Every year, Accuris works with our clients on their Conflict Mineral programs. As many companies are at least starting to think about their reporting year 2024 programs, now may be a great time to review our top ten tips for executing a successful Conflict Mineral program.
- Start early! Sorting out the suppliers to include in your Reasonable Country of Origin (RCOI) is an important step you can work on throughout the year. Focus only on suppliers who provide parts and materials that could realistically contain 3TG. Filter out all other suppliers and service providers to estimate the number of suppliers for your RCOI and the associated level of effort. Give these suppliers a heads-up that they will be included in your RCOI and set expectations. Include this type of discussion as you onboard new suppliers too.
- Leverage previous years’ reports. Review last year’s supplier responses. If a supplier reported they don’t use any 3TG in their products and there have been no changes, consider removing them from this year’s effort. This approach saves time, respects suppliers’ time, and results in more concise reporting.
- Clean up your CMRT by helping suppliers clean up theirs. Not all companies have robust conflict minerals programs, which can affect your own reporting. Use each year as an opportunity to review and help improve the information provided by suppliers through specific feedback. Modern Conflict Mineral software tools can automate feedback to suppliers, highlighting issues and suggesting improvements for their reporting.
- Use automated tools. Many companies still use manual methods to source and analyze CMRT data from suppliers. Automated tools can streamline this process, manage supplier contacts, track progress, roll up CMRT data, and retain it year-over-year. The Conflict Minerals Platform from Accuris (formerly IHS) is one such tool.
- Assemble a cross-functional task force. Successful Conflict Mineral Programs require input from several company functions. Involve colleagues from supply chain, compliance, legal, and procurement to address your conflict mineral strategies comprehensively.
- Look at your peers’ policies and public filings. To see what other companies are doing, use the US SEC Edgar site (www.sec.gov/edgar/search) to review companies’ SD/CMR (Special Disclosure/Conflict Mineral Report) filings. These filings often detail approaches and metrics, providing useful insights for benchmarking your efforts.
- Understand the importance of addressing Conflict Minerals. Companies undertake conflict mineral tasks for various reasons: SEC filing requirements, customer expectations, and corporate goals.
- Consider becoming an RMI member. Membership offers benefits such as access to Reasonable Country of Origin (RCOI) data, a facility database, and a Global Risk Mapping platform. Learn more at www.responsiblemineralsinitiative.org.
- Use Conflict Mineral content strategically. Your Conflict Mineral program may identify smelters in sanctioned countries, allowing you to address these risks in your supply chain.
- Review last year’s program experience. Show year-over-year improvement by describing steps taken and results achieved, such as advancements in due diligence, investment in training, increased engagement with stakeholders, and internal supply chain reviews.
Use these tips to strengthen your conflict minerals program every year!
For more information on how Accuris can help with you Conflict Mineral Program, contact us at https://accuristech.com/solutions/parts-content-services/.