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.

Supplier Engagement

Claigan provides data gathering solutions to help companies collect supplier surveys. These include various mineral reporting templates (CMRTs, EMRTs, and PRTs) and other questionnaires such as Supplier Code of Conduct or Human Rights qualifiers. Claigan’s services include:
 
  • Review and correction of supplier data
  • Storage and maintenance of supplier responses
  • Amalgamation of smelter data and custom CMRT/EMRT/PRT
  • 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, aerospace, medical, and more. 

FAQ

Smelter RCOI & Due Diligence

Dodd Frank Act – 3TGs 
 
  • 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
  • Accompanied by analysis of ESG impacts across mineral producing regions
  • Identification of risks related to CAHRAs, Sanctions, Materials of Russian Origin, and Forced Labour (UFLPA)
EU Battery Regulation – Battery Minerals
 
  • RCOI Data for each smelter
  • Analysis of social and environmental risks outlined in Annex X of the new EU Battery Regulation
  • Identification of risks related to CAHRAs, Sanctions, materials of Russian Origin, and Forced Labour
Child Labour – Cobalt & Mica
 
  • RCOI Data for each smelter
  • Assessment of child labour risk for cobalt and mica processors reported on your suppliers’ EMRTs
  • Identification of risks related to CAHRAs, Sanctions, materials of Russian Origin, and Forced Labour

At Claigan, we believe in doing the research ourselves and have cultivated strong relationships with mineral processors around the world. Our research is all 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

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