Conflict Minerals Report

Conflict minerals reporting documents the sourcing of tin, tantalum, tungsten, and gold (3TG) through the supply chain to determine whether these minerals originate from conflict-affected and high-risk areas (CAHRAs). The primary evidence documents are Conflict Minerals Reporting Templates (CMRTs) — standardised forms completed by suppliers that identify smelter sources, countries of origin, and due diligence status for 3TG minerals. Supporting evidence includes smelter audit status from the Responsible Minerals Initiative (RMI) Conflict-Free Smelter Programme, country of origin inquiries tracing back to mine or collection point, and OECD-aligned due diligence documentation covering supply chain policy, risk assessment, management response, and audit reports.

Conflict minerals reporting is required under the US Dodd-Frank Act Section 1502 for SEC-listed companies whose products contain 3TG minerals. The EU Conflict Minerals Regulation (EU 2017/821) requires due diligence for 3TG importers into the EU. Beyond these legal mandates, conflict minerals reporting is increasingly demanded by buyers in electronics, automotive, aerospace, and manufacturing supply chains under their own due diligence programmes. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas has become the international standard referenced by multiple regulatory frameworks and industry programmes.

CMRTs (Conflict Minerals Reporting Templates) are the industry-standard form completed by suppliers — they identify smelter sources, countries of origin, due diligence status, and whether products are DRC conflict-free. Smelter audit status records from the RMI Conflict-Free Smelter Programme identify which smelters are certified conformant, active, or not certified — enabling assessment of supply chain risk. Country of origin inquiries trace 3TG minerals back to mine or collection point through supply chain declarations. OECD-aligned due diligence documentation covers supply chain policy, internal management systems, risk identification and assessment, risk management strategy, independent third-party audits, and annual public reporting on due diligence.

CMRTs, smelter declarations, and due diligence reports are uploaded to Sustalium. Data maps to Dodd-Frank compliance records, EU Conflict Minerals Regulation frameworks, and buyer-requested supply chain transparency documents. Smelter status updates from the RMI are tracked — when a smelter's audit status changes, Sustalium flags affected products and supply chain participants for review. CMRT data is linked to supplier records and product SKUs, enabling reporting at the product, business unit, or company level. Due diligence documentation is organised according to the OECD five-step framework, providing a structured evidence base for regulatory filings and buyer requests.

The US Dodd-Frank Act Section 1502 requires SEC-listed companies to disclose whether their products contain conflict minerals and to file a Conflict Minerals Report with due diligence description. The EU Conflict Minerals Regulation (EU 2017/821) requires EU importers of 3TG minerals and metals to conduct OECD-aligned supply chain due diligence. The OECD Due Diligence Guidance is referenced by CS3D (EU Corporate Sustainability Due Diligence Directive) for mineral supply chains. The UFLPA and similar forced labour import restrictions intersect with conflict minerals due diligence for supply chain transparency. The Responsible Business Alliance (RBA) Code of Conduct requires conflict minerals due diligence for electronics supply chain members. Buyer programmes including the Conflict-Free Sourcing Initiative (CFSI) and RMI member requirements mandate CMRT collection and due diligence.