Understanding the Additional Minerals Reporting Template (AMRT)
The Additional Minerals Reporting Template (AMRT) is a free, standardized tool designed to help businesses collect essential due diligence data on minerals beyond conflict minerals (3TG) and extended minerals (cobalt and mica). Unlike these minerals, which have their own specific reporting templates, the AMRT provides a broader framework for tracking various minerals of concern. Developed by the Responsible Minerals Initiative (RMI), the AMRT enhances supply chain transparency, enabling companies to meet ethical and regulatory standards while ensuring responsible sourcing practices. Originally introduced as the Pilot Reporting Template (PRT) over two years ago, the tool has now evolved beyond its initial phase and has been officially rebranded as AMRT 1.2. What Makes AMRT Unique? The AMRT is a versatile reporting tool that is not limited to specific minerals. Instead, it allows businesses to track up to ten minerals of concern within a single template. This flexibility enables users to define the scope based on their unique supply chain needs. How Does AMRT Differ from CMRT and EMRT? Although the AMRT, Conflict Minerals Reporting Template (CMRT), and Extended Minerals Reporting Template (EMRT) share similarities, they serve distinct purposes: Challenges in AMRT Adoption Despite its benefits, companies face several challenges in implementing the AMRT: Solutions for Effective AMRT Implementation To address these challenges, companies can take proactive steps: Applications of AMRT The AMRT plays a crucial role in ensuring ethical and responsible sourcing by: At ComplianceXL, we offer AMRT regulatory compliance services to help companies collect and manage AMRT data for their products. Our compliance data management approach ensures that supplier certificates and declarations remain updated. Additionally, we provide ongoing maintenance services to validate and preserve regulatory documents, ensuring their accuracy and compliance with industry standards. FAQs: 1. Which minerals are covered by the AMRT? The AMRT primarily focuses on minerals that do not fall under the traditional 3TG category but still present ethical or sourcing concerns. This includes minerals like cobalt, mica, and others essential to various industries. 2. How can I access the AMRT? The AMRT is available for free on the Responsible Minerals Initiative (RMI) website. Companies can download the template and begin using it to report their due diligence information. By leveraging the AMRT, businesses can strengthen their commitment to ethical sourcing, regulatory compliance, and supply chain transparency.
ComplianceXL Secures a contract with a leading US manufacturer to support Conflict Minerals Compliance management
ComplianceXL has signed a contract with a US-based manufacturer of engineered products for industrial, commercial, and consumer markets worldwide. Under the multi-year blanket agreement, ComplianceXL will provide CMRT support services for their entire supply chain. An engineering leader serving a variety of end markets around the world, including industrial, commercial, and consumer markets, the client manufactures engineered products. Due to its global sales footprint, the client must ensure compliance with all major regulatory demands. Therefore, the client must maintain high standards of quality and safety. This system is regularly monitored and updated to ensure compliance with the latest regulations. The Conflict Minerals program by ComplianceXL will include supplier engagement strategy, CMRT collection, and validation, generating roll-up reports, a software platform to store all CoCs, and report submission. Therefore, the client will be able to manage complex products, markets, and supply chain networks while reducing CMRT reporting costs and time to market. Highlights of the engagement: According to CK Bharathan, Head of Compliance Solutions at ComplianceXL, this engagement will allow the client to manage compliance documentation effectively. As a result of this partnering, the client can streamline regulatory compliance management, ensuring seamless compliance with all applicable regulations.In addition, this engagement will provide them with the tools to monitor and enforce compliance requirements within the organization.
How to ensure your CMRT is complete without errors?
The conflict minerals reporting template consists of 8 tabs out of which 3 tabs must be filled by the companies or Suppliers and 2 tabs to check the completion. Important points to be noted while filling the 3 tabs to avoid errors, Declaration Tab: On the Declaration Tab make sure all the fields marked as (*) / cells highlighted in yellow are filled. Provide appropriate answers for the questions asked in the Company information section. Try to reduce the number of characters you include in the Comments section and be concise. Enter the Company name and other company related answers in English for accuracy. Select Declaration Scope from the drop-down list only. Contact name and Authorizer can be same but enter the name completely in each respective cell instead of giving “Same as above, etc,.”. Email address of the Contact person and Authorizer should be in correct email format. The Effective date must be entered in International format DD-MMM-YYYY and it can only be past or present date. The 3TG Questions from 1 to 8 are all mandatory questions. Answers should be selected from the drop-down list only. When Question 1 and 2 is answered as NO, all other cells will turn grey indicating it is not required to fill. When Question 1 and 2 are answered as YES, all other questions will remain yellow until you fill the cells. Majority of the Clients/ Companies expect the response rate of their supply chain to be above 90%. Report all the Smelter information received by your Company in the CMRT. Every Company who uses 3TG in their products is recommended to have a Conflict minerals policy published in their website. The Policy information section allows suppliers to project the action taken for the Conflict minerals sourcing. Each Question in the CMRT is related to one another. While answering each question make sure it is logically connected with one another. For Example: When 3TG is sourced from covered countries and Question 3 is answered as YES, you cannot answer Question 5 as YES as the Question goes as “Does 100% of the 3TG originate from Recycle/Scrap?” Smelter List Tab: Smelter list is the section where majority of the errors occur. This section is required only when 3TG is used. Without Smelter list, the origin of the minerals cannot be found. Column A – Smelter Identification Number Input Column is not mandatory. You can leave blank or provide the same Smelter ID given in Column F. Column B – Metal, Column C – Smelter Look-up and Column E – Smelter Country are mandatory Columns and select them from the drop-down list only. Smelter name can be entered manually only when it is not listed in the drop-down. In this case try to provide more information about the Smelter location, mines, origin, contact details, etc., in the respective Columns. When Metal and Smelter Look-up is selected from the drop-down list, Column D (Smelter Name) will turn grey (not required to fill) and all other fields like Smelter Country, Smelter Identification number and Source of Smelter ID will be auto-populated. Do not copy/paste the Smelter information to the Smelter list tab. The text length should not be more than approx. 255 characters. Product List Tab: Product List should be filled only for Product level CMRT. Refer – How to prepare a Product level CMRT for more info. Points to remember to check the CMRT, Checker Tab: Checker tab helps to identify the complete and incomplete fields. The Completed fields are highlighted in green whereas the incomplete fields are highlighted in red. You have links which will direct you to the incomplete field. Note that this tab will only help to fill the CMRT but not to identify errors. Smelter Look-up Tab: The Standard Smelter list provided by RMI is listed under Smelter Look-up tab. The Smelters listed under this tab only can be selected from the drop-down for relevant metals in the Smelter list tab. Provide correct Smelter name for correct Smelter ID. Refer Active Smelter list provided by RMI – http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/smelters-refiners-lists/export-all-active/ Refer Conformant Smelter list provided by RMI – http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/smelters-refiners-lists/export-all-conformant/ Conclusion: Use the most recent Standard template/version CMRT to collect information from your suppliers. This will be more efficient to consolidate the received supply chain data with accuracy. Conduct training programs and recommend you suppliers to participate in RMAP program to remain compliant. Review the CMRT completely before submitting. Talk to one our CMRT specialist today, to understand how you can address the Training and CMRT documentation requirements.
Get Ready! European regulation on Conflict Minerals is implemented
The European Union Conflict Minerals Regulation adopted in June 2017, will take effect on 1st Jan 2021, starting with importers, smelters, and refiners of tungsten, tin, tantalum and gold (3TG). It requires the EU companies to ensure they import the minerals and metals from responsible and conflict-free sources only. EU regulation aims at Ensuring EU 3TG importers to meet international responsible sourcing standards, created by Organisation for Economic Co-operation and Development (OECD). Ensuring all the 3TG global/EU smelters & refiners to source the minerals/metals responsibly. Stopping the illegal exploitation of minerals Bringing an end to exploitation and abuse of local communities and mine workers. EU introduces a concept called “Conflict-Affected and High-Risk Areas”. It’s quite different from US conflict mineral reporting. US conflict mineral reporting, which we currently have, is focused exclusively on the Democratic Republic of Congo (DRC) and surrounding areas, but the EU regulation is global in scope, means, not only Central Africa, it could be West Africa (conflict financing in Mali) or Myanmar (problem area for tin). Even though the reporting guideline has been released by EU, they have not specified the exact format and content of reporting. In order to perform due diligence sourcing, importers should have a system in place that provides with the following information. Country of mineral origin, from where minerals come in. Quantity imported. Trade names and types of minerals imported. Supplier name and address. If a mineral is sourced from conflict-affected and high-risk areas, importers must provide additional information and documentation on; Mine from where minerals come in. Where minerals are consolidated, traded and processed. The taxes and fees paid. If an EU importer has not complied with the regulation, then; Member state will order the firm to address the problem within a given deadline and follow up is madeto ensure it does so. Talk to compliance experts at ComplianceXL, to get more insights on the conflict minerals regulation requirements and its effect on your day to day business.
Conflict Minerals Compliance: FREQUENTLY ASKED QUESTIONS
While handling environmental compliances, suppliers and manufacturers from various industries face multiple challenges. After having provided successful compliance services to all our Clients across geographies, we decided to compile our set of frequently asked questions about Conflict Minerals Compliance. Below is the set for your reference: 1. What if a company decides not to comply with Section 1502 or SEC filing? If a company does not comply with the laws of the SEC, it will not be able to raise new capital under the Exchange Act. 2. Is SEC filing applicable for private companies? Private companies are not required to file annual reports under the SEC but if their customers are publicly traded on the US stock exchange and are liable to file a conflict minerals report, then the company should also report under SEC on the Origin and mining procedures of the minerals. 3. Which framework can be suggested for due diligence process? The due diligence process should be carried out by a nationally or internationally recognized framework. Currently, the only recognized framework is the OECD (Organization for Economic Cooperation & Development) which performs Due Diligence Guidance for a Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas. 4. When will an issuer NOT be considered as “contract to manufacture”? In the following cases the issuer cannot be considered as “contract to manufacture” If the issuer is involved in Specifying or negotiating contractual terms with the manufacturer Affixing brand, logo, marks or label to a generic product Services, maintenance or repair activity If the issuer is not directly or indirectly involved in the manufacturing process 5. What do you mean by “DRC conflict-free”? “DRC conflict free” means the product manufactured does not contain any of the 4 conflict minerals (Tantalum, Tin, Gold and Tungsten) that have been identified to directly or indirectly benefiting militants in the DRC- Democratic Republic of Congo, countries. 6. When can an issuer describe the products as “DRC conflict undeterminable”? If the issuer is not able to determine that the conflict minerals mined from DRC countries, are benefiting armed groups even after due diligence process then the products are considered to be “DRC conflict undeterminable”. The undeterminable status of the product would be based on the due diligence process (conducted by OECD). 7. Can a company provide Conflict minerals policy stating that “we are conflict free”? No, in most cases, a comprehensive Conflict Minerals Compliance process is required. However, if a company provides full due diligence documentation and supporting data through the Conflict Minerals Reporting Template (CMRT) to verify its products are conflict-free, a policy statement may be accepted. Compliance with due diligence requirements is mandatory and cannot be bypassed. 8. Which CMRT should be used for 2016 filings? We recommend to use the latest CMRT v4.01a which has been released after examining the errors in the prior versions. Moreover, the most updated Standard smelter list is included in CMRT v4.01a.