Claigan offers comprehensive conflict minerals services, including:

reASONABLE COUNTRY OF ORIGIN (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)
  • Data gathering from suppliers using the Extended Minerals Reporting Template (EMRT)
  • Development of an updated EMRT
  • Development of an updated CMRT
  • Review and correction of supplier data
  • Storage and maintenance of country of origin responses for audit and traceability

reASONABLE COUNTRY OF ORIGIN (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
  • Determination whether smelter is sourcing from Conflict Affected and High-Risk Areas (CAHRAs)

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