Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
In recent years, international attention has focused on the responsibility of major corporations regarding the origin of materials used in their products and how they manage their supply chains.
The cases of Apple and John Deere stand out in this context, particularly in relation to the use of minerals extracted from conflict zones, such as the Democratic Republic of the Congo (DRC). These cases demonstrate that corporate social responsibility does not end at the parent company, but extends to every link in the chain, including all types of suppliers.
Apple and “blood minerals”
Apple, the technology giant, has faced accusations related to the acquisition of minerals from regions affected by armed conflicts. In December 2024, the DRC filed criminal complaints in France and Belgium against Apple subsidiaries, alleging that the company used minerals illegally extracted in the eastern part of the country and “laundered” through global supply chains. These complaints maintain that Apple would be complicit in crimes committed by armed groups controlling some of the mines in the region.
Apple has denied these accusations, stating that it conducts thorough audits of its suppliers and is committed to responsible mineral sourcing. However, critics argue that certification mechanisms may be insufficient and that minerals from conflict zones can infiltrate the global supply chain under false pretenses.
John Deere and its conflict minerals policy
John Deere, a global leader in the manufacture of agricultural and construction machinery, has also addressed the issue of conflict minerals. In 2017, it acquired the German group Wirtgen for $5.1 billion. However, it did not adequately integrate Wirtgen into its compliance program, and it was later discovered that Wirtgen Thailand paid bribes to officials of the Royal Thai Air Force, the Department of Highways, and the Department of Rural Roads to secure contracts, resulting in severe financial penalties for John Deere.
In response to all of the above, John Deere established a global conflict minerals policy, in which it committed to:
• Exercise due diligence in its supply chain to identify the presence of conflict minerals.
• Require its suppliers to implement reasonable policies and measures to ensure that the minerals used do not finance or benefit armed groups in the DRC or adjacent countries.
• Support international initiatives aimed at increasing transparency and traceability in the mineral supply chain.
This policy reflects John Deere’s commitment to corporate social responsibility and its effort to avoid contributing, directly or indirectly, to armed conflicts through its business operations.
What conclusion can be drawn from these problematic cases?
The cases of Apple and John Deere underscore the complexity and challenges associated with ethical supply chain management. It is evident that periodic controls and assessments are not enough; it is essential that companies implement robust compliance systems that ensure:
• Transparency: knowing the exact origin of the resources used and their transfer routes.
• Accountability: ensuring that no link in the supply chain contributes to human rights violations or finances armed conflicts.
• Collaboration: working together with suppliers, non-governmental organizations, and international bodies to promote ethical and sustainable sourcing practices.
Ultimately, traceability and transparency in the supply chain have become indispensable requirements to avoid breaches in a supplier’s compliance system, which can impact the reputation and operations of a multinational corporation.
Therefore, having tools that enable companies to generate clear internal policies, train employees, monitor in real time and report on their supply chains, identify potential risks, and take corrective measures in a timely manner is essential.
Only through genuine commitment and concrete actions can we ensure that business operations contribute to sustainable development and respect for human rights in all regions of the world. At Trusty, we can help you achieve all of this. Shall we talk?
Related reading: EUDR Compliance for SMEs: Keep Your Direct Supplier Relationships and DORA Third-Party Risk Management: How Financial Entities and ICT Providers Share the Compliance Burden.
Frequently asked questions
In December 2024 the Democratic Republic of the Congo filed criminal complaints in France and Belgium against Apple subsidiaries, alleging the use of minerals illegally extracted in the eastern part of the country and laundered through global supply chains. Apple denies the accusations and says it audits its suppliers thoroughly.
John Deere acquired the German group Wirtgen in 2017 for 5.1 billion dollars but did not adequately integrate it into its compliance program. Wirtgen Thailand was later found to have paid bribes to Thai officials to secure contracts, which resulted in severe financial penalties for John Deere.
Due diligence in its supply chain to identify conflict minerals, a requirement that suppliers ensure the minerals used do not finance or benefit armed groups in the DRC or adjacent countries, and support for international initiatives that increase transparency and traceability in the mineral supply chain.
Periodic controls are not enough. Companies need transparency about the origin and routes of the resources they use, accountability so that no link in the chain contributes to human rights violations, and collaboration with suppliers, non-governmental organizations and international bodies.
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