Supply chain traceability and transparency are essential pillars of effective human rights due diligence, particularly where supply chains span contexts posing heightened risks of forced labour, like those of electronics.

The 2025 KnowTheChain ICT benchmark revealed traceability and supply chain transparency as a crucial gap in many ICT companies' approach to addressing forced labour risks. This deep dive analyses key examples of practice and provides recommendations for companies to improve their supply chain traceability and transparency.

ICT supply chains are highly interconnected, which means that companies may be exposed to labour rights risks and impacts through their direct and indirect sourcing relationships. A company’s unwillingness or inability to map and publicly disclose first-tier and below suppliers, and the countries from which it sources, means that stakeholders cannot be satisfied it is identifying and addressing forced labour risks in its supply chains. It also raises questions about a company’s ability to be held accountable to abuse where it occurs.

Yet this core pillar is largely absent from benchmarked companies’ due diligence processes, with more than a quarter of benchmarked companies (27%) scoring zero on their efforts to trace and disclose their supply chains.

Findings

Only four companies (9%) (Apple, Intel, LG Electronics, and Samsung) disclosed the names and addresses of SORs for critical minerals other than those of 3TG, suggesting that due diligence on mineral supply chains is limited to compliance with legislation only, leaving workers and communities unprotected from adverse impacts in other contexts. Better practice comes from Samsung which disclosed cobalt, lithium, mica, copper, nickel, aluminium and silver SORs.

Cobalt ore mined in the Democratic Republic of the Congo (DRC) and nickel mined in Indonesia have recently been added to the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labour and ICT inputs like aluminium continue to generate reports of links to forced labour. As complex production processes underpin the creation of electronics goods, companies cannot justify restricting their traceability efforts to a single supply chain and production context. A more robust approach to due diligence is especially important as companies transition to renewable energy technologies which drives greater demand for the extraction of transition minerals which the Business and Human Rights Resource Centre’s (BHRRC) Transition Minerals Tracker (TMT) has linked to 630 human rights allegations between 2010-2023.

The limitations of conflict minerals reports

Conflict mineral reports assessed by KnowTheChain found companies could not confirm which of the SORs listed in their reports were active suppliers, with the tracing process heavily reliant on supplier self-reporting through the RMI’s Conflict Minerals Reporting Template (CMRT). Only two companies (4%), LG Electronics and Nokia, took steps to identify below-first tier suppliers by tracing parts or components. This points to systematic and sector-wide issues in companies’ traceability practices where companies cannot be certain they are not causing or contributing to human rights abuses.

In December 2024, lawyers for the DRC Government announced filing criminal complaints against French and Belgian subsidiaries of Apple for allegedly sourcing conflict minerals “from the DRC and laundered through international supply chains” and for allegedly using “deceptive commercial practices to assure consumers that the tech giant’s supply chains are clean”.* Legal action such as this, coupled with a growing body of literature from organisations like the US Government Accountability Office (GAO), which has highlighted serious, ongoing and systemic deficiencies in conflict minerals reporting noting that an estimated 62% of companies were unable to identify the origin of 3TG minerals in their supply chains in 2023, should serve as a wakeup call for companies to go beyond regulatory minimums. When presented with allegations related to 3TG sourcing and forced labour no company demonstrated an impetus to go beyond current practice.

Allegations and the outsourcing of due diligence

Poor traceability is particularly concerning given the stark increase in the number of forced labour allegations identified by KnowTheChain in 2025. The benchmark includes 42 public allegations, identified in a systematic search of media and civil society sources, identified against 36 companies, with some companies linked to multiple allegations. All but six allegations, linked to the supply chains of five benchmarked companies, related to sourcing either directly or indirectly from facilities reportedly using Uyghur forced labour.

KnowTheChain identified 29 companies (64%) alleged to have sourced gold from either one or several below-first-tier suppliers who had businesses in China’s Xinjiang Uyghur Autonomous Region (XUAR). These suppliers: Zijin Mining, Shandong Gold, Zhaojin Gold and Lingbao Gold, are alleged to own and operate gold mines and refineries in XUAR and reportedly receive labour transfers of Uyghur workers. Only five companies (Advanced Micro Devices, Corning, Microchip Technology, NXP Semiconductors and Qualcomm) responded to the allegations.

All companies, with the exception of Corning, acknowledged sourcing from the suppliers and many cited the suppliers “conformant” statuses with the Responsible Minerals Initiative (RMI) or the London Bullion Market Association (LBMA) as grounds for continued sourcing.

Of the five companies that responded to the allegation by submitting additional disclosure to KnowTheChain, none scored under KnowTheChain’s assessment criteria in relation to how they were addressing and remediating the allegation. Only one company (Microchip Technology) disclosed taking steps to remove the identified suppliers from their supply chains. At the time of writing, it is not clear whether they have been removed.

The over-reliance of companies on industry initiatives and trade associations in responding to the allegations highlights another alarming gap in companies’ due diligence. Several allegations of misconduct have been made against the industry initiatives and trade associations cited by these companies, which undermine those organisations’ claims to objectivity when auditing and certifying 3TG suppliers.

The LBMA is facing legal action by the British law firm Leigh Day, who allege the LBMA continued to certify gold from an artisanal mine in Tanzania as compliant with its Responsible Sourcing Program, placing it on the organisation’s “Good Delivery List”, despite the deaths of several miners and the mine allegedly “being associated with a widely reported pattern of systemic human rights abuses over many years”.

Similarly, in 2022 the NGO Global Witness alleged uncovering evidence of International Tin Supply Chain Initiative (ITSCI) employees participating in the smuggling of conflict minerals from the DRC to Rwanda after conducting field research in 10 mining areas of the DRC’s North and South Kivu provinces. In 2024, lawyers for the DRC Government repeated this allegation in commencing legal action against subsidiaries of Apple. The RMI is also alleged by lawyers for the DRC Government to use data from the ITSCI’s tracking processes in the DRC for its RMAP database of conformant smelters in the Great Lakes Region despite suspending recognition of the ITSCI in 2022.

These allegations should serve as a stark reminder to companies that they cannot outsource their duties under the UNGPs to prevent, mitigate or remediate human rights abuses in their supply chains. They also undermine the potential of industry initiatives to support collaboration among companies in conducting due diligence and to collectively address human rights risks in their minerals supply chains.

KnowTheChain’s data highlights flaws in companies’ ability to know and show their supply chains, particularly in relation to high-risk minerals sourcing, where forced labour and egregious human rights abuse are highly prevalent. Compounding issues of traceability is a persistent overreliance on audits and certification schemes. Companies have a duty to exercise effective oversight of their supply chains and to start effectively implementing the principles of traceability and supply chain transparency. Recommendations for company action on traceability and transparency over supply chains are outlined below.

Recommended company action

Traceability

To enhance their supply chain traceability as a means to identify and assess adverse impacts in supply chains, companies are encouraged to:

1. Undertake due diligence in line with the OECD Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and disclose steps taken to identify and manage risks. Map and disclose supply chains across all significant and high-risk raw materials and disclose how they define raw materials as high-risk.
2. Do not rely solely on audits and certification schemes as part of traceability and due diligence efforts. Directly involve and work with workers, independent trade unions, worker organisations and expert civil society organisations to reduce the overreliance on audits and certifications by embedding worker-driven monitoring across supply chains to identify salient issues.
3. Use component level tracing to identify and publicly disclose the countries of origin of raw materials at high risk of forced labour, conflict financing and heightened human rights abuses.

Transparency

To enhance the transparency of their supply chains, companies are encouraged to:

1. Disclose a list of first and second-tier suppliers including supplier names, addresses and products supplied.
2. Disclose supply chains, including below-first-tier suppliers, across all high-risk raw materials, beyond that which is required by law.
3. Disclose the sourcing countries of raw materials at high-risk of forced labour, conflict financing and heightened human rights abuses.
4. In alignment with the UNGPs and advice from the Office of the United Nations High Commissioner for Human Rights (OHCHR), disclose criteria for responsibly terminating business relationships with suppliers linked to allegations or heightened risks of forced labour, conflict financing and other human rights abuses where there is insufficient leverage to prevent or mitigate such risks.

Leverage stakeholders and peers to drive collaboration on traceability and transparency:

1. Work directly with first and second-tier suppliers to respond to identified forced labour risks and build suppliers’ capacities to cascade supply chain policies; this should include regular beyond first-tier monitoring to assess improvements.
2. Engage with business associations, such as RMI and LBMA, to improve collective tools to identify, assess and monitor supply chain risks.

*The Paris Public Prosecutor’s Office dismissed the claim against on Apple on the 18 February 2025. Lawyers for the DRC have announced they will appeal the decision at the Paris Court of Appeal.