Due Diligence for Responsible Sand and Silicate Supply Chains

4. Considerations for enhancing responsible sourcing of sand and silicates

Abstract

This chapter explores how companies operating in sand and silicate supply chains can implement due diligence based on OECD standards. Considering their strategic uses, widespread adverse impacts and increasing, potentially unsustainable demand, there is a shared interest in collaborative measures by companies to more responsibly produce and source sand and silicates. Governments can support an enabling environment for responsible business conduct, including by setting an example through responsible public procurement and development finance for infrastructure.

Considerations for companies

Downstream uses of sand and silicates span a range of diverse sectors, some with significantly more experience with expectations for responsible business conduct. The following considerations can help companies with varying levels of experience apply OECD standards and their due diligence framework to the sand and silicates sector.

Considerations for all companies, including those with less experience in due diligence:

• Carry out a scoping exercise to identify risks across operations and business relationships, with special attention to high-risk areas and business models that may influence the nature of risks and the context of extraction and processing.

• Identify and assess actual and potential adverse impacts based on severity and likelihood. This includes reviewing credible, publicly available reports and engaging with suppliers, governments, civil society and relevant experts (OECD, 2018[82]).

• Engage with peer and partner companies to learn about joint action underway and explore pre-competitive collaboration to build leverage and pool resources for improving due diligence.

• Some sectors like construction consume large volumes of sand and silicates but tend not to disclose extensive information on their due diligence. Greater uptake of due diligence by this sector would make a significant contribution to enhancing responsible production and sourcing of sand and silicates.

Considerations for companies already conducting due diligence to integrate into existing systems and practices:

• Identify material locations and transport routes as part of the scoping exercise while being mindful of the participation of multiple, often small operators in supply chains of variable length and multidimensional exposure to risks and impacts.

• Identify dominant extraction systems as part of the risk scoping exercise to understand whether sourcing from freshwater and marine ecosystems is taking place. High-value biodiversity areas or ecosystems with unique biophysical characteristics can serve as additional screening factors for risk identification in sand and silicate production.

Adapt risk mitigation to the characteristics of the supply chain; where sand and silicates are produced and consumed within short value chains, identify localised approaches to risk mitigation. Where sand and silicate supply chains are transboundary, explore integration of sand and silicates into multi-tiered due diligence approaches for base and precious metals like those in Figure 1.1Figure 1.2. The use of lime in the smelting and refining of non-ferrous metals can be a good entry point for applying existing due diligence verification initiatives to the sand and silicates supply chain.

• Considering the interconnectedness of RBC risks in sand and silicates, adopt a holistic approach to risk mitigation. For example, in dynamic ecosystems, risks from sand and silicate extraction can propagate beyond the immediate extraction site and accumulate over time. OECD standards for RBC provide guidance on how to assess a company’s involvement with the actual or potential adverse impacts and how this influences expectations for risk mitigation (see Box 4.1) (OECD, 2018[82]).

• Investment in circularity measures and resource efficiency are relevant to addressing unsustainable extraction and consumption rates for sand and silicates and can help companies prevent environmental impacts (OECD, 2025[117]).

• Pursue an engagement strategy that meets the legitimate expectations of Indigenous Peoples, particularly with regard for domestic legal requirements to obtain free, prior and informed consent (FPIC) in order for projects to proceed. In countries where FPIC is not legally mandated, enterprises should consider local expectations, the risks posed to Indigenous Peoples and to the operations as result of local opposition (OECD, 2017[84]).

Any company producing or sourcing sand and silicate materials can engage in collaborative efforts to:

• Generate and share more information on supply chain risks in the sector.

• Establish upstream risk monitoring systems adapted to sand and silicate supply chains that companies can use to inform their responses to identified risks.

• Help generate more information on whether a control point1 approach is fit for purpose for sand and silicates and, where relevant, identify the most suitable control point.

• Explore the extent to which existing due diligence facilitation and verification initiatives (including audit and certification programmes) can adopt due diligence considerations for sand and silicates. Explore whether new approaches are needed while learning from, and building on, existing initiatives.

• Engage with other relevant stakeholders to support formalisation efforts and enhance market access for legitimate ASM in line with the OECD Minerals Guidance (OECD, 2016[80]) and building on international efforts and principles for ASM formalisation like those set out in Mosi-ao-Tunya Declaration (Mining, 2018[175]).

Box 4.1. OECD standards on responsible business conduct

The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct call on enterprises to undertake risk-based due diligence to identify, prevent, mitigate and account for how they address actual and potential adverse impacts in their own operations and supply chains. OECD standards on responsible business conduct address risks spanning human rights, labour, environment, corruption among others affecting people, planet and society. The OECD Due Diligence Guidance for Responsible Business Conduct (RBC Guidance) and the OECD Minerals Guidance set out a step-by-step due diligence framework with specific recommendations for all companies sourcing minerals.

The OECD Handbook on Environmental Due Diligence in Mineral Supply Chains helps companies apply OECD standards on responsible business conduct to address environmental risks spanning biodiversity loss, air, water and soil pollution, water depletion and climate change. Together, the Handbook and the Minerals Guidance delineate responsibilities of companies based on their position in the minerals supply chain and their proximity to adverse impacts, from miners and traders to smelters and recyclers. While the sand and silicates sector is exceedingly varied, with a range of processing and value chain configurations, the recommendations and concepts in the RBC Guidance, Minerals Guidance and Environmental Handbook are fit to apply to sand and silicates.

Due diligence applies across the supply chain and should be proportionate to the nature, severity, and likelihood of impacts. Where it is not feasible to address all identified impacts at once, businesses should prioritise the most severe and likely impacts and allocate resources accordingly. Enterprises’ relationship to adverse impacts determine how they should respond to them: where an enterprise causes an impact, it should cease, prevent or remedy it; where it contributes, it should mitigate or cooperate in remedy; and where it is directly linked, it should seek to influence partners to prevent or address the impact. The process applies across the entire supply chain, beyond first-tier relationships, and recognizes the role of “control points” such as smelters and refiners in mineral supply chains.

While contextual factors like leverage, size and resources influence how due diligence is carried out, they do not remove responsibility. The goal is meaningful progress on significant risks, using credible prioritisation and time-bound targets, without expecting risk-free supply chains.

Sources: OECD (2023[83]), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, https://doi.org/10.1787/81f92357-en; OECD (2018[82]), Due Diligence Guidance for Responsible Business Conduct, https://doi.org/10.1787/15f5f4b3-en; OECD (2016[80]), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, https://doi.org/10.1787/9789264252479-en; OECD (2023[81]), Handbook on Environmental Due Diligence in Mineral Supply Chains, https://doi.org/10.1787/cef843bf-en

Considerations for governments

Given the use of sand and silicates in a range of strategic sectors, spanning high-volume sectors like infrastructure as well as niche applications like semiconductors and specialty glass, widespread impacts and increasing, potentially unsustainable levels of extraction, there is a shared interest in setting global approaches and rules for the responsible, sustainable use of sand and silicates. Governments can take action by considering the following policy measures:

• In a context of growing economic security concerns, and building on existing efforts, consider shifting trade dependencies in the semiconductor supply chain in policies to enhance resilience for critical raw materials.

• Improve harmonisation and precision of national trade nomenclatures using the HS trade classification system for sand and silicates to enhance transparency of some of these materials.

• Progressively extend existing supply chain due diligence expectations to sand and silicates.

• Engage in customs and law enforcement cooperation to counter illicit flows of sands and silicates.

• Using a risk-based approach that is mindful of varying risk profiles across supply chains and commodities within the sand and silicates sector,, support the implementation of RBC provisions in public infrastructure policies spanning export credit agencies, quality infrastructure frameworks and certification programmes, and risk management frameworks applied by international development finance institutions (OECD, 2022[176]; OECD, 2022[177]). For example, governments can include certain criteria in public tenders to enhance responsible sourcing of sand and silicates (OECD, 2024[178]).

• Ensure enforcement of relevant environmental regulations in alignment with international best practice and integrate responsible sand and silicate supply chains into implementation programmes for international environmental conventions related to mining and quarrying, for example to help give effect to the United Nations Environment Assembly (UNEA) Resolution 6/5 on environmental aspects of minerals and metals (UNEP, 2024[179]).

• Pursue international co-operation to track sand and silicate extraction and consumption, especially for construction sand at regional level where extraction can become unsustainable, and foster multi-stakeholder collaboration to enable more sustainable sand and silicate production and consumption rates.

Considerations for other stakeholders

Civil society organisations and academia can help support due diligence by companies in sand and silicate supply chains by enhancing knowledge in five key areas for improvement if properly consulted and resourced:

• Whole-of-supply chain research on RBC impacts in sand and silicate supply chains is rare, and existing life cycle assessments tend to focus on energy consumption and carbon emissions alone, often overlooking broader environmental impacts. There is scope to enhance available evidence on RBC across supply chain segments

• Available evidence largely relates to risks and impacts that can be associated with construction aggregates sourcing. Industrial sands, clays, high-purity quartz, and other silicate minerals are less explored, indicating a need for future research and guidance.

• Many existing studies address isolated sets of impacts bounded by each extraction system (terrestrial, manufacturing, freshwater, marine). More comprehensive, integrated assessments of sand and silicate trade flows and risks through global and interconnected supply chains are needed.

• Existing research often discusses ‘illegal’ sand and silicate extraction with insufficient attention to the underlying causes of informal mining, processing and trading. More analytical research on gaps in applicable legal frameworks, governance systems and transparency can help generate a more nuanced understanding of these root causes and provide the contextual information needed to conceive meaningful solutions for formalisation in the concerned regions and supply chains.

Note

← 1.  Control points are points in the supply chain where more market concentration and leverage prevail, there is high visibility over upstream risks yet relatively straightforward for downstream companies to map their supply chains to. These points are ideal for assessments and where relevant audits, and broader efforts to obtain risk information or track results of risk mitigation.