Conflict Minerals Compliance
Conflict Minerals
Reporting
Conflict Minerals Compliance is intended to support international efforts to reduce trading in minerals sourced from conflict zones (‘conflict minerals’). It primarily requires companies that buy products containing Tin, Tungsten, Tantalum or Gold (3TG) to report on the procurement source of these minerals, and this, in turn, affects the entire downward supply chain.
In 2010, the US Congress passed the ‘Dodd-Frank Act’, with rules requiring SEC-listed companies to disclose whether they use conflict minerals in their products. They need to declare this by determining whether any level in their supply chain utilized minerals which originated in the Democratic Republic of Congo (DRC) Zone. Additionally, starting January 2021, a new law will apply across the EU – the ‘Conflict Minerals Regulation’ by OECD, to check if the imports into the EU are from a responsible supply chain of minerals and not from conflict-affected and high-risk areas.
Conflict Minerals Consulting Services
These two regulations bring new challenges like having to deal with gaps in traceability and lack of proper documentation, which are critical for compliance assessments and declarations. Not all suppliers are able to deliver the required documentation to prove that they have done their due diligence while declaring their supplies to be ‘free of conflict minerals’.
This regulation mandates annual reporting, necessitating ongoing efforts to gather the latest compliance declarations from suppliers. In the US, the Responsible Minerals Initiative (RMI) has established the Conflict Minerals Reporting Template (CMRT) as the prevailing standard for these declarations.
We offer comprehensive support for implementing Conflict Minerals compliance programs, encompassing supplier training, orientation, and annual CMRT collection efforts. Our online platform facilitates supplier engagement, and we proactively reach out directly to suppliers to streamline the process.
Exclusive Conflict Minerals Compliance consulting & services to our partners are
- Developing and executing a conflict minerals compliance programs
- Collection of CMRT from Suppliers
- Consulting and advisory services
- Supplier declaration validation and due diligence
- Preparation of the Form SD and Summary
- Compliance Reporting
