Conflict Minerals Compliance: Excel Alone is Not the Answer
This post is based on excerpts from the MetalMiner (part of the Spend Matters Network) paper: The Definitive Guide to Conflict Minerals Compliance for Manufacturers: An A–Z Guide to Conflict Minerals and Semi-Finished Metals.
There are two additional conflict minerals concerns that impact buying organizations. One concern involves the use of Excel-based approaches and whether binary Y/N answer frameworks yield information that OEMs trust as credible or valid enough to rely on without supporting narrative and/or explanatory information.
The second concern involves purchasing from both conflict and conflict-free sources. We understand some materials/component manufacturers purchase raw materials from both conflict and non-conflict sources and then maintain internal manufacturing and inventory controls to keep the conflict/non-conflict materials and products separated.
This results in conflict-free products manufactured at a non-conflict-free supplier. If these circumstances exist, such suppliers would not qualify for supplier-wide conflict-free declarations, but could make part-specific declarations under certain (albeit limited, difficult and arguably suspect) circumstances. A more likely scenario would involve separating product streams using unknown and unverified sources from product streams using verified non-conflict sources.
Given this, how does an OEM who must comply with the rules go about identifying, asking and answering the question “Do we source conflict minerals from conflict-free sources?” If an industrial-products company sources over 750,000 parts/products, that organization will likely take a supplier-centric approach by issuing mandates such as “isolate any/all metal services, electronics and materials suppliers” and sending suppliers a spreadsheet/template to verify that what they supply to the company comes from conflict-free sources.
But this approach raises a number of concerns and potential flags. Learn why in our full analysis: The Definitive Guide to Conflict Minerals Compliance for Manufacturers: An A–Z Guide to Conflict Minerals and Semi-Finished Metals.