ESG & Responsible Sourcing Alignment
Connecting due diligence to disclosure
Minerals due diligence feeds directly into your broader ESG posture. Investors, customers, and regulators increasingly expect companies to demonstrate that their supply chain programs produce measurable outcomes that map to recognized ESG reporting frameworks. The 3TGs bridges the gap between operational data and stakeholder disclosure.
ESG Engagement at a Glance
Across client engagements, The 3TGs has deployed a structured ESG Direct Engagement catalog spanning 13 modular supplier surveys across Environmental, Social, and Governance pillars. These metrics reflect the operational reach of that work.
What You Receive
Every engagement is scoped to your program maturity, reporting obligations, and stakeholder requirements. Outputs are audit-ready and designed to connect operational due diligence data to the disclosures that matter to investors, customers, and regulators.
ESG Program Design Aligned to the OECD Five Steps
Structured due diligence program architecture following the OECD five-step framework - from risk management policy through annual reporting - ensuring your program produces disclosure-ready outputs from the outset rather than as an afterthought.
GRI, SASB, and CSRD/ESRS Indicator Mapping
Systematic mapping of your program outputs to the specific indicators required by GRI Standards (including GRI 308 and GRI 414), SASB sector supplements, and the EU Corporate Sustainability Reporting Directive supply chain obligations - identifying what already exists, what is missing, and what needs to be collected.
ESG Direct Engagement via 13 Modular Supplier Surveys
Structured supplier outreach across Environmental (Climate Impact, Pollution, Resource Use, Biodiversity, Product Stewardship, Buyer-Specific Data), Social (Human Trafficking and Slavery, Labor Rights, Human Rights), and Governance pillars - each delivered as a standalone survey with conditional logic and response tracking.
Smelter and Refiner Risk Assessment
Assessment of identified smelters and refiners against conflict-affected and high-risk area (CAHRA) designations, OFAC and EU sanctions lists, and RMAP conformance status - with a structured risk narrative suitable for ESG disclosure and investor review.
Responsible Minerals Sourcing Policy Development
Drafting and publication support for a formal responsible minerals sourcing policy aligned to OECD guidance - suitable for external publication on your website, in your sustainability report, or in response to customer requests and investor questionnaires.
Customer Sustainability Questionnaire Response Support
Preparation of specific, evidence-based responses to GRI-, SASB-, and CDP-aligned questionnaires and customer-specific sustainability scorecards using your actual program data - replacing generic language with verifiable program evidence that scores well under customer ESG supplier assessments.
Year-Over-Year Performance Tracking
Structured tracking of program metrics covering supplier response rates, smelter conformance levels, risk flags raised and resolved, and engagement coverage year over year - producing the trend data that OECD guidance and ESG disclosure frameworks both require.
Board-Ready Summary Reports
Executive-level summary reports that translate due diligence program results into the language of ESG commitments - formatted for board reporting, investor questionnaires, and annual sustainability disclosure packages, with a clear narrative connecting operational data to stakeholder expectations.
Who It Applies To
Companies that face ESG reporting requirements from investors, customers, or regulators - and that operate minerals due diligence programs generating data that can support ESG disclosures - are the primary audience for this service.
The challenge is almost always structural. Operational due diligence is running, data is being collected, but none of it flows into the sustainability disclosures that external stakeholders are requesting. These two workstreams exist in separate parts of the organization and never connect. This service closes that gap.
Particular relevance applies to companies responding to GRI, SASB, CDP, or customer-specific sustainability questionnaires, and to those preparing for CSRD/ESRS obligations that require documented supply chain due diligence aligned to the OECD framework.
- Electronics and technology manufacturers with conflict minerals reporting obligations
- Industrial suppliers responding to customer ESG scorecards and questionnaires
- Publicly listed companies facing investor ESG disclosure expectations
- Companies entering EU markets with CSRD/ESRS supply chain requirements
- Businesses with CDP or GRI reporting commitments seeking to use due diligence data
- Organizations publishing annual sustainability or corporate responsibility reports
Key Requirements
ESG and responsible sourcing compliance sits at the intersection of voluntary framework alignment and increasingly mandatory disclosure obligations. These are the core requirements your program must be designed to satisfy.
OECD Five-Step Framework Alignment
Design your due diligence program around the OECD five-step framework - establishing a management system, identifying and assessing risk, designing a risk response, conducting audits of smelters and refiners, and publishing an annual report - to meet the baseline expected by regulators and investors across GRI, CSRD/ESRS, and SASB frameworks.
ESG Framework Indicator Mapping
Map program outputs to the specific indicators required by GRI Standards (particularly GRI 308 on supplier environmental assessment and GRI 414 on supplier social assessment), SASB sector supplements, and CDP's supply chain questionnaire - ensuring every data point collected has a corresponding disclosure destination.
CAHRA Risk Assessment
Assess each identified smelter and refiner against CAHRA designations - conflict-affected and high-risk areas as defined by the OECD - alongside OFAC and EU sanctions lists and RMAP conformance status. Document the risk basis for each sourcing decision in a format suitable for external disclosure.
Responsible Minerals Sourcing Policy
Develop and publish a formal responsible minerals sourcing policy aligned to OECD guidance. A published policy is expected by CSRD/ESRS, GRI, and most customer sustainability scorecards, and serves as the foundational governance document of any credible due diligence program.
Customer Sustainability Questionnaire Response
Respond to customer sustainability questionnaires using verifiable program data rather than generic language. Customers operating their own ESG programs increasingly score suppliers on the specificity and evidence basis of their responses - generic answers are now a competitive disadvantage in procurement decisions.
Annual Performance Reporting
Track and report on program performance metrics year over year - including supplier response rates, smelter conformance levels, and risk reduction progress - to demonstrate continuous improvement as explicitly required by OECD guidance and expected by every major ESG disclosure framework.
Where Programs Break Down
The most common reason ESG programs fail to satisfy investor and customer scrutiny is not absence of effort - it is structural disconnects between operational due diligence work and external disclosure. These are the six gaps The 3TGs is built to close.
Program-to-Disclosure Disconnect
Companies run active due diligence programs but never connect the outputs to ESG disclosures. Investors and customers see a sustainability report with no operational evidence behind it, and the program's value is invisible to the stakeholders it exists to satisfy.
Siloed Workstreams
Minerals due diligence and ESG reporting operate as separate workstreams with no data sharing. The compliance team collects CMRT data; the sustainability team writes the annual report. Neither team has visibility into what the other is producing, and the same suppliers are often engaged twice on overlapping topics with no unified output.
Missing Performance Metrics
Programs exist but track nothing over time. Without year-over-year data on supplier response rates, smelter conformance, and risk flag closure, companies cannot demonstrate the trajectory of improvement that investors, regulators, and OECD guidance explicitly require - rendering even well-run programs indefensible under scrutiny.
No Published Policy
Companies operate responsible sourcing programs without a published responsible minerals sourcing policy. A policy is the foundational governance document expected by CSRD/ESRS, GRI, and most customer scorecards. Its absence signals to assessors that the program lacks governance structure, regardless of what operational activity is actually occurring.
Generic Questionnaire Responses
Customer sustainability questionnaires are answered with boilerplate language that makes no reference to program data. As customers apply increasingly sophisticated scoring to supplier ESG responses, generic answers that lack specifics or evidence have become a direct competitive disadvantage in procurement and supplier qualification decisions.
OECD Framework Misalignment
Program structures that do not follow the OECD five-step framework cannot be credibly mapped to GRI 308, GRI 414, CSRD/ESRS supply chain requirements, or SASB sector standards. Without the OECD backbone, even well-intentioned due diligence programs fail the structural tests that ESG disclosure frameworks apply when verifying supply chain claims.
How The 3TGs Helps
Practical, program-level support that connects operational due diligence work to the ESG disclosures stakeholders are requesting - without rebuilding what is already working and without the overhead of a large consulting firm.
OECD Five-Step Program Design
Structuring your due diligence program around the OECD five-step framework from the outset, or retrofitting an existing program to align with OECD requirements - ensuring outputs are disclosure-ready and the program structure can withstand independent verification by auditors, investors, and customers.
GRI, SASB, and CSRD/ESRS Indicator Mapping
Systematic mapping of what your program already produces to the specific data points required by GRI 308, GRI 414, SASB sector supplements, and the EU Corporate Sustainability Reporting Directive supply chain indicators - identifying what exists, what is missing, and what needs to be collected.
13-Survey ESG Direct Engagement Catalog
Deploying a structured supplier engagement catalog spanning 13 modular surveys across three pillars: Environmental (Climate Impact, Pollution, Resource Use, Biodiversity, Product Stewardship, Buyer-Specific Data), Social (Human Trafficking and Slavery, Labor Rights, Human Rights), and Governance - with response tracking and gap analysis built in to every survey.
Smelter and Refiner Risk Assessment
Conducting structured risk assessments of identified smelters and refiners against CAHRA designations, OFAC and EU sanctions lists, and RMAP conformance status - producing documented risk narratives suitable for ESG disclosure, investor review, and customer due diligence requirements.
Responsible Minerals Sourcing Policy Development
Drafting a formal responsible minerals sourcing policy aligned to OECD guidance, written for external publication and structured to satisfy the policy requirements of GRI, CSRD/ESRS, and customer sustainability scorecards - delivered as a finalized, publication-ready document.
Customer Questionnaire Response Preparation
Preparing specific, evidence-based responses to GRI-, SASB-, and CDP-aligned sustainability questionnaires using your actual program data - replacing generic boilerplate with verifiable program evidence that scores well under the increasingly detailed scoring rubrics that large customers now apply to supplier ESG assessments.
Year-Over-Year Performance Tracking
Building and maintaining a structured performance tracking system covering supplier response rates, smelter conformance levels, risk flags raised and resolved, and engagement coverage year over year - producing the trend data that both OECD guidance and ESG disclosure frameworks require for credible continuous improvement claims.
Board-Ready Summary Reports
Producing executive-level summary reports that translate due diligence program results into the language of ESG commitments - formatted for board reporting, investor questionnaires, and annual sustainability disclosure packages, with a clear narrative that connects operational data to the commitments your organization has made publicly.
Bridge the Gap Between Due Diligence and Disclosure
If your due diligence program is generating data that is not flowing into your ESG disclosures, that is a structural problem - not a reporting one. The 3TGs helps you connect the two with practical, fixed-fee engagements scoped to your actual obligations.
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