The U.S. Securities and Exchange Commission (SEC) has adopted a rule mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act that seeks to encourage responsible sourcing by requiring companies to publicly disclose their use of conflict minerals (3TG - Tin, Tantalum, Tungsten, and Gold). All public companies now have to conduct a "reasonable country of origin inquiry," and indicate if the materials in their products have originated from the Democratic Republic of the Congo (DRC) or its adjoining countries, and are used to support armed conflict and humans rights violations.
Conducting the required investigations can be a daunting task for companies, given the wide gap between raw material sourcing and end product distribution. Adding to the complexity, supply chains are only growing larger, more multi-tiered, and geographically spread out. This puts companies under a lot of pressure to find resource-efficient, repeatable, and sustainable ways of tracking the source of potential conflict minerals in their products, and complying with the appropriate disclosure laws.
MetricStream combines a state-of-the-art conflict minerals software solution with a full range of services to help companies implement a robust conflict minerals program. At the start, a team of supplier management and compliance experts lays the groundwork for clients, and continues to support them at each stage of conflict minerals management - right from crafting an effective strategy, to managing supplier self-assessments, to answering suppliers' questions and doubts, to facilitating comprehensive reporting and analysis.
Alongside, the MetricStream solution strengthens the efficiency and effectiveness of conflict minerals programs by streamlining end-to-end workflows, automating resource-intensive tasks, and enabling real-time program tracking. The solution acts as a centralized point of reference, integrating all conflict minerals related processes, data, functions, and suppliers in a single, scalable framework for greater visibility and accountability.
Planning and strategy - The MetricStream team collaborates closely with clients through a series of workshops to help them develop an effective conflict minerals strategy and implementation plan. The team also provides online help, training, and webinars on best practices in conflict minerals management and supplier governance.
Supplier information management - The MetricStream solution integrates with enterprise and external systems to import information on suppliers, sub-suppliers, contractors, agents, products, smelters, and conflict minerals, as well as updates from sources such as the EICC Conflict Free Smelter list. All this information is stored in a centralized, easily searchable repository, and mapped to the client's internal business units and products for greater accountability and transparency.
Creation of supplier self-assessments and surveys - The MetricStream solution provides pre-built templates based on industry standards such as EICC-GeSI. Alongside, the MetricStream team designs supplier self-assessments and surveys to capture all critical information such as smelter lists, country of origin of materials, affected products, and sub-supplier reports on conflict minerals. The team also helps establish supplier communication protocols, escalation mechanisms, and automated alerts and notifications within the MetricStream solution.
Survey execution and follow-up - The MetricStream team manages the entire process of distributing surveys to suppliers, following up on responses, and providing comprehensive technical and support services to suppliers. A web-based portal in the MetricStream solution enables any number of suppliers from anywhere across the globe to log on, and complete the surveys. Capabilities such as multi-language support, and automated alerts and notifications keep the process on track, and help ensure that surveys are completed on time.
Issue and incident management - All issues that are identified during supplier surveys are automatically routed by the MetricStream solution through a systematic process of issue and remediation. Powerful dashboards help track all issues at the enterprise level, and proactively identify areas of concern or potential risk.
Analysis and reporting - The MetricStream solution provides an extensive database of pre-defined reports and dashboards, including conflict minerals reporting scorecards, supply chain KPI scorecards, refinery smelter diligence trackers, conflict lists, compliance 3TG smelter reports, and 3TG trace status in products reports. Alongside, graphical administrative dashboards enable the top management to track the progress of the conflict minerals program in real time across the enterprise.
After conducting a country of origin inquiry, if a company finds that the materials in its products have indeed originated from the DRC and its adjoining countries, MetricStream enables and supports the full range of required due diligence activities, including Source and Chain of Custody Due Diligence, Conflict Minerals Policy and Procedure Management, Conflict Minerals Assessments and Audit Management, Issue and Remediation Management, and Conflict Minerals Reporting.
The solution also offers the extensibility to go beyond conflict minerals management and reporting, and be used to address other areas of supplier governance such as supplier risk management, supply chain audits, supplier performance management, and supplier compliance.