Beyond Extraction: How Three New Frameworks Are Trying to Rewire the Ethics of the Mining Supply Chain

Introduction

Three policy developments published over the past month do not, at first glance, seem to belong in the same article. A partnership between the International Labour Organization and an industry body to tackle child labour in Congolese cobalt mines. A landmark OECD report extending responsible sourcing due diligence to sand and silicates. A joint statement from six multilateral development banks pledging coordinated ESG standards for critical mineral value chains in developing countries.

Look more closely, and a single argument runs through all three. The responsible sourcing frameworks that companies have relied on for the past decade, centred on audits, certifications, and a relatively narrow list of flagged minerals, are no longer adequate. The legal, physical, and geopolitical risks embedded in extractive supply chains have grown faster than the tools designed to manage them. Each of these three developments represents an attempt, from a different institutional vantage point, to close that gap.

For companies in the battery, semiconductor, solar, construction, and consumer electronics sectors, the practical implications are significant and largely unpriced. Mandatory due diligence deadlines are approaching. The definition of which materials require scrutiny is expanding. And the human cost of inaction, dramatised by the deaths of dozens of children in the DRC this year, is no longer something that can be kept at arm's length from boardroom decision-making.

Children in the Supply Chain: Why an Audit-Only Approach Has Failed

On March 3, 2026, a landslide at the artisanal coltan mine of Kasasa in North Kivu killed more than 200 people. The Congolese government confirmed that 70 of the dead were children, most of them working as labourers in hand-dug shafts with no helmets, no engineers, and no safety oversight. Less than a week later, the surviving miners had returned to work. They had no other way to earn money.

The Kasasa disaster was the second major collapse at the Rubaya mining area in 2026. A landslide in January had already killed more than 400 people, including artisanal miners, children, and small traders working near the excavation sites. Rubaya's coltan mines have been under the control of the M23 rebel group since May 2024; M23 has been collecting more than $800,000 per month in taxes on coltan production, which represents over 15 percent of the global tantalum supply.

This is the context in which, on May 8, 2026, the ILO's Child Labour Platform and the Responsible Minerals Initiative announced a formal partnership to address child labour in artisanal and small-scale mining (ASM). The ILO estimates that more than one million children are engaged in labour in mines and quarries globally. UNICEF estimates that around 40,000 of those children are working in mines in the DRC alone, where an estimated 15 to 30 percent of the country's cobalt output originates in artisanal operations.

The significance of this partnership lies less in its headline ambition, which no one would contest, and more in its strategic framing. The ILO-RMI agreement explicitly positions ASM formalization, not audits and certifications, as the primary mechanism for compliance. This matters because it reframes what due diligence actually requires. Research in the DRC has documented that formalization addresses child labour, improves mine safety, and removes the conditions that enable debt bondage, all through a single intervention. The partnership signals that companies with cobalt in their supply chains should treat support for formalization as a legally relevant component of their forced labour compliance strategy, not a voluntary gesture.

The regulatory backdrop makes this framing urgent. The EU's Forced Labour Regulation, which bans products made with forced labour from the EU market, applies from December 2027. The Corporate Sustainability Due Diligence Directive, already amended by the Omnibus I reforms that came into force in March (which I covered in detail in May), requires companies above defined thresholds to conduct human rights due diligence across their value chains from July 2029. Chinese companies currently control roughly 80 percent of DRC mineral processing capacity, which complicates the oversight picture considerably for Western buyers trying to trace their cobalt to source.

Sand in the Spotlight: The Responsible Sourcing Net Gets Wider

If the ILO-RMI partnership addresses the human cost of a well-known supply chain risk, the OECD's February 2026 report on sand and silicates addresses a risk that most companies have not yet registered at all.

Sand is the second most extracted resource on Earth after water. Global consumption currently stands at around 50 billion tonnes annually and is projected to reach 86 billion tonnes by 2060. The market is worth approximately $600 billion a year, which makes it more valuable annually than all gold production. Yet until this year, the OECD's responsible sourcing due diligence recommendations covered 15 minerals and metals. Sand was not among them.

The April 27 publication of the key findings brochure, summarising the full February report, marks a formal expansion of that framework. The OECD identifies ESG risks in sand supply chains spanning environmental degradation, human rights abuses in upstream extraction, conflict financing, and financial crime. These risks are not theoretical. Belgium, China, the Netherlands, Malaysia, Singapore, Switzerland, and Vietnam have all taken separate regulatory actions on sand governance in recent years, precisely because the problems are real and documented.

For most companies, the immediate practical relevance is in the semiconductor and solar subsectors. High-purity quartz, a member of the sand and silicates family, is the foundational raw material for polysilicon, which in turn is the primary input for both solar panels and semiconductor wafers. China declared high-purity quartz its 174th strategic mineral in April 2025. The high-purity quartz sand market, valued at $4 billion in 2024, is projected to grow to $6.3 billion by 2032. Yet as the OECD report notes, trade data for high-purity quartz is bundled with other sand and quartz categories in tariff schedules, making material traceability genuinely difficult.

The OECD framework does not impose legal obligations directly. What it does is establish the standard against which companies will increasingly be measured by regulators, investors, and litigation risk. In my analysis of the OECD's sand framework last month, I noted that these implications are significant and largely unpriced for companies across construction, electronics, and renewable energy. That assessment has not changed. The combination of growing regulatory momentum, concentration in high-purity quartz processing, and the expansion of mandatory due diligence scope means that sand is likely to move from a background operational input to a named supply chain risk category within a relatively short timeframe.

Development Banks Enter the Frame: ESG Conditionality at Scale

The third piece of this picture is structural rather than sector-specific. On April 17, 2026, six multilateral development banks, the World Bank Group, the African Development Bank, the Asian Development Bank, the EBRD, the EIB, and the IDB, issued a joint statement at a G7 Outreach session committing to align their ESG standards and co-financing approaches for critical mineral value chains across developing countries.

The statement is notable both for who signed it and for what it explicitly says. Masato Kanda, President of the ADB and Chair of the MDB Heads Group, was direct in his diagnosis: "Too often, mineral-rich developing countries simply export raw ore, while missing opportunities for value addition, skilled employment, and broad industrial growth." The framework commits the six MDBs to help build regional processing ecosystems, not just finance extraction.

This is a meaningful shift in development finance doctrine. For decades, the dominant model in resource-rich developing countries has been raw material export, with the higher-value refining and processing stages concentrated elsewhere (often in China, for reasons I examined in detail in my analysis of midstream processing vulnerabilities in April). The MDB framework explicitly frames ESG compliance as inseparable from development finance eligibility, meaning that projects which fail to meet environmental and social standards will not access the capital.

The Joint Collaboration Framework, to be completed by late 2026, will coordinate policy and regulatory reform support, infrastructure financing linked to mineral corridors, and co-financing with private investors. Private investor wariness is acknowledged directly: the MDB statement notes that de-risking through concessional finance, guarantees, and strategic partnerships is necessary to mobilise private capital at the required scale.

A note of scepticism is warranted. Devex observed that the real test will be whether this framework goes beyond coordination and actually delivers the value-addition that resource-rich countries have been requesting for years. The IMF estimates that Africa holds 30 percent of the world's proven critical mineral reserves. The countries sitting on those reserves have watched processing value accrue elsewhere for decades, and a joint statement, however well-aligned institutionally, is not the same as a bankable project. The MDB Heads Group has committed to delivering tangible "lighthouse" projects under the framework, and those will be the actual test of whether this coordination translates into structural change.

The Connecting Thread: Informality, Concentration, and the Limits of Audit Culture

Reading these three developments together, a common diagnosis emerges. The responsible sourcing architecture that companies have been using, built around third-party audits, certification schemes, and contractual representations from suppliers, was designed for a world where the problems were more visible and more tractable than they actually are.

The Kasasa collapse illustrates why audit culture alone fails. Audits check for conditions at a specific point in time at registered, accessible sites. Artisanal mining in conflict-affected areas is, by definition, informal, dispersed, and often operating under armed group control. An audit cannot reach a hand-dug pit 100 metres underground in territory controlled by M23. What can reach it, in time, is formalization: legal registration of mines, access to safety infrastructure, alternative income pathways that reduce the economic compulsion driving families to send children underground.

Sand and silicate supply chains present a different variant of the same problem. Because sand is treated as a bulk commodity rather than a named critical material, it has historically attracted none of the due diligence infrastructure applied to cobalt or gold. Yet the ESG risks, including illegal dredging, habitat destruction, conflict financing from riverbed sand extraction in fragile states, and human rights abuses in upstream operations, are real and documented. The OECD's extension of its framework is partly about correcting a category error: the assumption that ubiquity means low risk.

The MDB joint framework addresses a third dimension: the structural concentration of processing capacity that leaves raw material producers trapped in low-value export models. Chinese state-backed firms were willing to accept risks and returns that Western companies were not, which is how they came to control 80 percent of DRC mineral processing and dominate the global cobalt refining market. The MDB framework is, in part, an attempt to replicate that patient-capital approach through multilateral rather than bilateral state financing, without the governance compromises that have accompanied Chinese investment in some contexts.

All three initiatives also share a common view of what the private sector's role should be. None of them frames industry as a passive compliance recipient waiting to be told what to do. The ILO-RMI partnership explicitly uses the RMI's industry convening capacity to create pathways for downstream companies to contribute to upstream remediation strategies. The OECD guidance is addressed directly to companies across the sand and silicates value chain. The MDB framework calls for co-financing and shared diagnostics with private investors. The model in each case is active partnership, not enforcement against a reluctant corporate sector.

What Comes Next: Deadlines, Decisions, and Diminishing Lead Time

The regulatory calendar is worth stating plainly, because the timelines are shorter than many companies appear to have internalised. The EU Forced Labour Regulation applies from December 2027. The revised CSDDD, as amended by Omnibus I, applies from July 2029. The European Commission is required to publish implementation guidelines on forced labour due diligence by June 14, 2026, just over a month from now. That guidance will shape what companies are actually expected to do in practice, and it is likely to reference both the ILO normative framework and the OECD minerals guidance.

For cobalt buyers, the ILO-RMI partnership provides a structured, standards-based channel through which companies can engage with ASM formalization efforts in the DRC and Madagascar. The ILO is already operational in both countries through the GALAB project, which works to build government capacity to eliminate child labour from the cobalt mining sector. Companies that are not yet engaged with this infrastructure have less time than they may assume to build the upstream relationships that meaningful due diligence requires.

For companies with solar, semiconductor, or construction supply chains, the OECD sand framework is a leading indicator of where regulatory attention is heading. The high-purity quartz sector in particular, concentrated geographically and strategically significant for both solar panels and semiconductor wafers, is likely to attract the same policy scrutiny that rare earth elements received five years ago. The time to conduct supply chain mapping and risk assessment is before regulatory requirements crystallise, not after.

For governments and investors watching the MDB framework take shape, the test will come in the second half of 2026 when the Joint Collaboration Framework is finalised and the first lighthouse projects are announced. Whether the six MDBs can genuinely coordinate in ways that go beyond parallel lending into shared standards and co-designed projects will determine whether this initiative has lasting structural effect.

The overarching trajectory is clear. The scope of what counts as a responsible sourcing obligation is widening. The communities, materials, and geographies that fall within that scope are expanding. And the legal and financial consequences of failing to engage with that expanding scope are becoming concrete, enforceable, and time-bound. The question for companies is not whether these changes are coming. It is whether they are building the internal capacity and external partnerships to meet them before the deadlines arrive.