CMRT (Conflict Minerals Reporting Template) Data Validation

Table of Contents
INFO@ASSENTCOMPLIANCE.COM | WWW.ASSENTCOMPLIANCE.COM | TEL: 1-866-964-6931
1. What is Data Validation?
2. How does is work?
3. How do I check to see if my CMRT Data is Valid?
4. How do I ensure my Supplier’s CMRT Data is Valid?
5. Q&A

What is Data Validation?
Data Validation is the method by which companies identify inaccuracies in supplier provided CMRTs
In practice, this is done through the analysis of conflicting responses
Ex: A supplier states that they have only received information from 50% of relevant Tin suppliers
(Question 5) but have identified all of their Tin Smelters (Question 6)
If the Supplier has not received information from all sources, they cannot have identified all
their Smelters
Ex: A supplier states they do not have 3TGs from the DRC (Question 3) but list a Smelter known to
source that mineral from the DRC on the Smelter tab.
Even if a Smelter is certified as Conflict Free, if they source from the DRC and they are
listed on the Supplier’s Smelter tab, that supplier needs to answer yes for the appropriate
mineral in Question 3
Data Validation is becoming more and more prevalent, especially as companies start adopting more
advanced technologies to tackle Conflict Minerals and other regulations
Depending on your vertical and Conflict Minerals process, approximately 25% of Supplier data is invalid
This can have significant impact on your CMRT since you are rolling up your Supplier’s answers.
Recommendation: If you haven’t already, you need to start conducting Data Validation on your
Supplier’s CMRT submissions.

How Does it Work?
There are 2 different methodologies and 2 different implementation types
Methodologies
Standard
Look only at Supplier Declaration tab to compare answers for contradictory responses
Complex
Cross-reference information from the Supplier Declaration tab against the Smelter tab
looking for inaccuracies (Note: This is in addition to the checks made in the Standard
version)
Implementation Types
Manual
Automated
Standard methodology usually catches human errors or misunderstandings
The Complex methodology usually catches data that was previously unknown to the Supplier

Ensure your CMRT is Valid
How do you make sure your CMRT passes a Data Validation check?
Review your answers!
Many “Invalid” responses are accidental
Look at Questions 3, 4, 5 and 6!
The answer to those questions is what triggers 90% of Data Validation failures!
Send it to Assent – we’ll check it for free 
Looking at the major stumbling blocks:
#3 – Do any of your 3TGs originate from the covered countries?
You can answer Yes with 1 response but you can’t answer No without 100% (proving a
negative)
#4 – is 100% of the 3TG in question from a recycled source?
HINT – if you don’t know, the answer is no.
#5 – Have you received info from all relevant 3TG Suppliers?
If you are not at 100%, then you can’t make definitive statements for Questions 3, 4 and 6
#6 – Have you indentified all your Smelters?
If the answer here is yes, then #5 must be yes.
Also impacts #3

Ensure Supplier CMRTs are Valid
Here you need to look at your Methodology (Standard vs Complex) and your Implementation (Manual vs
Automated)
This is very hard to do Manually in general
Complex can not be done manually
If Manually then you will need to have all your answers on 1 spreadsheet,1 row per supplier, with all the
answers from the declaration tab populating their own columns to the right.
Use Data Filters
Filter Question #3 for the Answer “No”
Make sure that the corresponding answer for #5, 6 and 7 is yes
Any other response for #5, 6 or 7 would be invalid
Filter Question #4 for the Answer “Yes”
Make sure that the corresponding answer for #5, 6 and 7 is yes
Any other response for #5, 6 or 7 would be invalid
Filter Question #6 for the Answer “Yes”
Make sure that the corresponding answer for #5 is yes
For an Automated approach – you can use Assent 

2015 – What’s next
Give us CMRTs you have received from your Supply Chain and will run a Data Validation check on them
at no cost!
Slide deck and Recording to be sent this week
Continued Tactical level Webinar Series
The webinar series continues next week - January 15th
The Top 3 Do’s and Don’t of Conflict Minerals Due Diligence
Register here: https://attendee.gotowebinar.com/register/9029660441033715970
The rest of the series can be found here: http://www.assentcompliance.com/webinar.asp

Questions
?

CMRT (Conflict Minerals Reporting Template) Data Validation

Recommended

Recommended

More Related Content

Similar to CMRT (Conflict Minerals Reporting Template) Data Validation

Similar to CMRT (Conflict Minerals Reporting Template) Data Validation (20)

More from Matt Whitteker

More from Matt Whitteker (20)

Recently uploaded

Recently uploaded (20)

CMRT (Conflict Minerals Reporting Template) Data Validation