The OECD five-step framework and where satellite screening actually fits

If you work in minerals or metals compliance, you've had the OECD Due Diligence Guidance quoted at you by an auditor, a customer, or your own legal team often enough that the five steps are practically muscle memory: establish management systems, identify and assess risk, design a response, get an independent audit, report annually. What's less clear, most of the time, is what you're supposed to do when step two hits a wall because the tier-2 and tier-3 sites feeding your supply chain were never named by anyone.

That gap is where satellite screening earns its place, and it's worth being precise about which step it serves and which steps it doesn't touch.

The five steps, briefly

The framework comes from the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Plenty of due diligence programs outside minerals have borrowed its shape since. The five steps:

1. Establish strong company management systems, including a supply chain policy and a grievance mechanism.
2. Identify and assess risk in the supply chain, down to the mine, smelter, mill, tannery, or refinery level.
3. Design and implement a strategy to respond to identified risks.
4. Carry out an independent third-party audit at identified points in the supply chain.
5. Report annually on due diligence steps taken.

Steps one, four, and five are largely about process and documentation. You write the policy, you bring in the auditor, you publish the report. Step three depends entirely on what step two surfaces. And step two is the one that quietly assumes a supplier list exists.

Where step two breaks down

A tier-1 supplier will usually tell you who their direct sub-suppliers are, because there's a contract and an invoice trail. Go one or two tiers further back, into a producing region where smelting or tanning capacity has grown faster than anyone's paperwork, and that trail runs out. Your tier-1 may genuinely not know which smelter their material passed through. Or they know and don't want to say, because the real supplier doesn't appear on anyone's approved list.

Either way, you're stuck doing step two, "identify and assess risk," based entirely on what the company upstream of you chooses to declare. That's disclosure dressed up as identification, and whether it's complete is pretty much a matter of faith.

What satellite screening adds at this step

High-resolution multispectral satellite imagery reads physical signatures instead of contracts or invoices: the thermal and structural footprint of a smelter, the effluent patterns around a tannery, the layout that distinguishes a working refinery from a warehouse. Run over a producing region at a given point in time, it turns up sites that match those signatures whether or not anyone named them.

That's the specific job this fills in step two. It gives you a candidate list: facilities that physically exist and physically operate in the region your tier-1 sources from, set against the list your tier-1 gave you. A match on that candidate list doesn't by itself make a site non-compliant or prove it's connected to your supply chain. Where the two lists don't line up, though, you have a lead worth chasing through site visits, supplier questioning, or your own grievance mechanism, rather than a blind spot you didn't know you had.

What it doesn't replace

This is a screening input, not steps three through five. A candidate site still needs to be investigated before anyone calls it a risk, let alone a confirmed link to your supply chain. The independent audit in step four still has to happen on the ground. The annual report in step five still needs the narrative around what you found and what you did about it. Satellite screening closes one gap, in step two, and leaves the rest of the framework exactly as demanding as it already was.

For a compliance manager mapping a region with no declared supplier list below tier one, that distinction matters more than any benchmark number could. Supply Chain Mapping runs an annual satellite pass over a producing region and delivers exactly this: a candidate-site list of unreported smelters, mills, tanneries, and refineries to put alongside whatever your tier-1 is willing to disclose. If step two of your due diligence program has been running on faith, it might be worth seeing what the imagery actually shows.