The Conflict Minerals regulation was introduced by the Securities and Exchange Commission (SEC), as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The regulation requires SEC regulated companies to publicly disclose their use of Conflict Minerals in their products, if those minerals are necessary to the functionality or production of a product manufactured by those companies.
As per the regulation, the Conflict Minerals are Tantalum, Tin, Tungsten & Gold (3TG) which originated in the Democratic Republic of the Congo (DRC) or an adjoining country, which collectively form the ‘DRC Zone’. In order to comply with the Conflict Minerals regulation, companies are required to conduct a Reasonable Country of Origin Inquiry (RCOI), to determine whether their 3TG content originated in the DRC Zone or is recycled from scrap sources. The nature of an RCOI exercise will depend on a variety of factors like the size of the company, the products and its supply chain visibility.
The compliance effort brings with it new challenges for supply chain groups within companies, as they need to trace the source of minerals, particularly those contained in procured parts, assemblies or other items purchased from vendors. The fact that the supply base is not always geared to address these requirements only magnifies the challenge. CMRT (Conflict Minerals Reporting Template), a standardized template developed by Conflict-Free Sourcing Initiative facilitates the transfer of information through the supply chain regarding mineral country of origin and smelters and refiners being utilized.
Enventure’s Conflict Minerals compliance services are structured as complete solutions, and are designed to reduce the Client’s internal workload around meeting compliance requirements.
Customers consider Enventure as their strategic compliance partner and utilize services, such as:
- Developing Compliance Road Maps
- Consulting and Gap Analysis
- Collection of CMRT Declarations from Suppliers
- Ongoing Maintenance of Supplier Declarations
- Supplier Training