The Number One Software for Conflict Minerals Compliance & Reporting

What are conflict minerals and the 3TGs?

Conflict Minerals refer to raw materials or minerals that come from a particular part of the world where conflict is occurring and affects the mining and trade of those materials and resources.

The so called 3TGs are tin, tantalum, tungsten and gold which are often mined in eastern Congo (DRC) or adjoining countries.

Central problem of conflict minerals?

In a resource-rich country without sufficient state control, armed groups create a financial basis for themselves by exporting raw materials.

Their systematic exploitation can lead to serious human rights violations, violations of international humanitarian law or the realization of international criminal law.

A major difficulty is obtaining the necessary information on conflict commodities in supply chains, components, and products to effectively prevent their trafficking.
 

Learn More About Conflict Minerals

How do conflict minerals affect companies?

There is legislation on conflict minerals in both the United States and the European Union. While the details differ, both aim to promote responsible sourcing of tin, tantalum, tungsten, and gold (3TG) and to break the link between mineral trade, armed conflict, and human rights abuses.
 

United States: Dodd-Frank Act (Section 1502)

According to Dodd-Frank Act (Section 1502) publicly traded companies in the U.S. must determine whether 3TGs used in their products originate from the Democratic Republic of the Congo or neighboring countries. If so, they must file an annual Form SD with the Securities and Exchange Commission (SEC), including due diligence details and, in some cases, an independent third-party audit.

Even companies not listed in the U.S. can be affected: if they supply publicly traded U.S. companies, they may be asked to provide conflict minerals data, as reporting requirements are passed down the supply chain.
 

European Union: EU Conflict Minerals Regulation

Since January 1, 2021, EU-based importers of 3TG exceeding specific annual thresholds must conduct supply chain due diligence, assess sourcing risks from conflict-affected and high-risk areas (CAHRAs), and publish their findings. The EU Conflict Minerals Regulation follows the OECD Due Diligence Guidance and makes responsible sourcing a legal obligation for affected importers.

What is Cobalt?

Cobalt was first used for heat-resistant paints and pigments, e.g. for painting porcelain and ceramics. Today, cobalt is used as an alloying component to increase the high-temperature strength of alloyed and high-alloy steels, as a binder phase in hard metals and diamond tools.

Cobalt steels are used, for example, for highly stressed components that have to withstand high temperatures, such as valve seat inserts in internal combustion engines. Cobalt-based superalloys have historically consumed most of the cobalt produced. The temperature stability of these alloys makes them suitable for gas turbine blades and aircraft engines.

Furthermore, cobalt is used in lithium-ion batteries, which are an essential component of electric cars, among other things. It can therefore be assumed that demand for cobalt will increase significantly in the coming years.

Central problem of Cobalt production?

As with many other ores, mining is partly carried out under precarious conditions. Several reports have raised concerns about the social and environmental impacts of cobalt mining, including child labor, modern slavery unsafe working conditions.

It is estimated that in Congo, where a good half of the world's cobalt is mined, around 20% of the cobalt is mined by hand.
 

What is Mica?

Mica is a group of minerals commonly used in a variety of industries due to its excellent insulation properties, flexibility, and resistance to heat. It is widely used in electrical and electronic equipment as an insulator and dielectric material, in the automotive and aerospace industries for thermal management, and in cosmetics for its shimmering properties.

In the construction industry, mica is used in paints, coatings, and joint compounds to improve durability and provide a glittery appearance. It is also utilized in plastics and rubber as a filler and reinforcement material, enhancing the mechanical properties of these products.

Mica's versatility and wide range of applications ensure its continued demand across various sectors, making it a critical mineral in modern manufacturing and technology.
 

Central Problem of Mica Production?

Mica mining often occurs under challenging and hazardous conditions, particularly in regions with limited regulatory oversight. Reports have highlighted significant social and environmental issues associated with mica production, including child labor, exploitation, and unsafe working conditions.

In countries like India and Madagascar, where much of the world's mica is sourced, a substantial portion of the mining is done by hand, involving entire families, including children. This informal and unregulated sector is prone to human rights abuses and environmental degradation, raising serious ethical and sustainability concerns.

Is Cobalt reporting mandatory for companies?

Cobalt reporting is currently not required by any international legislation or regulation. According to the definition provided in the SEC Final Ruling (US Securities and Exchange Commission, 2012), as it relates to Section 1502 of the Dodd-Frank Wall Street  Reform and Consumer Protection Act of 2010 (US Congress, 2010), Cobalt is NOT a conflict mineral.

Why is voluntary cobalt reporting important for companies?
Companies need to keep pace with the market expectations of customers, investors and non-governmental organizations. Furthermore, companies can thus highlight their corporate responsibility.

What is the The RMI Reporting Framework?

The RMI Reporting Framework is a standardized set of guidelines and metrics developed by the Responsible Minerals Initiative to help companies report on their responsible sourcing practices for minerals. Additionally, the RMI provides specific reporting templates to streamline and standardize the reporting process.

Conflict Minerals Reporting Template (CMRT)

The Conflict Minerals Reporting Template (CMRT) is a standardized reporting tool developed to facilitate the disclosure and communication of information regarding mineral sourcing in compliance with regulatory requirements. Companies use the CMRT to report on the origin and supply chain of conflict minerals, ensuring transparency and responsible sourcing practices. The template guides users through a series of questions and data fields, helping them collect and report detailed information about the smelters and refiners in their supply chain. By using the CMRT, companies can effectively communicate their due diligence efforts to customers and stakeholders.

> To the Conflict Minerals Reporting Template
 

Extended Minerals Reporting Template (EMRT)

For Cobalt and Mica reporting, you can use the Extended Minerals Reporting Template (EMRT). The EMRT helps you collecting information about the country of origin and the smelters and refiners used.

For your cobalt reporting, you need to examine the supply chain in terms of smelter and refiner usage. To do this, you will need to communicate your company's requirements to your suppliers and collect data using the EMRT. Once the data is collected, you need to analyze it to determine the risk level of the smelters and refiners used in your supply chain.

> To the Extended Minerals Reporting Template

Additional Minerals Reporting Template

For reporting on additional minerals, you can use the Additional Minerals Reporting Template (AMRT). The AMRT helps you gather information about the country of origin and the smelters and refiners used in your supply chain for minerals beyond 3TG, such as lithium, nickel, rare earth elements, and other critical raw materials.

To ensure responsible sourcing, you need to assess the supply chain for these minerals by identifying the smelters and refiners involved. This requires communicating your company’s compliance requirements to suppliers and collecting data using the AMRT. Once the data is gathered, it must be analyzed to assess potential supply chain risks and ensure compliance with regulatory and industry standards.

> To the Additional Minerals Reporting Template

Our software iPoint Conflict Minerals helps you manage these individual steps in a central application along with your Conflict Minerals reporting.