Ethical Cobalt Sourcing: A Due Diligence Checklist for UK Manufacturers

Cobalt sits in more of what UK manufacturers make and buy than most people expect: cutting tools, superalloys, magnets, catalysts, pigments, and the lithium-ion cells inside everything from power tools to forklifts. It also sits at the centre of one of the harder conversations in the metals trade, because the large majority of the world's mined cobalt comes from the Democratic Republic of the Congo, where industrial mining and artisanal workings often overlap.

None of that makes cobalt sourcing automatically unacceptable. It does mean that "we asked our supplier and they said it was fine" no longer holds up — not in a customer audit, not in a lender's questionnaire, and not in front of a regulator. What follows is a working checklist you can adapt to your own purchasing structure.

Start with a map of your own exposure

Most manufacturers never buy cobalt. They buy parts, consumables and materials that contain it, which makes the first job an internal one.

• Pull bills of materials for your top products by value and by volume.
• Ask engineering which alloys, tooling, magnets, coatings and electronics could contain cobalt.
• Include the unglamorous items: grinding wheels, drill bits, catalysts, pigments, battery packs, certain solders and surface treatments.
• Note whether each supplier is direct, or arrives through a distributor or contract manufacturer.

The output should be a single page: part, supplier, tier, and the reason you think cobalt is present. Keep it live and review it twice a year.

Don't forget your own operations

Forklift and materials-handling batteries, service parts, workshop tooling and calibration equipment all count. If you maintain a fleet or run a repair arm, cobalt is in your building even when it never appears on a purchase order.

Push the chain to refinery level

Refiners are the pinch point. There are relatively few of them, and where feedstock is blended they are often the last place in the chain where origin can be established with any confidence. Naming the refinery behind your material is the single most useful piece of information you can ask for.

Ask your Tier 1 suppliers to pass the request upstream. Expect some resistance, and be specific about what you need:

• The refinery's name, country and ownership.
• Whether it appears on the Responsible Minerals Assurance Process (RMAP) list of conformant cobalt refiners, or is audited against the Cobalt Refiner Supply Chain Due Diligence Standard.
• Feedstock origin: mine-level, country-level, or unknown.
• Whether artisanal and small-scale mining material is accepted, and under what formalisation or monitoring arrangement.

"We buy from a reputable trader" is not an answer. Neither is a certificate covering a different site from the one that handled your material.

Use the frameworks that already exist

You do not need to invent a methodology. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas sets out a five-step approach — strong company management systems, identify and assess risks, respond to identified risks, arrange independent third-party audits, and report publicly — and its Annex II risks cover child labour, forced labour, bribery, money laundering and security-related abuses. The Cobalt Institute's framework builds on that specifically for cobalt.

Alongside those, consider your reporting duties. The Modern Slavery Act statement threshold applies to larger organisations, and the EU Battery Regulation introduces phased due diligence obligations for batteries placed on the EU market. Rules and commencement dates move, so check current government guidance rather than relying on last year's summary.

Treat any certification as a floor, not a ceiling. It tells you a process exists. It does not tell you the process caught everything.

A due diligence checklist to work through

1. Ownership. Name a person or team responsible for cobalt due diligence, and give them authority to escalate.
2. Policy. Circulate a supplier code stating your expectations on labour, environment, bribery and traceability.
3. Mapping. Maintain a register of products, suppliers and known or suspected refineries.
4. Risk assessment. Rank suppliers by country risk, commodity, spend and how much they disclose.
5. Evidence. Collect audit reports, refinery disclosures and grievance logs — then read them rather than filing them.
6. Contract terms. Require disclosure of refinery and origin, audit rights, and notification of material changes.
7. Grievance route. Make sure workers and communities can raise concerns, and that you see the themes.
8. Corrective action. Set out what happens when a supplier falls short, with timescales and consequences.
9. Records. Keep dated evidence of what you asked, what you received and what you did. Review annually at minimum.

Red flags worth acting on

Some signals justify a formal response rather than another email.

• A refinery that stays unnamed after two written requests.
• Origin that changes without explanation, or paperwork that contradicts itself.
• Volumes that do not stack up — a mid-tier supplier handling more cobalt than its feedstock could contain.
• Artisanal material with no formalisation, no traceability and no evidence of safe working conditions.
• Cash-based payment chains and prices well below market.
• No grievance mechanism, and no record of a concern ever being raised.

Turning findings into contracts and action

Put disclosure obligations in the purchase agreement, not in a side letter. Specify what must be reported, how often, and to whom. Where a supplier is willing but struggling, corrective action usually beats walking away — disengagement can push a problem into a less transparent corner. Where a supplier refuses to engage at all, escalation and, eventually, replacement is the honest answer.

These are legal and commercial decisions as much as ethical ones. Take advice from a qualified lawyer on contract terms, and on which reporting obligations apply to your business.

Practical next steps

Over the next ninety days: appoint an owner, complete the one-page exposure register, and send a short information request to your twenty highest-risk suppliers asking for refinery names and origin. Diarise a review, and take the findings to whoever signs off purchasing strategy.

Then keep going. Ethical cobalt sourcing is not a project with an end date; it is a habit of asking better questions, more often, and writing down the answers.

Photo: ArtHouse Studio / Pexels