Conflict Minerals Compliance: Supplier-Centric vs. Part-Centric Compliance Approaches

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. Spend Matters PRO Subscribers can also click to read two more detailed technology analyses on conflict minerals compliance strategy here and here.

Consider some of the challenges of a supplier-centric approach to conflict minerals compliance. Buying organizations will need to deploy supplier relationship management teams to suppliers who have failed to complete company-specific surveys, and the company may even need to deploy a more forceful approach to drive responses. Even when suppliers do submit a response, those responses require review to ensure completion and include reasonable/expected/conforming information. Of course, if any information from the suppliers indicates a problem, that should also set the supplier relationship teams in motion.

The alternative approach, which is more difficult to implement, involves the part-centric approach and laser-focusing only on those suppliers that may supply the 3T’s/G directly or more likely, supply products that contain the 3T’s/G. In other words, a company will work closer with the engineering/product development teams, rather than with procurement teams first. Any company that has good visibility into highly detailed bills of material (BOMs) and excellent data management tools will have a leg up in terms of identifying potential parts/products (as well as sites and contract manufacturers impacted).

For example, if an OEM can target the few hundred suppliers that may supply conflict minerals instead of sending out a blanket survey to potentially thousands of suppliers, the company can benefit from a significantly streamlined implementation process and avoid burdening that portion of the supply base that has no exposure to 3T’s/G. Also, as noted above, the OEM will need to review all incoming responses for completeness and validity, so while it may appear to take less effort to send out questionnaires to all suppliers, keep in mind the related efforts necessary on the back end. However, BOMs also have limitations as they typically exclude “consumables”—solder being one such consumable. And generally, solder contains 60% tin.

Download the full analysis Spend Matters Network site MetalMiner today: The Definitive Guide to Conflict Minerals Compliance for Manufacturers: An A–Z Guide to Conflict Minerals and Semi-Finished Metals. Spend Matters PRO Subscribers can also click to read two more detailed technology analyses on conflict minerals compliance strategy here and here.

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