confli ct minerals r eporting template · 2015. 9. 9. · is your conflict mineral sourcing policy...

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Welcome to Assent compliance Conflict Minerals Reporting Template (CMRT) guide. This guide provides comprehensive information and direct instruction on how to fill out a CMRT 4.01.The CMRT is broken down into 5 sections.

• Company Information

• Sourcing Questions

• Policy Questions

• Smelter Details

• Product Details

Each section covers a different aspect of requirements for the Conflict Minerals regulation. The guide shows each section step by step and helps select which answers would be appropriate on which scenarios.

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ConfliCt Minerals reporting teMplate

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Table of ConTenTs1. Company Information .............................................................................................................................................................. 3

2. Sourcing Information ............................................................................................................................................................... 4

3. Policy Questions ........................................................................................................................................................................ 7

4. Smelter Information (Smelter List Tab) ................................................................................................................................ 9

5. Product Information ............................................................................................................................................................... 10

6. Checker ..................................................................................................................................................................................... 11


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Company InformaTIon

The Company Information section allows manufacturers to declare who they are and which parts they are declaring for. Each field that is highlighted in yellow are required information for the CMRT.

CompanyName: Here manufacturers can list the name of their companies. For those that do business under another name, it is recommend that both company names be listed: .e.g. Acme Inc. DBA Fragile Packaging

Declaration of Scope or Class: Manufacturers can choose to select all of their production or some of their production within a specific CMRT when declaring 3TG sourcing.

A.company: All Products produced by the manufactured are covered under the CMRT.

B.User defined [‘Specify in Description of scope’]: This allows users to input their own definition of parts or products that fall under scope of a specific CMRT. This is usually done at a division level or under a specific category of product. Users that select this type of scope are required to fill the description of the scope on the following row.

C.Product(orlistofProducts):Users can choose to make a list products that fall under a specific CMRT. The list of products should be filled out under the Product List Tab. Please Note: Products listed must include a clear description of the product along with a part number.

CompanyUniqueID(Optional): Allows manufacturers to list a specific Code or Number associated with their companies for identification purposes.

CompanyUniqueIDAuthority(Optional): Manufactures can list the authority that is associated to the ID. This is highly recommended for companies that list a Company Unique ID.

Address(Optional): Companies can choose to list their mailing address within the CMRT; this is helpful when declaring under a certain division or business unit, rather than a whole company.


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ContactName:The Contact name will be the individual responsible for dealing with inquiries on the CMRT.

email–Contact:The Email Contact is the email of the Contact Name listed above.

Phone–Contact:The Phone Contact is the con-tact number for the Contact Name listed above.

Authorizer:The Authorizer would be the individual that is responsible for approving the use of the CMRT within a specific company. Please note: In many cases, the Authorizer and the Contact can be the same person.

Title–Authorizer(Optional):The Authorizer can choose to put his or her official title on the CMRT.

email – Authorizer: This would be the email of the Authorizer listed above.

Phone–Authorizer:This would be the telephone contact for the Authorizer Listed Above.

effective Date: Because sourcing information tends to be collected in waves, it is highly recommended you

keep your company’s CMRT up to date. The effective date allows you to associate a calendar date with the CMRT information. Please note that this date does need to be listed in the Day-Month-Year format to be accepted.

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sourCIng InformaTIon

The Sourcing Information section allows manufacturers enter the information on Conflict Minerals in their production.

1. Isthe3TGintentionallyaddedtoyourproduct?

This question asks if any conflict metals are found within the actual product themselves that are covered within the CMRT.

• Yes: If the company can confirm that the metal in question is found in the product.

• no: If the company can confirm that the metal in question is not found in the product.


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2. Isthe3TGnecessarytotheproductionofyourcompany’sproductsandcontainedinthefinishedproductthatyourcompanymanufacturesorcontractstomanufacture?

This question asks if any conflict metals are contained within the products covered in the CMRT. This differs from the previous question because 3TGs can be found in products during production, such as a catalyst or metal compound.

• Yes: Company confirms that the metal is added at some point during the manufacturing process.

• no: Company confirms the metal is not added at any point during the manufacturing process.

3. Doanyofthesmeltersinyoursupplychainsourcethe3TGfromthecoveredcountries?

The covered countries are: Democratic Republic of Congo (DRC), The Republic of Congo, Central African Republic, Tanzania, South Sudan, Burundi, Zambia, Rwanda, Angola and Uganda.

• Yes: Company has found that one or more smelters in its supply chain source the metal in question.

• no: Company has found the metal in question is not sourced from the covered countries. This should only be selected if companies have completely surveyed their supply chain for the covered metal (see question 5).

• Unknown: Company should select this option if they are still in the process of surveying their supply chains and have not determined if any supplier sources from the covered countries.

4. Does100percentofthe3TG(necessarytothefunctionalityorproductionofyourproducts)originatefromrecycledorscrapsources?

This question asks if the complete sourcing for all conflict metals originates from recycled or scrap sources. Please note that if you source from a recycler or scrap smelter you still must list the smelter on the Smelters details page.

• Yes: Company has confirmed that the entire sourcing for the affected metal is from a recycle or scrap smelter.

• no: Company has confirmed that it has found at least one source that is not a recycle or scrap supplier for the affected metal.

• Unknown: Company has yet to complete surveying suppliers and has yet to find a source that is not a recycle or scrap supplier.


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5. Haveyoureceiveddata/informationforeach3TGfromallrelevantsuppliers?

This question asks how much of your supply chain for the declared products have responded to your inquiries on sourcing and provided information. Answers are broken down into 25% intervals for each affected metal. Companies have the option to list exact percentages in the comments section.

6. Haveyouidentifiedallofthesmelterssupplyingthe3TGtoyoursupplychain?

This question asks if the manufacturer has been able to identify all the smelters listed from the parts covered within the CMRT.

• Yes: All smelters have been identified for the covered parts.

• no: Not all smelters have been identified for the covered parts.

7. Hasallapplicablesmelterinformationreceivedbyyourcompanybeenreportedinthisdeclaration?

Since smelter data may not always be accurate, it is important to list reasons of why all smelter data may not be listed on the CMRT (e.g. confirming smelter identity).

• Yes: All smelter data has been listed on the smelter list tab.

• no: Not all smelter data has been listed on the smelter list tab.

• Unknown: We cannot determine if all smelter information has been listed in the smelter list tab (multiple divisions could be dealing with information gathering).


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polICy QuesTIons

A. Doyouhaveapolicyinplacethataddressesconflictmineralssourcing?

• Yes: Our company has a policy in place.

• no: Our company does not have a policy in place.

B. Isyourconflictmineralsourcingpolicypubliclyavailableonyourwebsite?

• Yes: Company policy is available on our company website. (User must list the URL of policy in the comments section.)

• no: Company policy is not listed on our company website.

C. DoyourequireyourdirectsupplierstobeDRCconflict-free?

• Yes: We require all of our direct suppliers to provide conflict free 3TGs.

• no: We do not require our direct suppliers to provide conflict free 3TGs.

The Policy Questions section allows manufacturers to state their company policy and position on conflict mineral sourcing


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D. Doyourequireyourdirectsupplierstosourcethe3TGfromsmelterswhoseduediligencepracticeshavebeenvalidatedbyanindependentthirdpartyauditprogram?

• Yes: We require all smelters of our suppliers to go through an independent third party audit to confirm they are sourcing conflict free 3TGs.

• no: We do not require smelters that source to our suppliers to go through an independent third party audit.

e. Haveyouimplementedduediligencemeasuresforconflict-freesourcing?

• Yes: We have investigated the information provided to us by our suppliers to determine conflict free status of our 3TGs.

• no: We not investigated the information provided by our suppliers for 3TG sourcing to determine conflict free status.

F. DoyoucollectconflictmineralsduediligenceinformationfromyoursupplierswhichisinconformancewiththeIPC-1755ConflictMineralsDataexchangeStandard[e.g.,theCFSIConflictMineralsReportingTemplate]?

• Yes: Our suppliers have provided us with their 3TG sourcing information on an IPC-1755 or a CMRT.

• no: Our suppliers have not provided information to us on an IPC-1755 or a CMRT.

G. Doyourequestsmelternamesfromyoursuppliers?

• Yes: Smelter names are requested from our suppliers supply chains.

• no: We do not request smelter names from our suppliers.

H. Doyoureviewduediligenceinformationreceivedfromyoursuppliersagainstyourcompany’sexpectations?

• Yes: We run verification on due diligence findings against our company policy to see if the verification done by our suppliers aligns with our own.

• no: We do not run verification of due diligence findings from our suppliers against our company policy.

I. Doesyourreviewprocessincludecorrectiveactionmanagement?

• Yes: We do obligate suppliers to implement a conflict minerals process if we deem their efforts are not sufficient.

• no: We do not obligate suppliers to implement a conflict minerals process if we deem their efforts are not sufficient.

J. AreyousubjecttotheSeCConflictMineralsRule?

• Yes: We are a publically traded company and are required to file with the SEC our conflict minerals findings every year.

• no: We are not a publically traded company are not required to file with the SEC.


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It is possible to list a smelter that is not displayed on the CMRT by selecting the affected metal on the first column and then selecting the “Smelter Not Listed” on the second column. You then will have the option to input any information from the remaining columns.

For smelters that are not listed on the CMRT, it is important to list as much information as possible.

smelTer InformaTIon (smelTer lIsT Tab)

The smelter list tab allows companies to list all the smelters they have been able to find in their supply chains. Companies can select 3TGs from the first column and then select from one of the authorized smelters listed within the actual CMRT; these are smelters that have approached the CFSI to begin the process of verifying themselves as being conflict free.

PleASeNOTe: Just because a smelter is listed on the CMRT does not mean it is conflict free! All this means is that the smelter has begun the process to verifying themselves as conflict free. An updated list of conflict free smelters can be found on the CFSI website at the link below:

http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/

Our due diligence process will require us to reach out to these smelters and having as much information as possible will allow us to do.


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The Product List tab allows manufacturers to list of the products under the scope of this Declaration. This section of the CMRT is mandatory if manufacturers selected Product (or List of Products) in the Company Information section.

Pleasenote: manufacturers are required to list product numbers in the Manufacturer’s Product Number column.

produCT InformaTIon(produCT lIsT Tab)


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Checker Tab allows manufacturers to verify if all the required information has been populated. It is the best way to insure completion before submitting CMRT

Fields in green--completed

Fields in red--not completed

Look for the fields highlighted in red. The Notes in Column C prompt you what actions are required.

The Hyperlinks to Source in Column D provide you with the access to the fields that require completion.

Pleasenote: As the Checker is updated real-time, you can review it at any time while completing the template.

CheCker


confli ct minerals r eporting template · 2015. 9. 9. · is your conflict mineral sourcing policy...

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