Conflict Minerals
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act – legislated by the Congress of the United States of America in 2010 – requires companies to disclose whether any of the products manufactured or contracted to be manufactured by the company contains conflict minerals that originate in the Democratic Republic of Congo (DRC) or any of its bordering nations. For the purposes of the rule, conflict minerals include tantalum, tin, tungsten and gold (3TGs).
In 2012, the Securities and Exchange Commission issued an SEC Final Rule on the subject, requiring issuer’s whose conflict minerals originated in the effected countries to submit a report to the SEC including a description of the measures taken to exercise due diligence regarding the minerals’ source and chain of custody.
Claigan, the only conflict minerals service supplier to pass an independence private sector audit (IPSA) on their due diligence process, offers comprehensive conflict minerals services, including:
Reasonable Country of Origin Inquiry (RCOI) - Suppliers
Claigan provides solutions for completing the required country of origin inquiries, including:
- Data gathering from suppliers using the Conflict Minerals Reporting Template (CMRT)
- Review and correction of supplier data
- Development of an updated CMRT (EICC-GESI) form for the company
- Storage and maintenance of country of origin responses for audit and traceability
Reasonable Country of Origin Inquiry (RCOI) & Due Diligence - Smelters
The smelter outreach phase of the RCOI and due diligence process includes:
- Assessment of smelter list provided by suppliers (or generated through supplier RCOI)
- Directly contacting each smelter
- Gathering country of origin information from source smelters
- Risk assessment of supplier’s statement against publicly available information
- Determination whether there is ‘reason to believe’ the smelter is sourcing from the DRC or surrounding countries
- Performance of due diligence on smelters that are or may be sourcing from the DRC or surrounding countries
- Generation of technical documents summarizing the conflict-free nature of a company and its source smelters
- Review of findings with your stakeholders
Conflict Minerals Disclosure and Report
Claigan provides conflict minerals disclosure and reporting on solutions that include:
- Drafting of SEC disclosure
- Drafting of SEC conflict minerals reports, including due diligence
- OECD due diligence guidance
- Education and consensus building among internal stakeholders
- Support during third-party audits and related corrective actions
Download the latest version of the CMRT
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