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Tue May 02 2023 | 2 min read

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Responsible sourcing isn’t optional anymore. With rising regulatory scrutiny and growing stakeholder pressure, manufacturers must prove their supply chains are conflict-free—and that starts with knowing exactly who’s refining your minerals.

The Responsible Minerals Assurance Process (RMAP), maintained by the Responsible Minerals Initiative (RMI), offers a verified list of smelters and refiners that have undergone rigorous third-party audits. Whether you're reporting under the Dodd-Frank Act Section 1502, preparing your Form SD and Conflict Minerals Report (CMR), or simply trying to meet ESG expectations, the RMI Conformant Smelter & Refiner List is your first step toward transparency and traceability.

What Is RMI’s RMAP Participating Smelters and Refiners List?

The RMAP Smelter & Refiner List identifies facilities that have been audited and validated for responsible sourcing practices. It includes:

  • Facility name and location
  • Metal(s) processed (3TG: tin, tantalum, tungsten, gold)
  • Conformance status (Conformant, Active, or Non-participating)
  • Audit dates and reassessment schedule

This list allows downstream companies to make informed sourcing decisions and demonstrate due diligence to stakeholders, regulators, and customers.

Why the Smelter & Refiner List Matters for Conflict Minerals Compliance

  • Ensures your minerals are not funding armed conflict
  • Helps meet SEC disclosure and CMR expectations
  • Supports ESG and sustainability reporting frameworks
  • Reduces reputational, operational, and legal risks

Being proactive with smelter review shows your commitment to responsible sourcing and ethical business practices.

What Are Smelter Audits and Risk Assessments for CMRT?

A smelter audit evaluates whether a facility is sourcing minerals responsibly and complying with frameworks like the OECD Due Diligence Guidance. It typically includes:

  • Documentation review
  • Traceability checks
  • Chain-of-custody analysis
  • Site inspections (in some cases)

A risk assessment identifies and evaluates any red flags in your supply chain, such as:

  • High-risk sourcing countries (CAHRAs)
  • Suspicious ownership or management
  • Gaps in supplier disclosures

How to Prepare for Smelter Audits & Risk Assessments

How to Prepare for Smelter Audits & Risk Assessments - visual selection.png

  • Step 1: Identify Smelters in Your Supply Chain

Use tools like the Conflict Minerals Reporting Template (CMRT) or supply chain tracing software to gather smelter info from your Tier 1 and Tier 2 suppliers.

  • Step 2: Evaluate Risk Using Public & Proprietary Lists

Leverage:

  • RMI Conformant & Active Lists
  • EU CAHRAs List
  • Acquis’s Smelter Risk Heatmap (if using Acquis software)
  • Step 3: Remediate Non-Conformant Smelters
  • Replace high-risk smelters where possible
  • Work with suppliers to engage conformant facilities
  • Track and document all remediation efforts
  • Step 4: Prepare Documentation
  • Smelter audit reports
  • Supplier declarations
  • RCOI process records
  • Due diligence policies and training logs
  • Step 5: Engage & Educate Your Suppliers
  • Require conflict minerals clauses in contracts
  • Offer guidance on CMRT/EMRT completion
  • Share risk findings and expectations

Technology’s Role in Simplifying Audits

Modern compliance platforms like Acquis automate risk flagging, smelter validation, supplier outreach, and document management.

Look for Tools That Offer:

  • Pre-integrated RMI Smelter Lists
  • CMRT/EMRT survey automation
  • Custom dashboards and real-time analytics
  • AI-assisted smelter validation

How Acquis Simplifies the Process

  • Centralized CMRT & smelter data tracking
  • Auto-flagging of high-risk smelters
  • Built-in conformity status from RMI
  • Dynamic reports for SEC filing and stakeholder updates

Bonus: Our expert team guides you on engagement strategy, risk prioritization, and supplier compliance.

Strengthen Your Conflict Minerals Compliance

Whether you're starting your first RCOI or optimizing a mature program, Acquis helps you:

  • Ensure smelter transparency
  • Reduce supplier risk
  • Automate Form SD compliance

Schedule a Demo to streamline your conflict minerals due diligence.

Speak to Our Compliance Experts