Leverage APA’s global compliance expertise to meet with Conflict Minerals regulations

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What are Conflict Minerals?

Minerals that are sourced from conflict zones like Republic of Congo (DRC). There are 4
minerals that every downstream and upstream manufacturing companies should avoid and
are often referred as 3TG

Tantalum

Tin

Tungsten

Gold

US Congress passed the ‘Dodd-Frank Act’ in 2010 that stated –companies listed in SEC should
disclose whether they use conflict minerals in their products.

Conflict Minerals in the US and Europe

US Europe
Target minerals 3TG (tantalum, tin, tungsten and gold) 3TG (tantalum, tin, tungsten and gold)
Extracted source? Minerals mined and refined in the Democratic Republic of the Congo Zone Cover minerals mined from conflict-affected and high-risk areas, which could include any country that produces minerals
Applicable to? Company trades on US exchange EU-established importers of the targeted minerals
Effect from In effect January 2021

The intention of both U.S law and EU law is to ensure importers of 3TG (tin, tungsten, tantalum and gold) should meet international responsible sourcing standards, defined by the Organisation for Economic Co-operation and Development (OECD).

Business challenges with Conflict Minerals Compliance

  • 01.

    Finding alternative for 3TG minerals

  • 02.

    Gaps in traceability

  • 03.

    Lack of proper documentation

  • 04.

    Finding responsible smelters and refiners

  • 05.

    Supply chain due diligence

Knowledge Hub

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What are Conflict Minerals?

A free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that has information regarding country of origin and the smelters and refiners being utilized.

APA Conflict Minerals Services

  • Consultation & Strategy development
  • Conflict Minerals Compliance Plan
  • Compliance Reporting
  • Supply Chain due diligence

What do you get when you partner with APA

  • Complete due diligence of CMRT and CRT
  • Analysis, interpretation and documentation of compliance data
  • Software tool to automate the compliance process
  • Conflict minerals data acquisition from supply chain
  • Assist customers in identifying the Reasonable Country of Origin (RCOI)
  • Conflict Minerals report preparation for submission to their customers or SEC

CM-CS: Conflict Minerals Compliance Suite Software

Benefits of using CM-CS

  • 1

    CM-CS is an automation software that simplifies the Conflict Minerals Reporting process.

  • 2

    Key compliance checks such as sanity check,cross-referencing between 3TG and Smelter Details are completed within minutes.

  • 3

    Software not only saves significant time and cost but also greatly improves the accuracy of the data.

Features of CM-CS

1

Secure, cloud hosted, web-based application.

2

Manage customer requests and supplier CMRTs/CRTs.

3

Supports multi-division / multi plant reporting.

4

Configurable due diligence and feedback templates.

5

Rapid error free smelter consolidation.

6

Intuitive dashboard with smelter and supplier statistics.

Why Choose APA

  • Comprehensive 3TG & Cobalt due diligence by compliance specialists
  • Cloud based repository for enterprise-wide controlled access
  • Secure, ISO-27001 ready information management framework
  • Export all data in MS Excel
  • Best-in-class solution at lowest cost
  • Management dashboard with multiple performance metrics

FAQ

What is CMRT?

A CMRT (Conflict Minerals Reporting Template) is a is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that expedites the transfer of data regarding mineral country of origin and the smelters and refiners involved.

Which are the major countries that comes under this conflict affected regions?

Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia are the major countries that comes under this conflict affected regions.

What is Dodd-Frank Act?

The Dodd-Frank Act fully known as the Dodd-Frank Wall Street Reform and Consumer Protection Act is a regulation passed during the Obama administration in 2010 to prevent another financial collapse which took place in 2008.

Is sourcing from DRC and the adjoining countries against the law?

Sourcing of conflict minerals from DRC and the adjoining countries is not against the law unless and until the smelters are not RMI certified.

Is it mandatory to submit CMRT to the customer even if 3TG is not used in the products?

Yes, it is mandatory to submit CMRT to the customer even if 3TG is not used in the products where Q1 (Is any 3TG intentionally added or used in the product(s) or in the production process?) in the “declaration” tab should be filled as “No” indicating that 3TG is not used in the products.

What is the connection between SEC and conflict minerals regulation?

SEC’s role in CM regulation is to check whether the business is done through a proper channel; if the whole process dealing with conflict minerals is done legally.

What is CRT?

Cobalt Reporting Template (CRT) is a free, standardized reporting template developed by the Responsible Business Alliance (RBA) that assists the transfer of data regarding the smelters and refiners involved and its mineral country of origin.

How is CRT different from CMRT?

The main difference between CRT and CMRT is that CRT covers only cobalt whereas CMRT covers tin, tantalum, tungsten and gold. All other differences can be found here (Hyperlink of already posted difference between CRT and CMRT).

Move Towards Responsible Sourcing

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