Beyond Borders: Why Sub-National CAHRA Identification Is Now a Commercial Imperative for Mining Companies

The identification of conflict-affected and high-risk areas (CAHRAs) is a core component of responsible mineral sourcing. Since the OECD first codified the concept in its Due Diligence Guidance in 2011, a growing body of legislation, industry standards and investor expectations has prioritised the question of where minerals are mined, and under what conditions.

For most mining companies, the tools used to answer that question have not kept pace with the expectations placed on them. Country-level risk scores remain the dominant currency of CAHRA screening, despite the fundamental mismatch between the unit of analysis (a sovereign state) and the unit of concern (a mine site, a processing facility, a transport corridor).

Consider a country like the Democratic Republic of Congo (DRC), simultaneously one of the world's most important sources of cobalt and one of its most complex conflict environments. A single national risk score does almost nothing to differentiate a mine located in a stable, well-governed concession from one operating in an area where armed groups, illegal taxation, and human rights violations are documented realities in the vicinity. The DRC example illustrates the limitations of a one-dimensional national risk score and the opportunity for expanding the CAHRA framework to further operationalise the full range of OECD guidance.

What the OECD Guidance Requires

Before further examining the limitations of current practice, it is worth revisiting what the OECD Due Diligence Guidance says. The definition of a CAHRA is deliberately broad:

Three important considerations need to be highlighted in this OECD definition:

• It is explicitly not limited to active armed conflict. The concept of a "high-risk area" encompasses governance failure, institutional weakness, and human rights violations, conditions that may persist in regions of a country entirely separate from any active conflict zone.
• The OECD Guidance applies to all minerals and is global in scope, not just the typical 3TGs (Tin, Tungsten, Tantalum & Gold) covered by definitions such as the US Dodd-Frank Act, or the DRC-adjacent geography that preoccupied early responsible sourcing frameworks.
• Most critically, the definition refers to areas, not countries. The geographic unit is inherently sub-national.

In the last few years, the regulatory environment has been recognising these limitations. The EU's Corporate Sustainability Due Diligence Directive (CSDDD), the proposed EU Critical Raw Materials Act, and evolving guidance from the London Metal Exchange, the Responsible Minerals Initiative, and national implementing legislation across Europe are all pushing companies toward more granular, evidence-based assessments.

A country-level heat map, however well-constructed, is increasingly unlikely to satisfy a regulator, an investor, or a downstream buyer asking whether a specific mine site is, or is not, located in a CAHRA.

The three pillars of a robust CAHRA assessment

A credible CAHRA framework needs to operationalise the OECD definition across its full range. At Aseri, we structure our CAHRA tool around three analytical pillars, each reflecting a distinct dimension of risk identified in the OECD Guidance.

1. CONFLICT
   • Armed conflict, insurgency, inter-communal violence, presence of non-state armed groups, and documented incidents of conflict-related harm.
2. GOVERNANCE
   • State capacity, rule of law, corruption, institutional effectiveness, and the presence of illegal or unregulated extraction activity.
3. HUMAN RIGHTS
   • Documented abuses, forced labour, child labour, land rights violations, and suppression of civil society and community voice.

What distinguishes an effective CAHRA tool from a rudimentary one is the interaction between these pillars.

In our collective experience, the most consequential risks for mining companies rarely sit within a single dimension. A mine operating in an area with low direct conflict exposure may still be a clear CAHRA risk if it is in a jurisdiction characterised by entrenched governance failure or systematic human rights violations.

Conversely, a region that scores moderately on governance may require heightened scrutiny if there is documented presence of armed groups in the surrounding area, even if no active hostilities have occurred at the site itself.

This multi-pillar logic reflects the operational reality of how responsible sourcing failures occur.

Most documented cases in which mining companies have faced regulatory sanctions, reputational damage or supply chain disruption have involved governance and human rights factors rather than only proximity to active armed conflict.

Designing a CAHRA tool around conflict alone, or treating it as the primary filter, systematically underestimates risk.

Why country-level analysis fails mining companies

The limitations of country-level CAHRA assessment are well understood in theory, but their practical implications for mining companies are underappreciated.

Consider what a country-level assessment does to a mining company's decision-making in practice. If a country is classified as high-risk, every operation in that country receives the same elevated designation, regardless of whether those operations are in conflict-affected provinces or in areas with functioning governance, active civil society, and no documented human rights abuses.

The result is either systematic over-reporting, where companies flag every asset in a high-risk country as requiring enhanced due diligence, overwhelming compliance capacity or systematic under-reporting, where the category becomes so broad as to lose analytical utility.

The inverse problem is equally problematic. A country that scores at a medium risk level nationally may contain specific regions or districts that are genuine CAHRAs by any reasonable reading of the OECD definition.

Rwanda, to cite a well-documented example, presents a relatively stable picture at the national level. Yet concerns have persisted for years that minerals originating in eastern DRC are transiting through Rwandan supply chains, and specific border regions present materially elevated risks that a national score cannot capture. Any company sourcing from Rwanda without a sub-national lens is, in effect, conducting due diligence with only partial awareness.

This gap becomes commercially significant when downstream buyers, investors, or regulators request documentation of CAHRA assessment. A company that can demonstrate site-level assessment, supported by sub-national data on conflict incidents, governance indicators, and human rights conditions is in a fundamentally stronger position than one presenting a country heat map and a qualitative narrative.

The case for sub-national granularity

Sub-national CAHRA analysis is a qualitatively different exercise from national analysis, and one that requires different data architecture.

At the national level, the principal data sources are well-established: governance indices from the World Bank, Freedom House, Transparency International, and similar institutions; conflict databases such as ACLED and UCDP; human rights documentation from Amnesty International, Human Rights Watch, and UN mechanisms. These sources are valuable inputs, but they are designed to characterise countries, not sub-national areas. Their geographic granularity is, by design, limited.

Sub-national analysis requires layering additional data sources onto these foundations: geo-referenced conflict event data disaggregated to the district or municipality level; satellite-derived indicators of artisanal and small-scale mining (ASM) activity; documentary evidence of armed group presence in specific areas; community-level human rights reporting; and, where available, regulatory and permitting data that can identify whether a mine site is operating within or outside formal governance frameworks.

5 factors enabled by sub-national analysis

1. Site-level classification: a determination of whether a specific mine, processing facility, or transport route sits in a CAHRA, rather than whether the country it is located in is a CAHRA
2. Proportionate due diligence: the ability to direct enhanced scrutiny to genuinely elevated-risk operations rather than applying blanket heightened diligence to entire country portfolios
3. Regulatory defensibility: documentation of a credible, evidence-based methodology that maps directly to the OECD definition and its geographic intent
4. Supply chain transparency: the capacity to assess not just mine sites but processing hubs, smelters, and transport corridors where risks may differ materially from site-level conditions
5. Dynamic monitoring: tracking changes in sub-national risk conditions over time, enabling early identification of deteriorating situations before they become supply chain crises

It is imperative to emphasise the last point: CAHRA status is not static. Conflict dynamics evolve, governance conditions shift, and human rights situations deteriorate or improve in response to political, economic, and security developments.

A sub-national framework that is updated on a regular cadence, incorporating new conflict event data, updated governance indicators, and emerging human rights documentation, provides companies with a dynamic monitoring capability that a periodic national assessment (often limited to every 6 months) simply cannot replicate.

What the Aseri Sub-National CAHRA tool delivers

Aseri's CAHRA tool is built specifically to address the analytical gap described above. It is designed for mining and extractives companies that need to move beyond country-level screening and conduct credible, site-level CAHRA assessment across complex global supply chains.

Architecture & methodology

The tool maps a proprietary set of risk indicators across the three-pillar framework: conflict, governance, and human rights, at the sub-national level.

• Conflict pillar draws on geo-referenced incident data disaggregated to the district level, capturing active armed conflict, political violence, and documented armed group presence.
• Governance pillar incorporates indicators of state effectiveness, rule of law, corruption, and the prevalence of illegal or informal extraction.
• Human rights pillar integrates documentary evidence of abuses, community-level reporting, and indicators relevant to labour rights, land rights, and freedom of civil society.

Critically, the tool produces both a composite CAHRA classification and pillar-level scores for each assessed area. This pillar-level transparency is deliberate: it allows companies to understand not simply whether an area is classified as a CAHRA, but which dimensions of risk are driving that classification, information that is directly relevant to the design of appropriate due diligence and mitigation measures.

Speed & accessibility

One of the persistent barriers to robust CAHRA assessment in the mining sector is the cost and time associated with conducting it at the necessary level of granularity. Comprehensive sub-national assessments, if conducted through bespoke consultancy engagements, are expensive, slow, and difficult to scale across large or diversified supply chains.

The result, in practice, is that many companies conduct thorough assessments for their most scrutinised commodities or geographies and rely on less comprehensive, limited analysis elsewhere.

Aseri's tool is designed to solve that trade-off. By systematising the data infrastructure and methodology that underpins sub-national CAHRA assessment, we enable companies to generate credible, site-level outputs across their supply chain portfolios at a fraction of the cost and production time of a conventional consultancy engagement.

The Aseri tool is designed to support and structure expert analysis, keeping human judgement at the centre. It also expands access as the analytical depth previously available only to the largest and best-resourced companies is accessible to a much broader range of operators, such as small ethical jewellery brands.

How it compares

The regulatory trajectory is clear

Mining companies operating in or sourcing from complex geographies face a regulatory environment that is moving in one direction: toward greater specificity, greater documentation, and greater accountability for what happens at the site level. The days of country-level screening as a sufficient response to responsible sourcing obligations are numbered, if not already past.

The EU's CSDDD requires companies to conduct risk-based due diligence across their value chains, with an explicit focus on identifying adverse impacts. The CSDDD's implementing guidance, and the sectoral standard-setting underway in the minerals space, is increasingly pointing toward sub-national assessment as the baseline expectation.

Beyond regulation, the commercial dynamics are shifting. Downstream buyers in the automotive, battery, and electronics sectors are conducting their own supply chain due diligence and asking increasingly precise questions of their upstream suppliers. Institutional investors are incorporating CAHRA exposure into ESG assessments and engagement frameworks. Banks and insurers are factoring responsible sourcing performance into financing and coverage decisions. In this environment, the ability to demonstrate a rigorous, sub-national CAHRA methodology is important.

A note on proportionality

It is worth addressing one objection that sometimes arises in discussions of sub-national CAHRA analysis: the concern that a more granular approach will simply generate more red flags, overwhelming compliance functions and creating operational paralysis.

However, we advocate that country-level assessments, because they must be conservative to be credible, tend to generate broad designations that are difficult to act on.

A sub-national tool, by contrast, enables proportionate risk stratification: identifying the specific areas that genuinely warrant enhanced due diligence, while providing defensible grounds for a lower intensity approach in areas that do not meet the CAHRA threshold. The result is better-directed compliance effort, concentrated where it matters. Alongside this it provides clearer, more defensible audit trails for the regulators and investors asking the questions.

The UNDP's heuristic, "when in doubt, carry it out", remains a sound guide.

But the goal of a robust CAHRA framework should be to reduce the range of genuine doubt, so that maximum-intensity due diligence is reserved for the situations that truly warrant it.

That reduction in ambiguity is precisely what sub-national analysis enables.

Conclusion

CAHRA identification is the foundational step in a responsible sourcing programme, and a natural evolution in an AI- and data-rich world: it is the point at which companies determine where heightened scrutiny is warranted and where it is not. Getting that determination right, with the appropriate level of geographic granularity, is increasingly a legal obligation, a commercial necessity, and a matter of genuine ethical importance for companies operating in one of the world's most scrutinised sectors.

Aseri's CAHRA tool is designed to make that determination accessible, credible, and scalable, combining the sub-national granularity that the OECD definition demands with the speed and cost-efficiency that real-world supply chain assessment requires.

As the regulatory and commercial environment continues to sharpen its expectations of the mining sector, the question is not whether to invest in sub-national CAHRA capability, but how long companies can afford to operate without it.

We will also be developing tools to assess high-risk regions in other commodities globally and not just mining / metals. For example, we are developing a forced labour and commodity sub-national and business activity tool. Forced labour tools also often focus on high-risk countries without assessing industry and commodity risks in medium / low risk countries that can elevate substantially low or medium risk country scores. The subtle wage theft we find across the UK labour market, one of the most heavily regulated in the world, is a case in point.

The author of this post, (who also is a human rights and environmental auditor) has found deep rooted forced labour in areas where increased data and deep dives have been used to supplement ILO indicators.

This forms the basis of Aseri’s Intelligence Team. We are tired of current industry approaches to risk identification and understand the areas of improvement needed to take HREDD to the next level of genuine real risk identification and subsequent positive impact. Watch this space for more tools for HREDD.