The Electronic Industry Citizenship Coalition® (EICC®) and the Global e-Sustainability Initiative (GeSI) created the conflict minerals reporting template (the Template) as a common means for the collection of sourcing information related to “Conflict Minerals”. This template has been in circulation from the development and passing of Section 1502 of the Dodd-Frank Act through to the passing of the SEC’s final rules on Conflict Minerals this past August.
Companies (both in the electronics industry and beyond) can adopt this Template as an element of their due diligence program to verify the responsible sourcing of materials and to support compliance to section 1502 and, more specifically, the SEC Final Rules. Additionally, this template is consistent with EICC and GeSI’s related activities including the Conflict Free Smelter (CFS) Program.
Although the original set an excellent standardized framework for companies to move through the Conflict Minerals compliance process – the data gathering step, known as the RCOI or Reasonable Country of Origin Inquiry – in practice, as with all practical compliance processes, there were lessons learned, possible improvements arose and a new revision was born.
Revision 2 of the Template does not stray far from the original but there are key changes to note:
1) In the company information section at the top, there are 2 new questions, a few fields removed and some small wording adjustments:
A)“Declaration Scope” – which is a simple drop-down now allowing companies to choose exactly to what level this declaration applies:
i. Company Level
ii. Division Level
iii. Product Category Level
iv. Product Level
B)“Description of Scope” – This field allows for specification to be provided based on the scope chosen.
i. Company Level – does not require any further explanation
ii. Division and Product Category Level – needs to be explained as this can vary immensely company to company
iii. Product Level – the user needs to input the following info on a newly created tab “Product List”:
a. Product/Item Number
b. Product/Item Description
C) Contact Name, Email and Phone have been removed as those seemed not to be used fields (i.e. The contact and the authorized representative are one and the same in the vast majority of cases)
D) Authorized Management Representative is now Authorized Company Representative Name
2) There has also been a question moved and further wording changes in the Minerals-related section:
A) They have moved a question from the Corporate level questions, to the Minerals-related questions section:
“4) Have you received completed Conflict Minerals Reporting Templates from all of your suppliers? (*)”
B) With that move, other questions have shifted downward in the order and the wording on the shuffled questions 5 and 6 (formerly 4 and 5) has been updated to provide better specificity; the wording changes do not change the objective of the questions.
3) In the final section of the declaration form, required to be answered at a company level no matter the scope chosen, the wording on questions D, E, I and K has also been finely-tuned.
4) Perhaps most noticeable is that there are new tabs:
A) Standard Smelter Names – to assist companies in filling out the Smelter List tab that has always been included
B) Checker – Allows for verification that all needed sections are complete before submission to the requester
C) Product List – Tied to the description of scope field in the Company Information section (section 1) of the declaration form.
This Template is an essential component of the Conflict Minerals data gathering step – the Reasonable Country of Origin Inquiry (RCOI). Assent has this Template fully incorporated into our software and our compliance services.
Assent Compliance offers a turnkey Conflict Mineral Compliance service including Conflict Minerals Scope Assessments, Conflict Minerals Reasonable Country of Origin Inquiry, Conflict Minerals Reports, and Conflict Minerals Software.