Conflict Minerals: Supplier Prioritization and Data Validation

The following post is based on material contained in the MetalMiner report (available for free download): Conflict Minerals: Building Responsible Manufacturing Supply Chains. Join MetalMiner and Spend Matters for the Conflict Minerals EDGE event taking place on May 6th in Chicago.

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Supplier Prioritization

The OECD Cycle 3 Final Report states that “the majority of companies developed supplier priority levels based on 3T content in products... communicating with a sub-set of Tier 1 suppliers that provide parts with highest content of 3TG in the first phase of due diligence. Many of these companies plan to reach all suppliers of 3TG materials in subsequent phases” (Page 31). Other possible criteria include criticality of product/supplier; number of suppliers/products; dollar value of supply contract or product revenue; amount of available information on suppliers/products; and information on whether the supplier is participating in industry initiatives or is required by its customer base to address conflict minerals.

Key Point: A common supplier prioritization criterion is the amount of 3TG contained in the suppliers’ products.

Supplier Data Validation

“Validating supplier responses to ensure reliable data about smelters is being passed through the supply chain remains a big challenge. The majority of participants conducting supplier surveys validate responses manually and have difficulty verifying information beyond template completeness. They have reported limitations to checking information accuracy. Participants are specifically using the Conflict Minerals Reporting Template and Dashboard to collect data from their suppliers and to verify the smelter names against the Conflict Free Smelter Program and/or the ‘known smelter list’ that is now provided through the Template. They are also applying industry and technical knowledge and using common sense to validate responses” (Page 36).

Key Point: Information from suppliers has been of inconsistent quality and can require significant effort to validate. Suppliers should work to improve the quality of the information submitted, and users of that information should validate incoming data.

Curious to learn from experts and exchange pragmatic practices with industry colleagues that are also tasked with Conflict Minerals compliance? Join MetalMiner and Spend Matters for the Conflict Minerals Edge event taking place on May 6th in Chicago.

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