Supply Chain Due Diligence

In today’s global markets, businesses are expected to demonstrate more than operational efficiency they must also show transparency, traceability, and integrity across their supply chains.

Regulators, investors, and commercial partners increasingly require clear evidence that materials are ethically sourced, legally compliant, and unconnected to conflict, corruption, or human rights abuse.

At AKW Consultants, we help organisations design and implement OECD-aligned due diligence frameworks that strengthen supply chain governance and stand up to regulatory and stakeholder scrutiny. From policy design and risk mapping to supplier due diligence and reporting controls, we help businesses protect their reputation, meet UAE and international expectations, and build more resilient, responsible sourcing operations.

Challenges

Supply Chain Risks We Solve

Informal or Undisclosed Mining Sources

Sourcing from artisanal mines, informal operators, or Conflict-Affected and High-Risk Areas (CAHRAs) without proper verification can expose businesses to serious risks, including conflict financing, human rights abuses, and regulatory scrutiny.

Complex Transit and Trade Routes

Minerals and precious metals often move through multiple jurisdictions before reaching the end buyer. Where transport routes, customs documentation, and supplier disclosures are unclear or inconsistent, businesses face heightened risks of non-compliance, source contamination, and traceability failure.

Broken Chain of Custody

Gaps in shipment records, weight reconciliation, supplier declarations, or transaction documentation can weaken traceability and compromise the integrity of the supply chain. These failures often create challenges during certification reviews, audits, and due diligence assessments.

Weak Red-Flag Escalation Processes

Without a clear process for identifying, documenting, and escalating red flags, suspicious supplier behaviour can be missed or poorly managed. This increases exposure to regulatory breaches, audit findings, and reputational damage.

Limited Site-Level Verification

Policies and desktop reviews alone are rarely enough in high-risk supply chains. Where site visits, field-based assessments, and on-the-ground due diligence are missing, organisations may struggle to evidence compliance during inspections, independent audits, or stakeholder reviews.

How We Help

Our Supply Chain Due Diligence Solutions

Compliance Frameworks & Governance

We help organisations build supply chain due diligence frameworks that align with OECD guidance, UAE Due Diligence Regulations, and relevant industry rules. This includes developing sourcing policies, supplier onboarding procedures, Codes of Conduct, and internal escalation protocols, while also helping define oversight responsibilities and strengthen governance across compliance and procurement functions.

Risk Assessment & Mitigation

We identify and assess sourcing risks across supply chains, including exposure to CAHRAs, intermediaries, and high-risk transit routes. Our support includes enhanced due diligence reviews, site-level verification, chain-of-custody checks, and practical risk mitigation strategies ranging from corrective action planning to supplier disengagement where necessary.

Audit Readiness & Certification Support

We prepare businesses for external assurance reviews, regulatory inspections, and industry certification audits, including LBMA, RJC, and UAE Good Delivery requirements. Through gap assessments, mock audits, documentation reviews, and report preparation, we help ensure your due diligence programme is structured, defensible, and audit-ready.

Capacity Building & Training

We deliver tailored training for procurement teams, compliance functions, senior management, and operational staff to strengthen understanding of responsible sourcing obligations and due diligence requirements. Our programmes cover OECD-based due diligence, red-flag identification, documentation integrity, and interview readiness for regulators, auditors, and certification bodies.

Frequently Asked Questions

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The OECD due diligence framework follows five core steps: establishing strong management systems, identifying and assessing supply chain risks, designing and implementing risk mitigation measures, undergoing independent third-party audits where required, and publicly reporting on due diligence efforts. Together, these steps help businesses build a structured and defensible responsible sourcing programme.

The EBC Rules for Risk-Based Due Diligence in the Gold Supply Chain apply to UAE Good Delivery Accredited Member refiners and are aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs). These rules require refiners to adopt a risk-based approach to sourcing, supply chain monitoring, and ongoing due diligence.

Yes. We provide end-to-end audit readiness support for LBMA, RJC, UAE Good Delivery, and other responsible sourcing reviews. Our support includes gap assessments, policy and documentation review, mock audits, remediation planning, and staff preparation for auditor interviews.

Supply chain due diligence records must be retained in line with applicable UAE regulatory requirements and relevant industry standards. This typically includes sourcing records, supplier due diligence files, transaction documents, audit evidence, and internal risk assessments, all maintained in a way that supports inspection, audit, and traceability requirements.

Failure to implement adequate supply chain due diligence measures can result in significant regulatory, commercial, and reputational consequences. Depending on the nature of the breach, businesses may face financial penalties, adverse audit findings, licence-related action, loss of accreditation, or restrictions on market access.