When a company operates in or sources from a conflict-affected area, it enters a landscape that most corporate responsibility frameworks were not designed to navigate. The obligations are real and they are multiplying. CS3D, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, sector-specific instruments covering extractives, agriculture and financial services. Together, they create a substantial body of expectation around how companies should conduct themselves in environments where governance is fragile and harm is close to the surface.
The challenge is that none of these frameworks was built with the specific realities of Eastern DRC, the Sahel or Central Africa’s mining corridors in mind. They assume a baseline of state functionality, a regulatory authority that sets minimum standards, enforces them and provides a framework within which responsible business conduct can be assessed. In conflict-affected areas, that baseline frequently does not exist. The state is absent, compromised or itself a party to the dynamics that create harm.
This matters because due diligence frameworks that assume a functioning regulatory environment produce assessments that do not work where they are needed most. A supplier audit conducted against national labor law standards means little in a jurisdiction where those standards are not enforced. A human rights assessment that relies on worker interviews conducted in the presence of management is not a reliable picture of conditions where coercion is a real possibility. A sourcing relationship assessed against publicly available ownership information tells you nothing about whether revenue from that relationship is funding armed group activity that the ownership structure was designed to conceal.
Responsible conduct in conflict-affected areas requires a more specific set of questions. Which armed groups are present in the sourcing region and how do they interact with commercial activity? Is the workforce genuinely free or are there indicators of coercion, debt bondage or forced displacement? Does the revenue generated by a sourcing or operational relationship contribute, directly or indirectly, to activity that causes harm to communities? These questions cannot be answered through a desktop assessment. They require people on the ground with the contextual knowledge, local relationships and investigative capability to find answers that are not in any filing or database.
The companies that manage this well are not necessarily the ones with the most comprehensive compliance policies. They are the ones that understand the specific environment they are operating in, invest in the intelligence required to assess it accurately, and build their corporate responsibility approach around what is actually happening on the ground rather than what their frameworks assume to be true.
In conflict-affected areas across Africa, the gap between those two things is where the most significant harm occurs and where the most significant corporate responsibility failures originate.