Conflict Minerals Management
MetricStream Conflict Minerals Management Solution
The U.S. Securities and Exchange Commission on August 22, 2012 adopted a rule mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act that seeks to enhance transparency and publicly disclose the use of conflict minerals (Tin, Tantalum, Tungsten, and Gold / referred as 3TG) that are mined in the Democratic Republic of the Congo (DRC) or an adjoining country to support armed conflict and violate human rights.
As per Section 1502 Conflict Minerals of the Dodd-Frank Wall Street Reform and Consumer Protection Act, if a company uses any of the designated materials in their product and has some actual influence over the manufacturing of the product, it has to conduct a reasonable 'country of origin' inquiry and determine whether the minerals originated from the covered countries or are from scrap or recycled sources.
If the inquiry determines that the minerals are not from the covered countries or are from scrap or recycled sources, then the company must disclose its determination, provide a brief description of the inquiry it undertook and the results of the inquiry on Form SD and also publish the same in the public domain.
If the inquiry determines that the minerals have originated from the covered countries, then the company must undertake "due diligence" on the source and chain of custody of its conflict minerals, file a Conflict Minerals Report as an exhibit to the Form SD and publicly disclose the conflict mineral report. The company is also required to provide details of processes and audits performed to reach these conclusions. The due diligence measures must conform to a nationally or internationally recognized framework, such as the due diligence guidance approved by the Organisation for Economic Co-operation and Development (OECD). There are specific conflict mineral reporting requirements for DRC Conflict Free, Not Been Found to Be "DRC Conflict Free" and for DRC Conflict Undeterminable.
MetricStream Conflict Minerals Management Solution provides capabilities to determine whether it is applicable for the organization by capturing supplier, product information, details of conflict minerals included in the product, smelter reasonable country of origin etc. The built-in best practice templates and workflows help organizations to plan and manage audits, risk assessments, implement risk mitigation and issue remediation and prepare appropriate conflict minerals report.
Supplier, Location & CM Information Management - MetricStream solution provides capabilities to identify and manage information of various stakeholders in supply chain including supplier, sub-supplier, licensee, contractor, agents, smelters etc. and detailed information of conflict minerals and products supplied by each stakeholder. It helps capture and manage details of conflict free smelters, compliant smelter list for tin, tantalum, tungsten and gold, establish traceability and visibility across the supply chain. Buyers and Sourcing team can map the supplier and their product information to organization's internal business units and products. It has built-in templates and workflows to facilitate supplier declaration of smelter list, product list with conflict minerals and to identify applicability of the conflict minerals program for the organization. The MetricStream solution provides capabilities to integrate with third-party websites to download up-to-date information on Conflict Free Smelter list, Conflict Minerals and Company Rankings etc.
CM Policy and Procedure Management - MetricStream solution's policy management functionality allows organizations to create, manage, and communicate various policies and procedures on their conflict minerals program, usage of conflict minerals in the products supplied and supplier governance (for example - supply chain policies, policies to implement chain of custody, and traceability). It ensures suppliers are well aware and trained on company specific as well as regulatory compliance requirements.
Source and Chain of Custody Due-Diligence - MetricStream solution's risk management functionality provides capabilities to perform detailed due-diligence, identify and manage risks across the supply chain. It supports identification and assessment of various types of risks, risk categories, types, allows users to map risks to processes, products, suppliers etc and store the same in central repository. It supports configurable methodologies including OECD framework for scoring and rating of risks, qualitative and quantitative criteria to assess risks and aggregate results to create a risk profile for each supplier.
CM Assessments and Audits Management - MetricStream solution's audit management functionality helps companies plan, schedule and manage third-party audits required for conflict minerals program. Third-party auditors can login to MetricStream solution from anywhere, access the relevant supplier information; audit related tasks, activities; templates standard questionnaires, checklists, and surveys required for the audits. Auditors can capture relevant information, attach evidence, audit findings, issues and route it for review and approval.
Issue & Remediation Management - MetricStream solution's issue and corrective / preventive action functionality enables companies to establish and follow consistent procedures for capturing issues and planning risk mitigation processes, documenting corrective actions for audit findings, and reporting any potential risks and compliance gaps. It captures issues from supplier declarations, third-party audits, as well as due-diligence and route it to the suppliers, and subject matter experts to develop and implement corrective and preventive actions.
Reports, Dashboards and Analytics - MetricStream solution help create conflict minerals report with complete details of supplier, source information, chain of custody, smelter and product list with conflict minerals, details of audits and due-diligence conducted and results of the same. It has built-in reports that highlight conflict minerals program status, supplier improvement plans, Issue resolutions, conflict free smelter status, list of completed audits, compliant smelters, product 3TG traceability status etc.