www.assentcompliance.com
Assent Compliance answers the most common frequently asked questions with regards to conflict mineral compliance.
- What are conflict minerals
- What if we are a private company
- What is the difference between the CMRT 3.01 and the previous form
- We do not use 3TG's - What now?
And a host of other FAQ's. If you have any questions about conflict minerals and or conflict mineral compliance email: info@assentcompliance.com
On August 22, 2012 the Securities and Exchange Commission (SEC) adopted a new rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires publicly-traded companies in the United States to report the use of “Conflict Minerals”. Under the rule, Conflict Minerals are cassiterite, columbite-tantalite, gold woframite and their derivatives which have been limited to tantalum, tin and tungsten (collectively known as the 3Ts), that are sourced from mines in the Democratic Republic of the Congo (DRC) or surrounding countries (collectively known as the “Covered Countries”.)
While the reporting requirements only apply to publicly traded companies, it also impacts any company supplying a company that is required to report since publicly-traded companies are requiring their suppliers to support their due diligence efforts.
This paper looks at Conflict Minerals regulations from the perspective of a company in the electronics manufacturing services (EMS) in terms of the processes necessary to support disclosure requirements and the likely support services needed over time.
For more whitepapers and articles on PCBA design and manufacturing, visit http://blog.optimumdesign.com
Conflict Minerals: Understanding Dodd-Frank 1502 and Its Affect on Your Suppl...Optimum Design Associates
On August 22, 2012 the Securities and Exchange Commission (SEC) adopted a new rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires publicly-traded companies in the United States to report the use of “Conflict Minerals”. Under the rule, Conflict Minerals are cassiterite, columbite-tantalite, gold woframite and their derivatives which have been limited to tantalum, tin and tungsten (collectively known as the 3Ts), that are sourced from mines in the Democratic Republic of the Congo (DRC) or surrounding countries (collectively known as the “Covered Countries”.)
While the reporting requirements only apply to publicly traded companies, it also impacts any company supplying a company that is required to report since publicly-traded companies are requiring their suppliers to support their due diligence efforts.
This paper looks at Conflict Minerals regulations from the perspective of a company in the electronics manufacturing services (EMS) in terms of the processes necessary to support disclosure requirements and the likely support services needed over time.
For more whitepapers and articles on PCBA design and manufacturing, visit http://blog.optimumdesign.com
This guide is intended to provide a concise summary of the TCPA statute and related regulations, and explain the new rules and their known impacts on enterprises (the organizations making the outbound contact) and recipients (people on the receiving end of the interactions). A lack of clarity in the regulations has driven organizations with the financial means to hire legal firms to assist them in interpreting the rules. Companies without the financial resources for legal counsel are looking for guidance. No one knows whether their interpretation is correct, and the case law, which is addressed in Section 2.1 of this Guide, further confounds the market, as each case seems to involve a different facet of the regulations and how they are applied.
Supply Chain Metrics That Matter - A Focus on Contract Manufacturing - 13 AUG...Lora Cecere
Executive Overview
Growth is stalled. Margin pressure is high. Shorter life cycles, as well as increasing compliance and regulatory pressure, provide additional challenges to the contract manufacturing industry. Finally, excess capacity is a significant problem. Is this a recipe for opportunity or a disaster for the brand owner using outsourced manufacturing partners? We think the latter.
Over the last decade, brand owners from consumer electronics to medical devices have grown more dependent on outsourced contract manufacturing. In fact, the contract manufacturing industry grew up out of a desire to mitigate risk and improve costs for brand owners. However, the market has shifted significantly in recent years and the contract manufacturing industry is struggling. As a result, they pose a risk to brand owners. In this report, we illustrate how the lack of resiliency affecting contract manufacturers represents a serious risk to brand owners and offer advice on what can be done to mitigate the problem.
Over the last decade, many contract manufacturers have attempted to differentiate services and refine their business model to gain competitive advantage. However, in looking at the financial results, we find that most companies are struggling. As a result, it is time to redesign the business model and relationships of contract manufacturers and brand owners. While companies can outsource the role of manufacturing, they cannot outsource the responsibility of managing the extended supplier network. This is one of the many challenges the industry now faces.
Delivering Reliable and Affordable Wind O&M TechnologyWind Energy Update
Delivering technology that will increase reliability and lower costs is fundamental. So we asked 3 technology experts at Broadwind Energy, Romax Technology and Moventas to provide exclusive insight on Delivering Reliable and Affordable Wind O&M Technology
They discuss the effects of the changing O&M market, how they are innovating to drive down costs and which new technologies will change the way we monitor our assets, optimize performance and increase reliability.
On August 22, 2012 the Securities and Exchange Commission (SEC) adopted a new rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires publicly-traded companies in the United States to report the use of “Conflict Minerals”. Under the rule, Conflict Minerals are cassiterite, columbite-tantalite, gold woframite and their derivatives which have been limited to tantalum, tin and tungsten (collectively known as the 3Ts), that are sourced from mines in the Democratic Republic of the Congo (DRC) or surrounding countries (collectively known as the “Covered Countries”.)
While the reporting requirements only apply to publicly traded companies, it also impacts any company supplying a company that is required to report since publicly-traded companies are requiring their suppliers to support their due diligence efforts.
This paper looks at Conflict Minerals regulations from the perspective of a company in the electronics manufacturing services (EMS) in terms of the processes necessary to support disclosure requirements and the likely support services needed over time.
For more whitepapers and articles on PCBA design and manufacturing, visit http://blog.optimumdesign.com
Conflict Minerals: Understanding Dodd-Frank 1502 and Its Affect on Your Suppl...Optimum Design Associates
On August 22, 2012 the Securities and Exchange Commission (SEC) adopted a new rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires publicly-traded companies in the United States to report the use of “Conflict Minerals”. Under the rule, Conflict Minerals are cassiterite, columbite-tantalite, gold woframite and their derivatives which have been limited to tantalum, tin and tungsten (collectively known as the 3Ts), that are sourced from mines in the Democratic Republic of the Congo (DRC) or surrounding countries (collectively known as the “Covered Countries”.)
While the reporting requirements only apply to publicly traded companies, it also impacts any company supplying a company that is required to report since publicly-traded companies are requiring their suppliers to support their due diligence efforts.
This paper looks at Conflict Minerals regulations from the perspective of a company in the electronics manufacturing services (EMS) in terms of the processes necessary to support disclosure requirements and the likely support services needed over time.
For more whitepapers and articles on PCBA design and manufacturing, visit http://blog.optimumdesign.com
This guide is intended to provide a concise summary of the TCPA statute and related regulations, and explain the new rules and their known impacts on enterprises (the organizations making the outbound contact) and recipients (people on the receiving end of the interactions). A lack of clarity in the regulations has driven organizations with the financial means to hire legal firms to assist them in interpreting the rules. Companies without the financial resources for legal counsel are looking for guidance. No one knows whether their interpretation is correct, and the case law, which is addressed in Section 2.1 of this Guide, further confounds the market, as each case seems to involve a different facet of the regulations and how they are applied.
Supply Chain Metrics That Matter - A Focus on Contract Manufacturing - 13 AUG...Lora Cecere
Executive Overview
Growth is stalled. Margin pressure is high. Shorter life cycles, as well as increasing compliance and regulatory pressure, provide additional challenges to the contract manufacturing industry. Finally, excess capacity is a significant problem. Is this a recipe for opportunity or a disaster for the brand owner using outsourced manufacturing partners? We think the latter.
Over the last decade, brand owners from consumer electronics to medical devices have grown more dependent on outsourced contract manufacturing. In fact, the contract manufacturing industry grew up out of a desire to mitigate risk and improve costs for brand owners. However, the market has shifted significantly in recent years and the contract manufacturing industry is struggling. As a result, they pose a risk to brand owners. In this report, we illustrate how the lack of resiliency affecting contract manufacturers represents a serious risk to brand owners and offer advice on what can be done to mitigate the problem.
Over the last decade, many contract manufacturers have attempted to differentiate services and refine their business model to gain competitive advantage. However, in looking at the financial results, we find that most companies are struggling. As a result, it is time to redesign the business model and relationships of contract manufacturers and brand owners. While companies can outsource the role of manufacturing, they cannot outsource the responsibility of managing the extended supplier network. This is one of the many challenges the industry now faces.
Delivering Reliable and Affordable Wind O&M TechnologyWind Energy Update
Delivering technology that will increase reliability and lower costs is fundamental. So we asked 3 technology experts at Broadwind Energy, Romax Technology and Moventas to provide exclusive insight on Delivering Reliable and Affordable Wind O&M Technology
They discuss the effects of the changing O&M market, how they are innovating to drive down costs and which new technologies will change the way we monitor our assets, optimize performance and increase reliability.
This presentation shows different ways companies can comply to conflict minerals legislation. Posted with permission from Ron Jones of N-Able Group International who presented on this topic in November 2013.
Confirmations are an essential component of derivative transactions and a demanding regulatory environment has left the industry facing significant mandatory change.
As in house lawyers you’re ultimately responsible for the reputation of your business. This update seminar looked at various areas of law and at your role in protecting that reputation in the following areas:
- Data Protection – now that GDPR and (just in time) the Data Protection Act 2018 is in force – what have we seen since implementation? What does the recent case law and last minute ICO guidance tell us about how to deal with data? How can you best protect and prepare your business for data breaches. How should you best deal with suppliers, sub-contractors and others in order to keep your business out of the headlines?
- Employment – dealing with reputational risk and contractors, IR35 and self-employment. What do you need to do, to do right by your employees and contractors?
- Influencer marketing – with social media 'influencers' and 'brand ambassadors' being the latest in marketing ploys – what do agreements with them look like and what risks do they pose to you as a brand and under advertising law and data protection legislation?
- Vicarious liability – following the Barclays case – when are you liable for people who do work for you – whether or not they are employed by you?
- Public/private engagement – based on research by CBI and in the light of the recent changes - how best can private business engage with public sector opportunities? Where’s the reward and what’s the risk – should you be looking at this area?
Commercial insurance risk and liability review, February 2016Browne Jacobson LLP
Our annual review provides a comprehensive review of some of the most important judgments and legal developments during 2015 and our analysis of some of the changes on the horizon for 2016 and beyond. We have covered a lot of ground this year so I hope you will be able to find a number of updates that are relevant and useful to you.
If you would like to know more about any of the topics, please feel free to contact any of the authors of the articles.
https://www.brownejacobson.com/insurance/training-and-resources/legal-updates/2016/01/commercial-insurance-risk-and-liability-review-2015-2016
EU Conflict Minerals Update -- Amnesty International Report ReviewMatt Whitteker
UPDATE - Due to recent results in the EU Parliament's vote on EU Conflict Minerals, Assent Compliance will be adding a Summary of the decision along with Impacts and Timelines.
Assent Compliance will be hosting a free, 30 minute webinar on Tuesday May 26th, to address the recent EU Conflict Minerals vote and analyze the recently released Amnesty International & Global Witness report called Digging for Transparency.
The EU Conflict Minerals Vote has laid down some drastic changes over the originally proposed Voluntary measures, including:
- Mandatory rules for all 880,000 EU Manufacturer's that use 3TGs
- Global scope that far exceeds the DRC region
Assent Compliance will help you understand the latest on EU Conflict Minerals by addressing the following items:
- Potential Impact of the Rules
- Next Steps
The Amnesty International report makes several claims against industry's efforts towards Conflict Minerals including:
- 80% of companies have failed to meet the minimum requirements of the US Conflict Minerals Law
- Only 16% are going adequately mapping their Supply Chain
- More than 50% of companies do not report risks to Senior Management
This report has set of alarms for many companies impacted by the law and caused them to re-examine their efforts for 2015.
Why Companies Succeed.
Assents CEO presents an insightful look on why companies succeed. Relying on chance alone is not a strategy.
http://www.assentcompliance.com
Reach webinar additional information assent april 2015Matt Whitteker
A possible new interpretation for Articles is on the table but that is not all... There are important lists and annexes associated with REACH compliance that keep updating.
We will review:
• CoRAP - 134 Substance Evaluations
• Restriction Proposal Decisions
• Authorisation Applications
• Registry of Intentions
• Proposed SVHCs
• Recommendations for the Authorization List
We will discuss how these changes affect you and your products. We'll also ensure you know what to focus on and some key tips to practically handle REACH Compliance.
More Related Content
Similar to Conflict Mineral Compliance - Frequently Asked Questions
This presentation shows different ways companies can comply to conflict minerals legislation. Posted with permission from Ron Jones of N-Able Group International who presented on this topic in November 2013.
Confirmations are an essential component of derivative transactions and a demanding regulatory environment has left the industry facing significant mandatory change.
As in house lawyers you’re ultimately responsible for the reputation of your business. This update seminar looked at various areas of law and at your role in protecting that reputation in the following areas:
- Data Protection – now that GDPR and (just in time) the Data Protection Act 2018 is in force – what have we seen since implementation? What does the recent case law and last minute ICO guidance tell us about how to deal with data? How can you best protect and prepare your business for data breaches. How should you best deal with suppliers, sub-contractors and others in order to keep your business out of the headlines?
- Employment – dealing with reputational risk and contractors, IR35 and self-employment. What do you need to do, to do right by your employees and contractors?
- Influencer marketing – with social media 'influencers' and 'brand ambassadors' being the latest in marketing ploys – what do agreements with them look like and what risks do they pose to you as a brand and under advertising law and data protection legislation?
- Vicarious liability – following the Barclays case – when are you liable for people who do work for you – whether or not they are employed by you?
- Public/private engagement – based on research by CBI and in the light of the recent changes - how best can private business engage with public sector opportunities? Where’s the reward and what’s the risk – should you be looking at this area?
Commercial insurance risk and liability review, February 2016Browne Jacobson LLP
Our annual review provides a comprehensive review of some of the most important judgments and legal developments during 2015 and our analysis of some of the changes on the horizon for 2016 and beyond. We have covered a lot of ground this year so I hope you will be able to find a number of updates that are relevant and useful to you.
If you would like to know more about any of the topics, please feel free to contact any of the authors of the articles.
https://www.brownejacobson.com/insurance/training-and-resources/legal-updates/2016/01/commercial-insurance-risk-and-liability-review-2015-2016
EU Conflict Minerals Update -- Amnesty International Report ReviewMatt Whitteker
UPDATE - Due to recent results in the EU Parliament's vote on EU Conflict Minerals, Assent Compliance will be adding a Summary of the decision along with Impacts and Timelines.
Assent Compliance will be hosting a free, 30 minute webinar on Tuesday May 26th, to address the recent EU Conflict Minerals vote and analyze the recently released Amnesty International & Global Witness report called Digging for Transparency.
The EU Conflict Minerals Vote has laid down some drastic changes over the originally proposed Voluntary measures, including:
- Mandatory rules for all 880,000 EU Manufacturer's that use 3TGs
- Global scope that far exceeds the DRC region
Assent Compliance will help you understand the latest on EU Conflict Minerals by addressing the following items:
- Potential Impact of the Rules
- Next Steps
The Amnesty International report makes several claims against industry's efforts towards Conflict Minerals including:
- 80% of companies have failed to meet the minimum requirements of the US Conflict Minerals Law
- Only 16% are going adequately mapping their Supply Chain
- More than 50% of companies do not report risks to Senior Management
This report has set of alarms for many companies impacted by the law and caused them to re-examine their efforts for 2015.
Why Companies Succeed.
Assents CEO presents an insightful look on why companies succeed. Relying on chance alone is not a strategy.
http://www.assentcompliance.com
Reach webinar additional information assent april 2015Matt Whitteker
A possible new interpretation for Articles is on the table but that is not all... There are important lists and annexes associated with REACH compliance that keep updating.
We will review:
• CoRAP - 134 Substance Evaluations
• Restriction Proposal Decisions
• Authorisation Applications
• Registry of Intentions
• Proposed SVHCs
• Recommendations for the Authorization List
We will discuss how these changes affect you and your products. We'll also ensure you know what to focus on and some key tips to practically handle REACH Compliance.
Stock Price and Business Case for ComplianceMatt Whitteker
Assent's latest research paper attempts to clarify the relationship between companies’ environmental compliance strategies, and their profitability (as measured by their stock prices). An independent analysis—performed by two prestigious U.S. institutions: consulting firm Watermark Advisors, and Vanderbilt University’s Owen Graduate School of Management—examined the performance of one hundred publicly traded companies (Assent Customers). As Assent customers, these companies had all invested significantly in their compliance programs.
- Did Their Stock Price Outperform the Market at Large?
- How Much or How Little?
- What Latent Functions Could Investing in Compliance Cause?
- Why Should Companies Invest Vs Do the Bare Minimum?
- What Conclusions Can we Draw About Investing in Compliance.
The European Chemicals Agency (ECHA) updated the SVHC Candidate List on December 17th, 2014. This update added 6 substances to the current substance of very high concern list. This brings the total number of SVHC’s to 161. What does this mean for your products, your company and your compliance team? Assent is hosting a free webinar to examine the full spectrum of implications on Jan 21st, 2015.
CMRT (Conflict Minerals Reporting Template) Data Validation Matt Whitteker
CMRT (Conflict Minerals Reporting Template) Data Validation is the second subject covered in Assents Conflict Mineral 2015 Webinar Series. For information about Conflict Mineral Compliance visit: http://www.AssentCompliance.com
Conflict Minerals Survey -- Tulane University Matt Whitteker
In a follow up survey of companies effected by Dodd Frank Section 1502 Chris Bayer of Tulane university conducted a thorough industry bench-marking survey. The results are broken down in sections:
Profile of affected companies
Internal company resources utilized
External resources utilized
Cost summary
Synergies
Market impact
Good practices
It’s encouraging to note that Assent Compliance was listed as a global top 3 provider of conflict mineral compliance software in terms of adoption rate. A huge thank you to all the Assent customers and suppliers that exchange data on our platform.
You can download the full survey here: Conflict Minerals Survey — Tulane Post Filing
Need a hand with anything compliance related? Email us at Info@AssentCompliance.com
Advancing Compliance Assurance and EHS Management Systems Matt Whitteker
At Assent we’re very active in the compliance community. One of the industry associations we are a proud member and sponsor of is The National Association of EHS Managers (NAEM). It is the largest professional community for corporate environmental, health and safety, and sustainability decision-makers. Assent recently attended NAEM’s Advancing Compliance Assurance and EHS Management Systems conference and was able to get some great insights into the topics affecting compliance and EHS managers today. Here was the agenda: http://ehscompliance.naem.org/agenda.php
RoHS Exemption List - Review By: Assent Compliance Matt Whitteker
www.assentcompliance.com
Assent Compliance outlines the RoHS exemption list and associated information. Assent Compliance provides companies with RoHS support and software services. If you need a hand with anything compliance related please email info@assentcompliance.com
REACH Regulation - Frequently Asked Questions Matt Whitteker
http:/www.AssentCompliance.com
Assent Compliance examines the frequently asked questions around the EU REACH regulation.
What is REACH?
How does it apply to me?
What are SVHC's ?
Does the REACH List change?
And many other important questions examined. Need a hand with REACH Compliance? Email info@assentcompliance.com
CMRT 3.01 - Comparison To The EICC Gesi Template Matt Whitteker
http://www.assentcompliance.com
Assent reviews in full detail the differences between the CMRT 3.01 (conflict minerals reporting template) and the EICC Gesi template. The CMRT has officially replaced the EICC Gesi as the industry accepted standard. Do you know the difference? Here is the full breakdown.
Need a hand with anything compliance related? Email: info@assentcompliance.com
www.assentcompliance.com Assent Compliance looks at psychological mechanisms to improve supplier conversion rates around product compliance and data collection. This unique spin on classic psychology research takes readers through a variety of studies and their application to supply chain. Visit http://www.assentcompliance.com or email info@assentcompliance.com for more information.
Conflict Mineral Compliance Toolkit For Executives Matt Whitteker
Assent Compliance was the only software vendor that the SEC consulted with when passing the Conflict Minerals legislation. Assent has been on the ground floor and has been able to work with over 20% of S&P 500 companies in scope of the law. We've compiled this Ebook to assist with companies that need to comply. This is a play book with everything you need to know. If you want more information visit http://www.assentcompliance.com or email info@assentcompliance.com
Product Compliance Software Vendor Sourcing Guide Matt Whitteker
Choosing a Product Compliance Software / Services Vendor can be a daunting prospect. At Assent we've made things easy with the following guide. We look at best practices, different service, business models and give you an indepth look at how to source a product compliance vendor for software and services.
CMRT 3.01 Different Between EICC - Gesi Form Matt Whitteker
The CMRT 3.01 form has replaced the previous EICC Gesi form for conflict mineral reporting. The CMRT 3.01 is now the industry standard reporting form. This presentation by Assent Compliance outlines the differences between the previous template and the new one. If you need any help with conflict minerals compliance or would like clarification on this document please do not hesitate to contact info@assentcompliance.com or visit at http://www.assentcompliance.com
RoHS II Compliance Presentation - Assent ComplianceMatt Whitteker
Assent Compliance hosted a free webinar on January 29th, covering RoHS II Compliance and the changes you will need to implement within your existing RoHS program in order to achieve compliance.
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o Exemption Expirations
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Conflict Mineral Compliance - Frequently Asked Questions
1. [ INFO@ASSENTCOMPLIANCE.COM WWW.ASSENTCOMPLIANCE.COM TEL: 1 (866) 964-6931 ] /1
The Dodd-Frank Act was a regulation passed by the Obama administration following the economic
housing collapse that took place in the United States. The act was set to increase liability among
companies and to prevent another collapse due to unethical business practices. This includes
regulations on financial reporting as well as ethical business standards. Although this act only covers
publically traded companies, everyone who does business with a public company is affected, as these
standards spiral down the chain of production.
CONFLICT MINERALS
FREQUENTLY ASKED QUESTIONS
2. /2
TABLE OF CONTENTS
1. What is the Dodd–Frank Wall Street Reform and Consumer Protection Act and how does it
relate to me? ................................................................................................................................................3
2. What are Conflict Minerals? How do they relate to me? ....................................................................3
3. We are a private company, how does this apply to us? .......................................................................4
4. How do I collect this data from my suppliers? What is an EICC-GeSI form? ..................................4
5. What is the CMRT? How is it different from the EICC-GeSI? ..............................................................5
6. What is a declaration of scope? Which one should I declare my 3TG sourcing with? ............... 6
7. What are Smelters? How do they play a role? ..................................................................................... 7
8. When is all this information needed by? ................................................................................................7
9. We do not use 3TGs – why do I have to complete the CMRT? .........................................................7
10. We do not use conflict minerals – why do I have to complete the CMRT? .....................................8
11. All we have is a company declaration – what do I do? .......................................................................8
12. I don’t know if these minerals can be found in my products – what do I do? ................................9
13. We do not do business with the client you have noted in your communications to us – why are
you contacting us? ......................................................................................................................................9
14. This doesn’t apply to us/ we are out of scope – why is Assent contacting us? ..........................10
[ INFO@ASSENTCOMPLIANCE.COM WWW.ASSENTCOMPLIANCE.COM TEL: 1 (866) 964-6931 ]
3. /3
1. WHAT IS THE DODD–FRANK WALL STREET RE-FORM
AND CONSUMER PROTECTION ACT AND
HOW DOES IT RELATE TO ME?
The Dodd-Frank Act was a regulation passed by the Obama administration following the
economic housing collapse that took place in the United States. The act was set to increase
liability among companies and to prevent another collapse due to unethical business practices.
This includes regulations on financial reporting as well as ethical business standards.
Although this act only covers publically traded companies, everyone who does business with
a public company is affected, as these standards spiral down the chain of production.
2. WHAT ARE CONFLICT MINERALS? HOW DO THEY
RELATE TO ME?
Included in the Dodd-Frank Act was a section pertaining to Conflict Minerals (Section 1502).
Conflict Minerals are: (A) columbite-tantalite, also known as coltan (the metal ore from which
tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite
(the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or
its derivatives determined by the Secretary of State to be financing conflict in the Democratic
Republic of the Congo or an adjoining country.
More easily understood; Conflict Minerals are 3TGs (Tin, Tantalum, Tungsten and Gold) that
are found to be financing conflict in the Democratic Republic of Congo (DRC) or an adjoining
[ INFO@ASSENTCOMPLIANCE.COM WWW.ASSENTCOMPLIANCE.COM TEL: 1 (866) 964-6931 ]
4. /4
country1 (collectively known as the “Covered Countries”). The Dodd Frank Act requires that
all publically traded companies investigate and report the sourcing for their 3TGs. It also
requires that all suppliers to those companies participate in the collection of this data.
3. WE ARE A PRIVATE COMPANY, HOW DOES THIS
APPLY TO US?
Although the Dodd Frank Act does not apply to private institutions, it does affect publically
traded companies. As a result; even though you may not be required to report 3TG sourcing,
it is a requirement that you provide this information to your customers who are publically
traded. It is recommended that all companies begin to investigate the sourcing of their 3TGs
in order meet the requirements of doing business with publically traded companies.
4. HOW DO I COLLECT THIS DATA FROM MY
SUPPLIERS? WHAT IS AN EICC-GESI FORM?
Companies can choose to collect the required data by questioning their suppliers on 3TG
sourcing. This can be done by using the EICC-GeSI form; which is considered the standard
on communicating the necessary data for meeting the regulatory requirements surrounding
Conflict Minerals. The EICC form allows for companies to communicate whether or not 3TGs
are used in their products and where they originate from.
1 A country that shares an internationally recognized border with the DRC, which presently includes Angola, Burundi,
Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia
[ INFO@ASSENTCOMPLIANCE.COM WWW.ASSENTCOMPLIANCE.COM TEL: 1 (866) 964-6931 ]
5. /5
5. WHAT IS THE CMRT? HOW IS IT DIFFERENT
FROM THE EICC-GESI?
The latest round of revisions to the EICC GeSI Conflict Minerals reporting template has been
released – for the 2014 reporting year the version has moved to 3.0X. As of July 2014, Version
3.01 is the most current. The EICC GeSI Conflict Minerals Reporting Template is now referred
to as CMRT and was previously known as the EICC GeSI. CMRT 3.0X was designed to better
synchronize the CFSI CMRT data fields with the current IPC-1755 Standard.
The CMRT 3.01 has seen major changes including the following:
1. Addition of new company information fields.
2. Two additional 3TG sourcing questions and removal of one.
3. Minor changes to question text throughout.
4. Expansion of instructions and definitions.
5. Updated translations of all modified text.
6. Updated smelter information including new smelter ID’s
The company information field has changed in addition to the original six questions from
v2.03a based on declaration scope have had text changes as well as the company level
policy questions plus one question added, and now comprises seven questions for v3.00.
A comparison of the old versus new questions can be seen in the Assent Document –
Comparison of the EICC GeSI 2.03 and CMRT 3.0.
[ INFO@ASSENTCOMPLIANCE.COM WWW.ASSENTCOMPLIANCE.COM TEL: 1 (866) 964-6931 ]
6. /6
6. WHAT IS A DECLARATION OF SCOPE? WHICH ONE
SHOULD I DECLARE MY 3TG SOURCING WITH?
Declaration of scope is found at the top of the EICC-GeSI form, it’s what allows manufactures/
suppliers to declare what products are being covered with this specific form. Products can be
declared using the following:
Company Level: This covers all parts manufactured by the company in question. The upside
to this form of declaration is that you can have a standard form to provide to all your customers
should they inquire about your 3TG sourcing.
Product Level: This last level is on a part-by-part basis. The benefit of this declaration of
scope is that it will give the highest overall percentage of completion based on the fact your
concentrating your efforts overall. However the downside to this level is that it is customized
for every customer.
User Defined: Previous versions of the form allowed users to choose between Product
Category and Division Level declarations of scope. This caused a great level of confusion from
manufacturers as they weren’t sure what scope to select. In order to avoid confusion this year,
the CMRT has been updated to include a user defined scope that will allow manufacturers to
lay out the definitions of their scope.
[ INFO@ASSENTCOMPLIANCE.COM WWW.ASSENTCOMPLIANCE.COM TEL: 1 (866) 964-6931 ]
7. /7
7. WHAT ARE SMELTERS? HOW DO THEY PLAY A ROLE?
Smelters are organizations that purchase raw materials from mines or recyclers/scrap
suppliers and melt them down for use in production. Manufacturers that use 3TGs at some
point within the supply chain have to purchase the metals from a smelter. In turn, the smelter
becomes the perfect organization to audit in order to determine if a metal is “Conflict Free”;
as they have direct access to the mines that extract the metals in question.
8. WHEN IS ALL THIS INFORMATION NEEDED BY?
Conflict Minerals reporting is due by May 30th of each year for the previous calendar year (ie.
May 30th 2015 filing deadline is based on 2014 data). By then publically traded companies are
expected to have gathered information as well as have had a level of due diligence to review
the answers given by their suppliers. Assent compliance, on behalf of its clients requires
you to provide whatever level of information has been gathered at the time of the request.
It is also important you provide updates to that information as they become available. Your
customers need to have 100% of their supply chain information as soon as possible.
9. WE DO NOT USE 3TGS – WHY DO I HAVE TO
COMPLETE THE CMRT?
If it’s the case where your products do not contain any conflict minerals, please complete
the following information fields required on the CMRT 3.01 that are designated by yellow
highlighting: the company information section and both the first and second questions.
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8. /8
Selecting no to these questions confirms that as a supplier you are not sourcing 3TGs from
conflict mines. Once selected, the form will autocomplete and the remaining fields will be
“closed off”. Please submit this on our launch portal once you are completed.
10. WE DO NOT USE CONFLICT MINERALS – WHY DO
I HAVE TO COMPLETE THE CMRT?
Do you not use tin, tungsten, tantalum or gold in your products at all or are you referring to the
fact you do not source these minerals originating from the DRC?
• If you do not use tin, tungsten, tantalum or gold, see above for the response for “We do
not use 3TGs”.
• If you do not source from the DRC, you must complete the CMRT 3.01 form as it is the
acceptable and standard format for a supplier to declare their position on this.
11. ALL WE HAVE IS A COMPANY DECLARATION –
WHAT DO I DO?
The industry standard for this regulation is the CMRT 3.01. This is the template we use as
it allows us, on behalf of your customer, to compile the necessary information gathered in
regards to 3TG sourcing within your company. The purpose of this CMRT 3.01 is to be passed
along the supply chain to the point that identifies the smelters used to refine or smelt the
minerals, a critical part of identifying conflict free sourcing. Unfortunately a declaration does
not give us the level of detail required.
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12. I DON’T KNOW IF THESE MINERALS CAN BE
FOUND IN MY PRODUCTS – WHAT DO I DO?
You would need to gather this information from your suppliers. This can be done by passing
along a CMRT 3.01 template, which is considered the standard form for collecting 3TG
sourcing and process information. You would survey your suppliers with this form to identify
if any conflict minerals are present in your supply chain.
13. WE DO NOT DO BUSINESS WITH THE CLIENT
YOU HAVE NOTED IN YOUR COMMUNICATIONS
TO US – WHY ARE YOU CONTACTING US?
You may do business with one of our client’s individual business units, which may have
a different name. Please submit your question to the account manager listed in the
communication you received from Assent.
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10. /10
14. THIS DOESN’T APPLY TO US/ WE ARE OUT OF
SCOPE – WHY IS ASSENT CONTACTING US?
If the product you supply to the customer falls into one of the following categories that are
usually considered as out of scope, please submit this information to the account manager
listed in the communication you received from Assent.
Possible out of scope categories:
• Packaging that does not end up in the final product that the customer uses. Please note
that if the label is on the actual product it can be considered as part of the final product.
• Parts that do not end up in the final product. This would include equipment used to
make the product materials or components, but not a part of the actual product itself.
• Test Labs that will test resistance or durability of a product.
• Service Providers such as couriers, delivery companies, staffing agencies, accounting
firms, consultants, law firms, software firms, restaurants or bars.
• Other Company items such as forklifts or office supplies that do not physically go into
the products or services such as electricians and plumbers.
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