on the ground assessments, and review this against the due diligence processes of the Guidance "},{"$f":"'2. Alignment Assessment'!G74","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H74","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I74","v":"N/A"},{"$error":"#NAME?"},null,null,null,null,"No. of Not Aligned",{"$f":"COUNTIF(D110:D122,0)","v":0},{"$f":"COUNTIF(F110:F122,0)","v":0},{"$f":"COUNTIF(H110:H122,0)","v":0},null,"Implementation",{"$f":"(P69+P71)/K70","v":{"$error":"#DIV/0!"}},{"$f":"P70","v":{"$error":"#DIV/0!"}},{"$f":"P72","v":{"$error":"#DIV/0!"}},{"$f":"P74","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B75","v":"B.47"},{"$f":"'2. Alignment Assessment'!C75","v":"For downstream companies: Where necessary, undertake spot checks at the smelter/refiner's facilities."},{"$f":"'2. Alignment Assessment'!G75","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H75","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I75","v":"N/A"},{"$error":"#NAME?"},null,null,null,null,"% of Not Aligned",{"$f":"N73/K69","v":{"$error":"#DIV/0!"}},{"$f":"O73/$K69","v":{"$error":"#DIV/0!"}},{"$f":"P73/$K69","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B76","v":"B.48"},{"$f":"'2. Alignment Assessment'!C76","v":"Assess risks against the requirements of the company's supply chain policy (consistent with Annex II), the relevant Supplement of the Guidance, national laws and other relevant legal instruments. Any reasonable inconsistency between these requirements and the information obtained through due diligence should constitute a risk."},{"$f":"'2. Alignment Assessment'!G76","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H76","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I76","v":"Partially Aligned"},{"$error":"#NAME?"}]
[null,{"$f":"'2. Alignment Assessment'!C77","v":"Step 3: Design and implement a strategy to respond to identified risks"},null,null,null,null,null,null,null,"Programme governance review"]
[null,{"$f":"'2. Alignment Assessment'!C78","v":"Requirements set by Programmes for those companies subject to audit under the Programme:"},null,null,null,null,null,null,null,"Overall"]
[{"$f":"'2. Alignment Assessment'!B79","v":"B.49"},{"$f":"'2. Alignment Assessment'!C79","v":"Report findings of risk assessment to designated senior management, outlining the information gathered and the actual and potential risks identified in the supply chain risk assessment."},{"$f":"'2. Alignment Assessment'!G79","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H79","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I79","v":"Fully Aligned"},{"$error":"#NAME?"},null,"Count",{"$f":"COUNT(D130:D172)","v":0},null,null,"No. of Fully addressed",{"$f":"COUNTIF(D130:D172,2)","v":0},null,null,null,"Overall","Fully addressed","Improvement opportunity","Not addressed"]
[{"$f":"'2. Alignment Assessment'!B80","v":"B.50"},{"$f":"'2. Alignment Assessment'!C80","v":"Enhance engagement with suppliers and strengthen internal controls, having regard to the specific measures for upstream and downstream companies provided in the Supplement."},{"$f":"'2. Alignment Assessment'!G80","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H80","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I80","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Max",{"$f":"K78*2","v":0},null,null,"% of Fully addressed",{"$f":"O78/K78","v":{"$error":"#DIV/0!"}},null,null,null,{"$f":"K81","v":{"$error":"#NAME?"}},{"$f":"O79","v":{"$error":"#DIV/0!"}},{"$f":"O81","v":{"$error":"#DIV/0!"}},{"$f":"O83","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B81","v":"B.51"},{"$f":"'2. Alignment Assessment'!C81","v":"For downstream companies:  Companies that have been unable to identify refiners in their supply chain(s) should devise a risk management plan that will enable them to demonstrate significant measureable improvement in doing so."},{"$f":"'2. Alignment Assessment'!G81","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H81","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I81","v":"N/A"},{"$error":"#NAME?"},null,"Sum",{"$f":"SUM(D130:D172)","v":{"$error":"#NAME?"}},null,null,"No. of Improvement opportunity",{"$f":"COUNTIF(D130:D172,1)","v":0},null,null,null,{"$f":"100%-S79","v":{"$error":"#NAME?"}},{"$f":"100%-T79","v":{"$error":"#DIV/0!"}},{"$f":"100%-U79","v":{"$error":"#DIV/0!"}},{"$f":"100%-V79","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B82","v":"B.52"},{"$f":"'2. Alignment Assessment'!C82","v":"Manage the identified risks by either: (i) continuing to trade but with measurable risk mitigation, (ii) temporarily suspending trade while mitigation is put in place, or (iii) ceasing trade with the relevant supplier. In doing so have regard to the specific recommendations of the relevant Supplements. "},{"$f":"'2. Alignment Assessment'!G82","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H82","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I82","v":"Partially Aligned"},{"$error":"#NAME?"},null,"Score",{"$f":"K80/K79","v":{"$error":"#NAME?"}},null,null,"% of Improvement opportunity",{"$f":"O80/K78","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B83","v":"B.53"},{"$f":"'2. Alignment Assessment'!C83","v":"For downstream companies: Companies should take immediate steps to disengage with a refiner if the refiner has not immediately suspended or discontinued engagement with its suppliers where reasonable risks of serious abuses or direct or indirect support to non-state armed groups exist."},{"$f":"'2. Alignment Assessment'!G83","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H83","v":"N/A"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I83","v":"N/A"},{"$error":"#NAME?"},null,null,null,null,null,"No. of Not addressed",{"$f":"COUNTIF(D130:D172,0)","v":0}]
[{"$f":"'2. Alignment Assessment'!B84","v":"B.54"},{"$f":"'2. Alignment Assessment'!C84","v":"Measurable risk mitigation should result in significant and measureable improvement towards eliminating the identified risks, other than serious abuses, within six months from the adoption of the risk management plan. If there no such measurable improvement within six months, companies should suspend or discontinue engagement with the supplier for a minimum of three months. "},{"$f":"'2. Alignment Assessment'!G84","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H84","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I84","v":"Not Aligned"},{"$error":"#NAME?"},null,null,null,null,null,"% of Not addressed",{"$f":"O82/K78","v":{"$error":"#DIV/0!"}}]
[{"$f":"'2. Alignment Assessment'!B85","v":"B.55"},{"$f":"'2. Alignment Assessment'!C85","v":"Build and/or exercise leverage over the actors in the supply chain who can most effectively and most directly prevent and mitigate the risks of adverse impacts. "},{"$f":"'2. Alignment Assessment'!G85","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H85","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I85","v":"Not Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B86","v":"B.56"},{"$f":"'2. Alignment Assessment'!C86","v":"Consult with suppliers and affected stakeholders to agree on the strategy for measurable risk mitigation in the risk management plan."},{"$f":"'2. Alignment Assessment'!G86","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H86","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I86","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B87","v":"B.57"},{"$f":"'2. Alignment Assessment'!C87","v":"For upstream companies: Publish the supply chain risk assessment and the supply chain management plan, with due regard to business confidentiality and other competitive concerns, and make them available to external stakeholders as set out in the relevant Supplement."},{"$f":"'2. Alignment Assessment'!G87","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H87","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I87","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B88","v":"B.58"},{"$f":"'2. Alignment Assessment'!C88","v":"For upstream companies: Gold producers with red flagged operations and other upstream companies sourcing ASM gold should assist and enable legitimate ASM producers to build supply chains consistent with the Guidance."},{"$f":"'2. Alignment Assessment'!G88","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H88","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I88","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B89","v":"B.59"},{"$f":"'2. Alignment Assessment'!C89","v":"Implement the risk management plan, monitor risk mitigation and report performance to designated senior management, and consider suspending or discontinuing trade with a supplier after failed attempts at mitigation."},{"$f":"'2. Alignment Assessment'!G89","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H89","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I89","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B90","v":"B.60"},{"$f":"'2. Alignment Assessment'!C90","v":"For upstream companies: Implement, monitor and track performance of risk mitigation in cooperation/consultation with local and central authorities and other relevant stakeholders. Consider establishing or supporting community-based networks to monitor risk mitigation. "},{"$f":"'2. Alignment Assessment'!G90","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H90","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I90","v":"Not Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B91","v":"B.61"},{"$f":"'2. Alignment Assessment'!C91","v":"Maintain ongoing risk monitoring, evaluate the effectiveness of risk mitigation efforts and undertake additional fact and risk assessments as required, for example following changes to the supply chain. "},{"$f":"'2. Alignment Assessment'!G91","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H91","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I91","v":"Partially Aligned"},{"$error":"#NAME?"}]
[null,{"$f":"'2. Alignment Assessment'!C92","v":"Step 4: Carry out independent third party audit of supply chain due diligence at identified points in the supply chain"}]
[null,{"$f":"'2. Alignment Assessment'!C93","v":"Requirements set by Programmes for those companies subject to audit under the Programme:"}]
[{"$f":"'2. Alignment Assessment'!B94","v":"B.62"},{"$f":"'2. Alignment Assessment'!C94","v":"Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain."},{"$f":"'2. Alignment Assessment'!G94","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H94","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I94","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B95","v":"B.63"},{"$f":"'2. Alignment Assessment'!C95","v":"Facilitate auditor access to company sites, documentation, records and, as appropriate, access to suppliers and other relevant stakeholders, such as on-the-ground assessment teams. "},{"$f":"'2. Alignment Assessment'!G95","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H95","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I95","v":"Fully Aligned"},{"$error":"#NAME?"}]
[null,{"$f":"'2. Alignment Assessment'!C96","v":"Requirements that Programmes set for auditors"}]
[{"$f":"'2. Alignment Assessment'!B97","v":"B.64"},{"$f":"'2. Alignment Assessment'!C97","v":"Audit scope covers all of the smelter/refiner's business activities and management processes related to mineral supply chain due diligence."},{"$f":"'2. Alignment Assessment'!G97","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H97","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I97","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B98","v":"B.65"},{"$f":"'2. Alignment Assessment'!C98","v":"The audit criteria assess the conformity of the smelter/refiner's due diligence practices against the requirements of a standard based on the Guidance."},{"$f":"'2. Alignment Assessment'!G98","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H98","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I98","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B99","v":"B.66"},{"$f":"'2. Alignment Assessment'!C99","v":"Auditors are required to be independent of the smelter/refiner and its supply chain, both with respect to business or financial relationships and with any services provided to the auditee company or its supply chain relating to due diligence practices."},{"$f":"'2. Alignment Assessment'!G99","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H99","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I99","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B100","v":"B.67"},{"$f":"'2. Alignment Assessment'!C100","v":"Auditors should be technically competent with appropriate mineral supply chain knowledge, as described in the Supplements. "},{"$f":"'2. Alignment Assessment'!G100","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H100","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I100","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B101","v":"B.68"},{"$f":"'2. Alignment Assessment'!C101","v":"Audit activities should include audit preparation, document review, in-site investigations, risk-based sampling of due diligence records and data, and audit conclusions, as described in the Guidance."},{"$f":"'2. Alignment Assessment'!G101","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H101","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I101","v":"Partially Aligned"},{"$error":"#NAME?"}]
[null,{"$f":"'2. Alignment Assessment'!C102","v":"Step 5: Report on supply chain due diligence"}]
[null,{"$f":"'2. Alignment Assessment'!C103","v":"Requirements set by Programmes for those companies subject to audit under the Programme:"}]
[{"$f":"'2. Alignment Assessment'!B104","v":"B.69"},{"$f":"'2. Alignment Assessment'!C104","v":"Annually report, or integrate into annual sustainability or corporate responsibility reports, information on supply chain due diligence."},{"$f":"'2. Alignment Assessment'!G104","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H104","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I104","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B105","v":"B.70"},{"$f":"'2. Alignment Assessment'!C105","v":"For all upstream companies (including smelters/refiners): The report should describe the company's management systems, the methodology and results of the risk assessment and the steps taken to manage risks, consistent with the specific content described in the Guidance. The report should be published."},{"$f":"'2. Alignment Assessment'!G105","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H105","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I105","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B106","v":"B.71"},{"$f":"'2. Alignment Assessment'!C106","v":"For smelters/refiners: The audit reports should be published."},{"$f":"'2. Alignment Assessment'!G106","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H106","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I106","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B107","v":"B.72"},{"$f":"'2. Alignment Assessment'!C107","v":"For gold refiners: In addition to reporting on management systems, risk assessment and risk management as defined in the Supplement, refiners should publish the summary audit reports including details of audit dates, activities, methodology and conclusions (either directly or through cooperation with an Industry Programme or Institutionalised Mechanism)."},{"$f":"'2. Alignment Assessment'!G107","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H107","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I107","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B108","v":"B.73"},{"$f":"'2. Alignment Assessment'!C108","v":"For downstream companies: The report should describe the company's management systems, the methodology and results of the risk assessment and the steps taken to manage risks, consistent with the specific content described in the Supplement."},{"$f":"'2. Alignment Assessment'!G108","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H108","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I108","v":"Fully Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B109","v":"C"},{"$f":"'2. Alignment Assessment'!C109","v":"Specific responsibilities of Programmes"}]
[null,{"$f":"'2. Alignment Assessment'!C110","v":"Step 1: Establish strong company management systems"}]
[{"$f":"'2. Alignment Assessment'!B111","v":"C.1"},{"$f":"'2. Alignment Assessment'!C111","v":"Undertake due diligence on the ownership (including beneficial ownership) and corporate structure of refiners/smelters seeking accreditation/certification or membership status under the Programme."},{"$f":"'2. Alignment Assessment'!G111","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H111","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I111","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B112","v":"C.2"},{"$f":"'2. Alignment Assessment'!C112","v":"Provide training to companies and/or their suppliers on due diligence management systems and processes."},{"$f":"'2. Alignment Assessment'!G112","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H112","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I112","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B113","v":"C.3"},{"$f":"'2. Alignment Assessment'!C113","v":"Programmes that provide support for downstream companies should collect and process information from suppliers, including smelters/refiners, on due diligence in the supply chains of minerals from conflict-affected or high risk areas."},{"$f":"'2. Alignment Assessment'!G113","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H113","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I113","v":"Not Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B114","v":"C.4"},{"$f":"'2. Alignment Assessment'!C114","v":"Provide or facilitate access to a grievance mechanism that allows any impacted stakeholder to voice concerns relating to the extraction and supply chain activities of the relevant mineral(s) covered by the Programme."},{"$f":"'2. Alignment Assessment'!G114","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H114","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I114","v":"Not Aligned"},{"$error":"#NAME?"}]
[null,{"$f":"'2. Alignment Assessment'!C115","v":"Step 2: Identify and assess risks in the supply chain"}]
[{"$f":"'2. Alignment Assessment'!B116","v":"C.5"},{"$f":"'2. Alignment Assessment'!C116","v":"Support companies sourcing minerals from red flagged operations in establishing on-the-ground assessment teams with appropriate capabilities and access rights as set out in the Guidance."},{"$f":"'2. Alignment Assessment'!G116","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H116","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I116","v":"Not Aligned"},{"$error":"#NAME?"}]
[null,{"$f":"'2. Alignment Assessment'!C117","v":"Step 3: Design and implement a strategy to respond to identified risks"}]
[{"$f":"'2. Alignment Assessment'!B118","v":"C.6"},{"$f":"'2. Alignment Assessment'!C118","v":"Demonstrate an understanding, gained through some form of impact analysis or qualitative or quantitative evaluation, of the social and economic impacts that the Programme's requirements may have on developing countries and the Programme's relevance to or linkages with other existing internationally recognised standards."},{"$f":"'2. Alignment Assessment'!G118","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H118","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I118","v":"Not Aligned"},{"$error":"#NAME?"}]
[null,{"$f":"'2. Alignment Assessment'!C119","v":"Step 4: Carry out independent third party audit of supply chain due diligence at identified points in the supply chain"}]
[{"$f":"'2. Alignment Assessment'!B120","v":"C.7"},{"$f":"'2. Alignment Assessment'!C120","v":"Draft Audit Standards in accordance with the recommendations of the Guidance."},{"$f":"'2. Alignment Assessment'!G120","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H120","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I120","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B121","v":"C.8"},{"$f":"'2. Alignment Assessment'!C121","v":"Accredit the auditors who may perform audits under the Programme."},{"$f":"'2. Alignment Assessment'!G121","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H121","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I121","v":"Partially Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B122","v":"C.9"},{"$f":"'2. Alignment Assessment'!C122","v":"Oversee, periodically review and monitor the ability of auditors to carry out audits in conformity with the Programme's requirements, based on the objectives, scope and criteria of the audit and judged against audit programme records."},{"$f":"'2. Alignment Assessment'!G122","v":"Not Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H122","v":"Partially Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I122","v":"Not Aligned"},{"$error":"#NAME?"}]
[{"$f":"'2. Alignment Assessment'!B123","v":"C.10"},{"$f":"'2. Alignment Assessment'!C123","v":"Publish summary audit reports of smelters/refiners that include: (a) Smelter/refiner details, date of the audit and the audit period, (b) Audit activities and methodology and (c) Audit conclusions."},{"$f":"'2. Alignment Assessment'!G123","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!H123","v":"Fully Aligned"},{"$error":"#NAME?"},{"$f":"'2. Alignment Assessment'!I123","v":"Fully Aligned"},{"$error":"#NAME?"}]
[]
[]
[]
[]
[]
[{"$f":"'3. Programme governance review'!B4","v":"Implementation aspect"},null,{"$f":"'3. Programme governance review'!D4","v":"Rating"}]
[null,{"$f":"'3. Programme governance review'!C5","v":"Stakeholder engagement"}]
[{"$f":"'3. Programme governance review'!B6","v":1},{"$f":"'3. Programme governance review'!C6","v":"The Programme involves/has involved external stakeholders (e.g. civil society, regulators) in the development and oversight of the due diligence, reporting and auditing requirements, including in risk mitigation efforts as set out in Step 3 of the Guidance."},{"$f":"'3. Programme governance review'!D6","v":"Fully addressed"},{"$f":"_xlfn.IFS(C130=\"Fully addressed\",2,C130=\"Improvement opportunity\",1,C130=\"Not addressed\",0)","v":{"$error":"#NAME?"}}]
[{"$f":"'3. Programme governance review'!B7","v":2},{"$f":"'3. Programme governance review'!C7","v":"The Programme regularly participates in relevant public forums (whether through media or events such as conferences) where it provides information about its responsible supply chain programme, including the risks it identifies in the supply chains of companies within the Programme and on mitigation strategies that are being effectively deployed to address these risks. "},{"$f":"'3. Programme governance review'!D7","v":"Improvement opportunity"},{"$f":"_xlfn.IFS(C131=\"Fully addressed\",2,C131=\"Improvement opportunity\",1,C131=\"Not addressed\",0)","v":{"$error":"#NAME?"}}]
[{"$f":"'3. Programme governance review'!B8","v":3},{"$f":"'3. Programme governance review'!C8","v":"The Programme has established a functioning and accessible grievance mechanism that enables stakeholders to raise concerns relating to the Programme itself (i.e. not just issues in companies' supply chains)."},{"$f":"'3. Programme governance review'!D8","v":"Not addressed"},{"$error":"#NAME?"}]
[null,{"$f":"'3. Programme governance review'!C9","v":"Responsiveness"}]
[{"$f":"'3. Programme governance review'!B10","v":4},{"$f":"'3. Programme governance review'!C10","v":"The Programme has a mechanism for monitoring, tracking and sharing information - including between programmes, if appropriate - on incidents or emerging risks identified from company's risk assessments and other relevant sources that could create red flags for companies participating in the Programme. "},{"$f":"'3. Programme governance review'!D10","v":"Improvement opportunity"},{"$f":"_xlfn.IFS(C134=\"Fully addressed\",2,C134=\"Improvement opportunity\",1,C134=\"Not addressed\",0)","v":{"$error":"#NAME?"}}]
[{"$f":"'3. Programme governance review'!B11","v":5},{"$f":"'3. Programme governance review'!C11","v":"The Programme has an effective process for communicating details of incidents or emerging risks to companies, auditors and other relevant stakeholders in a timely manner in order to support companies in performing their own supply chain due diligence activities. "},{"$f":"'3. Programme governance review'!D11","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B12","v":6},{"$f":"'3. Programme governance review'!C12","v":"The Programme has a process for regular review and, as necessary, updating of its guidance and requirements for companies and auditors."},{"$f":"'3. Programme governance review'!D12","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B13","v":7},{"$f":"'3. Programme governance review'!C13","v":"The Programme has defined its expectations for the timeliness and completion of corrective actions or non-conformance findings that are identified through a company's audit against the Programme requirements. "},{"$f":"'3. Programme governance review'!D13","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B14","v":8},{"$f":"'3. Programme governance review'!C14","v":"The Programme has a regular communications programme through which it informs companies and other relevant stakeholders of relevant developments in its responsible sourcing scheme, including updates to standards or guidance documents."},{"$f":"'3. Programme governance review'!D14","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B15","v":9},{"$f":"'3. Programme governance review'!C15","v":"The Programme has procedures in place to follow up and address grievances brought to it in a timely manner (whether relating to supply chain issues or the Programme itself). "},{"$f":"'3. Programme governance review'!D15","v":"Not addressed"},{"$error":"#NAME?"}]
[null,{"$f":"'3. Programme governance review'!C16","v":"Membership requirements and/or conditions of certification/accreditation"}]
[{"$f":"'3. Programme governance review'!B17","v":10},{"$f":"'3. Programme governance review'!C17","v":"All organisations that are considered members of the Programme (regardless of whether they are subject to audit) are required by the Programme to commit to implementing the OECD Due Diligence Guidance. "},{"$f":"'3. Programme governance review'!D17","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B18","v":11},{"$f":"'3. Programme governance review'!C18","v":"A third party audit that verifies a company's conformance with all of the requirements of the Programme's responsible sourcing scheme is required for companies at identified points in the supply chain (as determined by the Guidance) to be considered accredited or certified by the Programme."},{"$f":"'3. Programme governance review'!D18","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B19","v":12},{"$f":"'3. Programme governance review'!C19","v":"Where an audit finds non-conformance issues, the Programme requires companies to submit an action plan to the Programme. Actions to address major non-conformance findings are monitored by the Programme and sanctions applied (e.g. delisting/exclusion) if such issues are not addressed to the Programme's satisfaction within 6 months of the date of the finding. "},{"$f":"'3. Programme governance review'!D19","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B20","v":13},{"$f":"'3. Programme governance review'!C20","v":"Programme communications (whether private with individual companies or public) demonstrate that the Programme does not have unrealistic expectations in relation to the due diligence activities and performance of companies within the Programme (e.g. an acceptance of failings/challenges following good faith and reasonable efforts, provided there is commitment to improve within an agreed timeframe)."},{"$f":"'3. Programme governance review'!D20","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[null,{"$f":"'3. Programme governance review'!C21","v":"Audit governance"}]
[{"$f":"'3. Programme governance review'!B22","v":14},{"$f":"'3. Programme governance review'!C22","v":"The Programme has a process for validating the credentials and suitability of auditors. Only auditors that have been approved by the Programme can undertake audits of company conformance with the Programme's responsible sourcing requirements."},{"$f":"'3. Programme governance review'!D22","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B23","v":15},{"$f":"'3. Programme governance review'!C23","v":"The Programme maintains an up-to-date list of approved auditors."},{"$f":"'3. Programme governance review'!D23","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B24","v":16},{"$f":"'3. Programme governance review'!C24","v":"The Programme requires auditors to be independent of auditees and has defined its definition of independence with reference to recognised global standards (e.g. ISO 19011, ISAE 3000)"},{"$f":"'3. Programme governance review'!D24","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B25","v":17},{"$f":"'3. Programme governance review'!C25","v":"Where the Programme has a process for review and approval of company's audits or their audited reports, mechanisms have been established to ensure that the Programme's review/approval activities are transparent and free of any potential conflicts of interest."},{"$f":"'3. Programme governance review'!D25","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B26","v":18},{"$f":"'3. Programme governance review'!C26","v":"Where the Programme has a process for review and approval of company's audits or their audited reports, mechanisms have been established to ensure that the Programme's review/approval activities are undertaken in a timely fashion."},{"$f":"'3. Programme governance review'!D26","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[null,{"$f":"'3. Programme governance review'!C27","v":"Audit standards and guidance"}]
[{"$f":"'3. Programme governance review'!B28","v":19},{"$f":"'3. Programme governance review'!C28","v":"The Programme requires audits to be undertaken in accordance with recognised global standards (e.g. ISO19011, ISAE 3000)."},{"$f":"'3. Programme governance review'!D28","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B29","v":20},{"$f":"'3. Programme governance review'!C29","v":"The Programme requires auditors to develop an understanding of the auditee company's business and supply chain."},{"$f":"'3. Programme governance review'!D29","v":"Fully addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B30","v":21},{"$f":"'3. Programme governance review'!C30","v":"The Programme requires auditors to develop risk-based audit testing/sampling strategies that consider: (a) inherent risks, (b) control risks and (c) detection risks.*"},{"$f":"'3. Programme governance review'!D30","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B31","v":22},{"$f":"'3. Programme governance review'!C31","v":"The Programme requires auditors to apply materiality in the design and execution of their audit testing/sampling strategies."},{"$f":"'3. Programme governance review'!D31","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B32","v":23},{"$f":"'3. Programme governance review'!C32","v":"The Programme requires auditors to utilise sufficient and appropriate evidence to form their conclusions."},{"$f":"'3. Programme governance review'!D32","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B33","v":24},{"$f":"'3. Programme governance review'!C33","v":"The Programme provides guidance to auditors and companies on the identification and handling of non-conformance findings. This includes guidance - without impairing auditors' professional judgement - on the distinction between major and minor non-conformance (or high, medium or low risks). "},{"$f":"'3. Programme governance review'!D33","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[null,{"$f":"'3. Programme governance review'!C34","v":"Programme internal governance"}]
[{"$f":"'3. Programme governance review'!B35","v":25},{"$f":"'3. Programme governance review'!C35","v":"The Programme has given consideration to where there could be actual or perceived conflicts of interest between Programme management personnel and companies, and has established processes to manage potential conflicts of interest. "},{"$f":"'3. Programme governance review'!D35","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B36","v":26},{"$f":"'3. Programme governance review'!C36","v":"The Programme has documented internal procedures for the vetting of prospective companies and auditors wishing to join or be accredited by the Programme."},{"$f":"'3. Programme governance review'!D36","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B37","v":27},{"$f":"'3. Programme governance review'!C37","v":"Key decisions relating to the management of the Programme, particularly decisions relating to the performance of companies or auditors within the Programme, are internally documented. "},{"$f":"'3. Programme governance review'!D37","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[null,{"$f":"'3. Programme governance review'!C38","v":"Transparency"}]
[{"$f":"'3. Programme governance review'!B39","v":28},{"$f":"'3. Programme governance review'!C39","v":"The Programme publicly provides details of its own internal governance structure, staffing, resources and oversight mechanisms."},{"$f":"'3. Programme governance review'!D39","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B40","v":29},{"$f":"'3. Programme governance review'!C40","v":"The Programme maintains an up-to-date, publicly available, list of companies who are currently in conformance with the Programme's requirements."},{"$f":"'3. Programme governance review'!D40","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B41","v":30},{"$f":"'3. Programme governance review'!C41","v":"The Programme maintains an up-to-date, publicly available, list of companies who have been disqualified/suspended for failure to meet the Programme's requirements."},{"$f":"'3. Programme governance review'!D41","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B42","v":31},{"$f":"'3. Programme governance review'!C42","v":"Programmes proactively encourage transparent disclosure by companies of challenges, identified risks and mitigation plans.  "},{"$f":"'3. Programme governance review'!D42","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B43","v":32},{"$f":"'3. Programme governance review'!C43","v":"The Programme encourages companies to provide sufficient details within their reports to enable performance over time to be measured by external stakeholders."},{"$f":"'3. Programme governance review'!D43","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[null,{"$f":"'3. Programme governance review'!C44","v":"Programme aims and objectives"}]
[{"$f":"'3. Programme governance review'!B45","v":33},{"$f":"'3. Programme governance review'!C45","v":"The Programme has established processes for monitoring and evaluating whether the Programme itself is meeting its own aims and objectives in relation to responsible sourcing practices within the industry sector in which it operates."},{"$f":"'3. Programme governance review'!D45","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B46","v":34},{"$f":"'3. Programme governance review'!C46","v":"The Programme publicly reports on its evaluations of whether it is meeting its own aims and objectives in relation to responsible sourcing practices."},{"$f":"'3. Programme governance review'!D46","v":"Not addressed"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B47","v":35},{"$f":"'3. Programme governance review'!C47","v":"The Programme encourages mutual recognition - subject to appropriate quality control - of other responsible sourcing Programmes, both vertically (at different stages of the supply chain) and horizontally (with the same or similar scope)."},{"$f":"'3. Programme governance review'!D47","v":"Improvement opportunity"},{"$error":"#NAME?"}]
[{"$f":"'3. Programme governance review'!B48","v":36},{"$f":"'3. Programme governance review'!C48","v":"The Programme actively supports implementation the Appendix on 'Suggested measures to create economic and development opportunities for artisanal and small-scale miners'."},{"$f":"'3. Programme governance review'!D48","v":"Not addressed"},{"$error":"#NAME?"}]