Compliance & Responsible Sourcing

Prove your supply
chain is clean.

European regulation now requires companies to prove where their materials come from and how they were produced. We collect the evidence, verify it, and package the proof your buyers and auditors require. We do not trade the goods we verify. We gather and check the evidence your notified body, auditors and buyers will test.

IndependentAligned to OECD guidanceEnglish & FrenchFixed fees
Why This Matters

Regulation moved the burden
of proof onto the buyer.

A decade ago, a European company could buy from a supplier and take their word for it. That era has ended.

Under the EU Batteries Regulation, the EU Deforestation Regulation and, from July 2029 for the largest companies, the Corporate Sustainability Due Diligence Directive, the company placing goods on the European market carries the legal obligation to prove those goods are traceable, legally produced and free of human rights abuse. Fail, and you lose market access.

That proof cannot be assembled from a desk in Europe. It has to be gathered at source, by people who can visit the sites, speak the languages and be trusted by the communities. That is exactly where we work.

Independent by design
Field-level evidence collection
Aligned to OECD Due Diligence Guidance
Local teams, local languages
EU Batteries RegulationDue diligence from 18 Aug 2027
EU Deforestation RegulationApplies from Dec 2026
OECD Due Diligence GuidanceIn force
Conflict Minerals (3TG)In force
CSDDDJuly 2029, over 5,000 staff and €1.5bn turnover
Liability sits with the company placing goods on the EU market.
What We Do

Assurance, not extraction.

Six capabilities that turn an undocumented supply chain into a defensible compliance position.

Site Monitoring

Independent checks on conditions, safety and human rights risk at the point of production, with photographs, structured data and honest reporting.

Traceability at Source

We follow material from origin through the chain, acting as the field layer for international traceability platforms and chain-of-custody systems.

Producer Formalisation

Helping cooperatives and small-scale producers meet recognised responsible sourcing standards through registration, training and record-keeping.

Audit Readiness

Preparing producers and processors for OECD-aligned third-party audit and scheme certification, then closing the gaps we find.

Due-Diligence Dossiers

Packaging the evidence international buyers need to satisfy their legal obligations, in the format their regulators and auditors expect.

Grievance & Community Engagement

Local-language complaint and remediation systems, designed and operated as the regulation requires them to be.

Standards

Aligned to the standards
that matter.

We do not invent frameworks. We help you meet the ones your buyers, regulators and auditors already use.

OECD Due Diligence GuidanceThe global foundation every other framework builds on.
EU Batteries RegulationRegulation (EU) 2023/1542. Due diligence applies from 18 August 2027 to operators with turnover above €40m. Policies must be verified by a notified body, then audited periodically.
EU Deforestation RegulationTraceability and legality for listed commodities.
CIRAF, Copper Mark & Cobalt MarkSite-level responsible production assurance schemes.
Responsible Minerals InitiativeIndustry audit programme and reporting templates.
CSDDDFrom July 2029, companies with over 5,000 staff and €1.5bn turnover. Their suppliers will be asked for evidence well before then.
Why ICONGRP

Why buyers trust our data.

Evidence at Source

We hire in the markets we serve. Field teams work close to producers, in French and local languages, where the evidence actually is.

Independent

We do not buy, sell or trade the goods we verify. ICONGRP SARL has no cobalt trading business. We have no commercial interest in the finding, which is why our data is data you can trust.

Compliance Expertise

We understand precisely what European regulators, buyers and auditors require, and how to produce it to their standard.

Honest Reporting

Child labour and abuse are the core issue. We never overstate what we find. Accuracy is the entire product.

Where the Pressure Is Highest

Cobalt is where this regulation
bites first.

Around 70% of the world's cobalt originates in the Democratic Republic of Congo. It sits in every electric vehicle, phone and laptop battery sold in Europe.

Under the EU Batteries Regulation, any company placing batteries on the European market must prove that cobalt is responsibly sourced, traceable, and free of human rights abuse. The obligation falls on the importer. But the evidence sits with the producer, thousands of miles away, in a language they do not speak.

That gap is the whole problem. Closing it is the whole service.

The local rules matter. Since 16 October 2025, cobalt leaves the DRC under an export quota system run by ARECOMS, with a yearly cap and monthly allocations. Hand-dug cobalt can only be bought and sold through the state company EGC. A cooperative that sells outside that route is not a compliant source, however good its site conditions. We check where a cooperative sits in that system before we check anything else.

We support both sides of it: Congolese exporters who must produce the evidence, and European buyers who must hold it. ICONGRP has an established operation in Kinshasa, a small field team in Kolwezi, Lualaba province, where most monitored cobalt sites are, and a UK compliance team that knows what regulators and notified bodies will accept.

Who Needs This

Battery manufacturersObligated
EV and electronics brandsObligated
Cobalt exportersMust supply evidence
Refiners and tradersMust supply evidence
Enforced from18 August 2027
Head office in Kinshasa, field team in Kolwezi, Lualaba. We do not operate in the conflict-affected eastern provinces.

Beyond cobalt

The same model applies wherever the burden of proof outruns the available evidence. The EU Deforestation Regulation places identical obligations on timber, cocoa, coffee, rubber, soy, palm oil and cattle. The CSDDD extends the principle across the supply chains of the largest companies. As our clients' obligations widen, so does our practice.

Who We Help

Four kinds of client.

Importers & Brands

Battery makers, EV manufacturers and electronics brands placing goods on the EU market, who carry the legal obligation to prove responsible sourcing.

Producers, Exporters & Refiners

Mining companies, exporters and refiners who must supply evidence to their buyers in order to keep selling into European markets.

Cooperatives

Artisanal and small-scale producer groups formalising their operations to meet recognised responsible sourcing standards.

Assurance & Traceability Firms

International providers who need a trusted field delivery partner in the markets they cannot reach.

Who Does the Work

Named people, on the ground.

Plamedi Lukubu

Country Director, DR Congo. Leads the compliance practice in-country. Director of ICONGRP SARL, based in Kinshasa, with a background in construction and technical delivery. Completes an eight-week compliance programme with the UK team before the cobalt work begins.

Kolwezi Field Team

A small team of Congolese staff based in Kolwezi, Lualaba province, who carry out the site visits. They speak French, Swahili and local languages and are employed by ICONGRP SARL, not subcontracted.

UK Compliance Team

Based at our Milton Keynes office. Sets the method, reviews every report before it leaves, and keeps the regulatory position current. Led by Joel Mbala, Managing Director.

Reaching the sites

Kinshasa is 1,500 km from the cobalt belt, which is why the field team lives in Kolwezi rather than travelling from the capital. Sites around Kolwezi, Fungurume and Likasi are reached by road within a day.

Our Method

What a site verification
involves.

01

Desk review

Before anyone travels we check the cooperative's registration, its position in the EGC and ARECOMS system, its export records and any previous audit findings.

02

Site visits

Two visits, the second unannounced. We photograph conditions, record GPS, count and observe the workforce, check safety provision and look at how material is weighed, bagged and moved off site.

03

Interviews

Workers and community members are interviewed away from the site and away from site management, in their own language. Names are never recorded and nothing is attributed to an individual.

04

Evidence check

Every statement in the report is tied to a photograph, document or dated observation. Where accounts conflict, we say so. We never overstate what we find.

If we find child labour

We do not quietly note it and move on. The client is told the same day. The finding goes in the report as a critical issue with the evidence behind it. We do not remove children from a site ourselves, because that can push families into worse situations; we refer the case to the relevant local child protection body and record that referral. The site cannot be reported as compliant until a follow-up visit confirms the issue has been addressed and the cause dealt with. The same applies to forced labour and serious safety failures.

What You Receive

The report,
section by section.

We have not published a sample report because we have not completed a client pilot yet, and we will not invent one. This is the structure every client receives.

Summary and rating

One page: site, dates, overall finding (compliant, compliant with conditions, or not compliant) and the critical issues, if any.

Regulatory position

Registration, EGC and ARECOMS status, export route, and how the site maps to the OECD five-step framework and the Batteries Regulation requirements.

Findings with evidence

Each finding with its photographs, GPS, documents and dated observations. Interview findings summarised without identifying anyone.

Gaps and actions

What stops the site being audit-ready, what would fix it, and what we would need to see on a follow-up visit.

Data and Confidentiality

Who sees what.

Storage

Field data, photographs and reports are held on encrypted cloud storage administered from the UK under UK GDPR. Nothing stays on personal phones once a visit is uploaded.

Access

Only the field team, the UK reviewer and the client's named contacts can see a client's file. We do not share findings between clients.

NDAs

We sign a mutual NDA before any pilot and are happy to work under yours.

Interviewees

Worker and community interviews are anonymised at source. Identities are not recorded, not stored and not shared with the site, the client or anyone else.

Founding Pilot Clients

Where we are, honestly.

Our cobalt verification work starts in 2027. We do not have case studies yet and we will not pretend otherwise. We are taking on a small number of founding pilot clients who want a field partner in Lualaba in place before the Batteries Regulation due diligence date of 18 August 2027.

Scope

One site, three to four weeks.

Fee

Fixed, from £8,000 per site. Additional sites in the same area quoted at a reduced rate.

Included

Desk review, two site visits, interviews, evidence check, written report, one follow-up call.

Not included

The notified-body verification itself. We prepare you for it; we do not replace it.

How It Works

Start with one site.

A single-site pilot tells you where you stand before you commit to anything larger.

01

Talk to Us

Tell us the site or the supply line you need to stand behind. We will tell you what the regulation asks of you.

02

Pilot

Three to four weeks on one site: desk review, two site visits, worker interviews and an evidence check. Fixed fee from £8,000.

03

Deliver

We collect and verify the data, then hand you an audit-ready report or a complete due-diligence dossier.

04

Sustain

Ongoing monitoring and reporting that keeps your compliance position current as the rules move.

Questions Buyers Ask

FAQ

Are you a notified body?

No. Under the Batteries Regulation your due diligence policy must be verified by a notified body appointed by an EU member state. We prepare the evidence and the site that verifier will test.

Do you trade cobalt?

No. Neither ICONGRP nor ICONGRP SARL buys, sells or trades cobalt or any other material we verify.

How do you reach sites in Lualaba?

Our field team is based in Kolwezi. Sites in the Kolwezi, Fungurume and Likasi areas are reached by road within a day.

What if you find child labour?

The client is told the same day, the finding is recorded as critical, the case is referred to the local child protection body, and the site cannot be reported as compliant until a follow-up confirms it has been addressed.

Do you have case studies?

Not yet. The cobalt work starts in 2027 and we are taking on founding pilot clients now.

Which regulations do you cover?

The EU Batteries Regulation (due diligence from 18 August 2027), the EU Deforestation Regulation, OECD Due Diligence Guidance, 3TG conflict minerals rules and, from July 2029, the CSDDD for the largest companies.

Who sees our data?

Your named contacts, our field team and the UK reviewer. Data is held on encrypted UK-administered storage and we sign an NDA before starting.

How much does a pilot cost?

From £8,000 for one site over three to four weeks, fixed in advance.

Request a Pilot

Tell us about your supply chain.

We respond within one working day with an honest assessment of what the regulation requires of you, and what a pilot would involve.

Thank you. We have received your enquiry and will respond within one working day.