Claigan has been in the responsible minerals space since before the SEC published its Final Rule on Conflict Minerals. We have developed a world-class research process for mapping and identifying risks in mineral supply chains from tier one engagement to research on smelters many steps removed; we know mineral supply chains.

Critical minerals

In 2022, the USGS designated 50 minerals, including rare earth elements, copper, aluminum, and zinc, as “critical minerals” that are necessary to the production of modern technologies. Countries, such as China, hold near monopolies on the production of some of these minerals. In a time of trade uncertainty, this poses a significant threat to international supply chains.

Leveraging our knowledge of mineral production and factors impacting trade, such as prices and export bans, Claigan will identify the critical mineral risks specific to your company’s operations. Claigan’s Critical Minerals service will do the following:

  • Pinpoint the critical minerals used in your products
  • Identify the risk level of each critical mineral
  • Explain risk factors and historical supply disruptions
  • Relate these risks to actual products made by your company 
supplier engagement

Claigan provides data gathering solutions to help companies collect supplier surveys. These include various mineral reporting templates (CMRTs, EMRTs and AMRTs) and other questionnaires such as Supplier Code of Conduct or Human Rights qualifiers. Claigan’s services include:

  • Contacting suppliers and collecting completed reporting templates
  • Review and correction of supplier data
  • Storage and maintenance of supplier responses
  • Amalgamation of smelter data and custom CMRT/EMRT/AMRT
  • Real-time risk identification

Claigan’s experienced project managers will work with your team to increase quality and quantity of responses each year. Our knowledge of supply chain actors allows us to streamline your program for successful engagement with your suppliers. Claigan has experience working with suppliers across a range of industries, including electronic, automotive, consumer, aerospace, medical, and more.

Smelter RCOI & Due Diligence

Dodd Frank Act – (Tin, Tantalum, Tungsten, and Gold) 

  • RCOI Data for each smelter
  • Determination whether there is ‘reason to believe’ the smelter is sourcing from the covered countries
  • Due diligence on smelters sourcing from the covered countries
  • Identification of risks related to Conflict-Affected and High-Risk Areas (CAHRAs), sanctions, materials of Russian origin, and forced labour (UFLPA)

EU Battery Regulation – (Cobalt, Lithium, Nickel, and Natural Graphite) 

  • RCOI Data for each smelter
  • Analysis of social and environmental risks outlined in Annex X of the new EU Batteries Regulation
  • Identification of risks related to Conflict-Affected and High-Risk Areas (CAHRAs), sanctions, materials of Russian origin, and forced labour (UFLPA)

Responsible Mica Sourcing 

  • RCOI Data for each smelter
  • Assessment of child labour risk for mica processors reported on your suppliers’ EMRTs
  • Identification of risks related to Conflict-Affected and High-Risk Areas (CAHRAs), sanctions, materials of Russian origin, and forced labour (UFLPA)

At Claigan, we believe in doing the research ourselves and have cultivated strong relationships with mineral processors around the world. Our research is entirely based on direct smelter engagement and publicly available evidence. We also include references to smelter participation in recognized industry schemes.

Program and Compliance Support

Claigan’s subject matter experts will support improvements to your company’s overall responsible minerals program. Including, but not limited to:

  • Drafting reports for submission to the SEC and/or publication on your company’s website
  • Ensuring your program’s alignment with the OECD Due Diligence Guidelines
  • Helping your company navigate customer expectations