2. Table of Contents
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1. CMR Refresher
2. CMR Process
3. CMR Content – How to Meet the 5 Steps
4. Timeline
5. Examples
6. Q & A
3. CMR Refresher
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Before we get to the Conflict Minerals Report you need to have found “reason to believe” that some of
the 3TGs in your Supply chain may have originated in the covered countries.
At that point, you must conduct Due Diligence on those sources in accordance with a nationally
recognized framework
There's only 1- the OECD's Due Diligence Guidance
The activities and results for that Due Diligence is reported in the CMR
5 Steps:
1. Establish Strong Management Systems
2. Identify and assess risks in the supply chain
3. Design and implement a strategy to respond to identified risks
4. Carry out independent third-party audit of smelter/refiner’s due diligence practices
5. Report annually on supply chain due diligence
4. CMR Process – Big Picture vs Practical
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Big Picture
Your Conflict Minerals report should speak to items that would potentially be covered in an Audit:
Your process (What did you set out to do)
Your execution (Did you follow through with your process)
Practical Terms
Don’t just copy and paste from the OECD Guidelines.
Actually explain your process
Include your activities surrounding the following items:
Data Collection
Data Validation
Risk
Smelter Verification
These activities should be carried out daily, in real-time as you receive Supplier responses
Don’t save all the work until the end!
All these items should be documented in the system you use to track Conflict Minerals data
This system would be part of your audit (proof of execution in good faith)
The CMR content itself should be a matter of compiling and summarizing this data
5. CMR Content - How to meet the 5 Steps
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Step 1 - Establish Strong Company Management Systems
Your Conflict Minerals Policy
Your policies surrounding communication with suppliers
This includes:
Data Collection
Data Validation
SCARs
Audit Trail
Help Desk
Supplier Success Center
3 email attempts and 3 phone attempts (Best practice)
Step 2 - Identify and assess risks in the supply chain
The methodologies you employ to ensure accuracy and identify potential DRC sources:
Data Validation (fact checking the CMRTs)
Supplier Due Diligence (red flag analysis on supplier responses A-J)
Smelter Verification (cross-referencing Smelter data and reaching out to undocumented
smelters)
6. CMR Content - How to meet the 5 Steps
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Step 3 – Design and Implement a strategy to respond to identified risks
This is your process to respond to risk (hint – part of your communication strategy):
QA team
SCAR program
Help Desk
Supplier Success Center
Grievance Mechanism
All items must be documented in your system for transparency
Step 4 - Carry out independent third-party audit of smelter/refiner’s due
diligence practices
For downstream users, it is recommended that you join an industry group such as the CFSI
Step 5 – Reporting annually on supply chain due diligence
This item is covered by the CMR itself
7. Timelines
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Timelines for Completion
Since the data is collected and verified on a continual basis, compiling and summarizing can begin
anytime
This data can also be fed into a template closer to the actual reporting deadline (IE: You can put
together the CMR and input the final percentages and facilities right before submission)
In general, these reports take between 1 – 2 months (start to sign off)
This timeline would not include an audit – be prepared to add more time!
