Conflict Minerals - Top 3 Due Diligence Do's and Don'ts.docx

Top 3 Conflict Minerals Due Diligence Do’s and Don'ts
2015

Table of Contents
INFO@ASSENTCOMPLIANCE.COM | WWW.ASSENTCOMPLIANCE.COM | TEL: 1-866-964-6931
1. Defining Due Diligence
2. Gathering Data
3. Error Checking
4. Identification of Red Flags
5. Q&A

What is Due Diligence?
The activities your organization undertakes in order to make sure the information you have is accurate
and any risks disclosed.
There are 3 areas therefore to focus on:
Completeness of data
Accuracy of data
Risk in data
These areas are covered by through 3 phases of Supplier Engagement:
Gathering the data (Part of your RCOI)
Data Validation (objective fact checking)
Red Flags (subjective identification of risk)
If you can successfully conduct Due Diligence on the items above, the effort involved for the creation of
your Form SD and CMR reporting will be greatly reduced

Completeness of Data
Do’s
3 email attempts and 3 phone call attempts seems to be the standard
Follow-up with different contacts
Search website for more info (contacts and possibly declarations)
What did their Form SD/CMR state?
Closure notice
Use the CMRT!
Do Not
Operate a 1 and done system
Attempt the same contact over and over again
Use a survey to gather responses that has the same questions as the CMRT
Frustrating and usually hard/impossible to enter Smelter data

Accuracy of Data
Do’s
Validate their responses
Use a commonly accepted validation schema (we handed one out last webinar)
At a MINIMUM check question #5 – if they answer is NOT Yes then the supplier can not make any
definitive statements for 3, 4 or 6
Check the Smelter Tab “easy wins” – Malaysia Smelting Corp, Hong Kong based smelters, etc
Provide Feedback as to why you are rejecting the CMRT – ALWAYS be objective.
Do Not
Blindly accept all CMRTs with a “It’s the supplier’s responsibility to check errors.” mentality.
You roll up their data, therefore their errors become your errors

Identifying Red Flag & Risks
Do’s
Review a companies approach as well as their answers (the A-J questions)
Look at A, E, H and I for Red Flags
If a company answers no to any of those questions, how do they verify accuracy and how
will their data ever improve?
Check the Smelter list against CFSI & LBMA data
Looking for source and status
Base a Supplier’s risk on the smelter’s they use
Do Not
Risk of containing a 3TG DOES NOT equate to risk.
Stop at the CMRT – it is not the finish line
Data must be reviewed and corrected in order to assure accurate data is submitted to clients and
the SEC

2015 – What’s next
Give us CMRTs you have received from your Supply Chain and will run a Red Flag analysis on them at
no cost!
Slide deck and Recording to be sent shortly
Continued Tactical level Webinar Series
The webinar series continues next week - January 22nd
Product Level Conflict Minerals – How to get there
Register here: https://attendee.gotowebinar.com/register/7434044768758742786
The rest of the series can be found here: http://www.assentcompliance.com/webinar.asp

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Conflict Minerals - Top 3 Due Diligence Do's and Don'ts.docx

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