CM-3 Guide for Responding to the
Conflict Minerals Reporting Templates
4th Edition
Agenda
1.
2.
3.
4.
5.
6.
CM-3 Introduction
What is CMRT
Which suppliers are in scope
Questions 1-7 and A-J
CMRT Assessment Process
Conducting Due Diligence
CM-3
Guide for Responding to the Conflict
Minerals Reporting Template
4th Edition
AIAG CM-3 Publication
• Template assessment
developed by the AIAG
Conflict Minerals Work
Group
• Purpose is to unify the
expected quality of supplier
responses.
• OEMs and Tier-N suppliers
may utilize this optional tool
CM-3 Content
• Introduction
• The Conflict Minerals Reporting Template (CMRT)
• Considerations When Answering CMRT Questions
– Individual sections on Questions 1-7
– Individual sections on Company Level Questions A-J
•
•
•
•
CMRT Assessment Process: Instructions
CMRT Assessment Process
Conducting Due Diligence
Resources
Conflict Minerals Basics
• Dodd–Frank Wall Street Reform and Consumer
Protection Act (2010) and U.S. Securities and Exchange
Commission rule (2012)
• Requests cascade through the
supply chain from the top to the
smelters and refiners
• Primary goal: prevent funding of
ongoing conflict in the covered
countries
What is the CMRT?
The CMRT is the Conflict Minerals Reporting Template
(formerly known as the EICC-GeSI Template)
The “Declaration”
tab contains the
mandatory questions
and company
information
(required).
The “Smelter List” is
the location to list all
smelters/refiners of
3TG in your supply
chain identified by
your direct suppliers
(required).
Relevant Suppliers
Which suppliers are in scope ?
Which suppliers are in scope ?
Companies have the discretion to define relevance
among their suppliers.
Some options may include:
1) all suppliers that use 3TG in the parts that they
provide to your company,
2) top suppliers based on overall annual spend or
turnover,
3) suppliers of a particular commodity known to
contain 3TG, or
4) combination of the above.
Which suppliers are in scope ?
Companies that have access to the International
Material Data System (IMDS) may find it a useful
tool to help identify suppliers that use 3TG.
• IMDS should not be the only tool used due to
the lack of de minimus.
CMRT
Conflict Minerals Reporting Template
Questions 1-7 and A-J
CMRT Questions 1-7
• No 3TG– answer questions 1 & 2 only
• 3TG present– answer all questions 1 through 7
• Answer questions using “drop-down” options
only. Do not type your own answer!
• There is a “Comments” field available for each
answer when additional information is
required.
Company Level Questions A-J
• Questions A-J give the customer additional
details on how your company sources
materials used in their product
• Answer questions using “drop-down” options
only. Do not type your own answer!
• There is a “Comments” field available for each
answer when additional information is
required.
CMRT ASSESSMENT PROCESS
How to assess your supplier’s CMRT
CMRT Assessment Process
Page 18 of the CM-3
Questions 1 through 7
from the CMRT
CMRT Assessment Process
Page 19 of the CM-3
Possible responses
from the drop down
menu in the CMRT for
questions 1 through 7
CMRT Assessment Process
Page 19 of the CM-3
Instructions based on
answers to questions 1
through 7 from the
CMRT.
CMRT Assessment Process
Page 19 of the CM-3
Actions that may be
taken depending upon
the responses for
questions 1 through 7
of the CMRT
CMRT Assessment Process
Instructions on
how to properly
add smelters
CMRT Assessment Process
The CMRT has a built in
checker that will review for any
missing data points.
Red means you need to
complete the missing data
Conducting Due Diligence
Conducting Due Diligence
• Due diligence is defined by the OECD Guidance as:
“an ongoing, proactive and reactive process through which companies can
ensure that they respect human rights and do not contribute to conflict”
• Due diligence is conducted by:
– Determining if your products contain any amount of 3TG along with a list
of relevant suppliers who may supply 3TG
– Collecting information about the origin of these minerals from your
relevant suppliers
– Analyzing the collected information to determine if any supplied 3TG
directly/indirectly funded armed conflict in the DRC or covered country
– Reporting those findings to your customer
• Due diligence goes beyond exchanging data through
the CMRT or other mechanisms
Conducting Due Diligence
• Basing internal processes on industry best practices
enables companies to strengthen due diligence efforts
• Some current best practices include:
– Consulting IMDS for general product content
– Determining top suppliers by spend
– Send a communication to your suppliers with an explanation of the
requirements
– Use central/controlled email accounts such as “generic” emails
– Collect data using the latest CMRT form
– Use the OECD Due Diligence Guidance
– Carefully review your report to your customer in line with each
company’s unique reporting requirements
• Partner with industry groups such as AIAG to ensure alignment
with current practices
Resources
Resources
CM-3: http://www.aiag.org/corporate-responsibility/social/conflictminerals/products
AIAG: http://conflictminerals.aiag.org/
AIAG Conflict Minerals Resources: http://www.aiag.org/corporateresponsibility/social/conflict-minerals/resources-and-links
CFSI Training: http://www.conflictfreesourcing.org/resources-andtraining/training/
CMRT: http://www.conflictfreesourcing.org/conflict-minerals-reportingtemplate/
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
from Conflict-Affected and High-Risk Areas:
http://www.oecd.org/corporate/mne/GuidanceEdition2.pdf