What is RMI's RMAP Participating Smelters and Refiners List

To promote responsible sourcing practices and prevent the use of conflict minerals, the Responsible Minerals Initiative (RMI) has created the Responsible Minerals Assurance Process (RMAP). RMI maintains a comprehensive list of smelters and refiners that participate in the Responsible Minerals Assurance Process. This publicly available list is updated annually and contains detailed information on the location of the facilities, the minerals they process, and their responsible sourcing measures. Downstream companies can rely on this data to make informed decisions when choosing suppliers, ensuring responsible sourcing practices throughout the supply chain.

Why is the Conflict Minerals Smelter & Refiners List important?

If you're in the business of sourcing metals, it's essential to ensure that the smelters or refiners you're working with are responsible and ethical. That's where the RMI’s conformant & Active smelter and refiners list comes in.

  • Conformant Smelter & Refiner Lists

Conformant lists represent smelters and refiners that have successfully completed an assessment against the RMI's RMAP standards or an equivalent assessment in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Area. It's important to note that RMI assessments are backward-looking and evaluate the auditee's due diligence systems and processes to conform with the RMAP standards. They're not a material validation assessment. The audit cycle indicates the period from the last assessment date to the next planned reassessment date, which is one year for RMAP smelters and three years for smelters in a risk-based audit program and TI-CMC members.

  • Active Smelter & Refiner Lists

Active lists represent facilities that have committed to undergoing an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment. They may be in the pre-assessment, assessment, or corrective-action phases of the assessment. The RMI also notes on the active smelters list the names of any smelters or refiners that have left the active or conformant list and intend to re-enter the program. If you're looking to work with smelters and refiners who are committed to responsible sourcing, you should check out the active smelter and refiners’ lists.

Why is Conflict Minerals Smelter & Refiners List important

  • It allows companies to identify which smelters and refiners may be processing minerals from conflict-affected & high-risk regions. This information is critical for companies that are required to comply with conflict mineral regulations, as they need to ensure that their supply chain is free from conflict minerals.

  • The list provides transparency into the smelting and refining industry, allowing companies to make informed decisions about their suppliers and the minerals they source.

What are Smelter Audits and Risk Assessments

Smelter audits and assessments are critical components of due diligence for conflict minerals compliance. It is conducted to evaluate the smelters' due diligence practices and ensure that they are sourcing minerals responsibly. These audits and assessments evaluate the smelters' documentation, management systems, and traceability of minerals from the mine to the final product. To prepare for smelter audits and assessments, companies must understand the requirements and expectations of auditing firms. The following sections will provide you with the necessary steps to prepare for smelter audits and assessments.

How to Prepare for Smelter Audits and Risk Assessments

  • Step 1: Identify Smelters Used in Your Supply Chain

The first step in preparing for smelter audits and risk assessments is to identify the smelters used by your company. You must know which smelters process the minerals used in your products and where these smelters source their minerals. To identify your smelters, you can ask your suppliers to provide you with a list of smelters they use or conduct a survey of your supply chain. You can also use the Conflict Minerals Reporting Template (CMRT), a standardized reporting template developed by RMI, to collect information on your supply chain.

  • Step 2: Evaluate Your Smelters Risk

To ensure that your smelters are free from conflict minerals, it's essential to evaluate them thoroughly. One useful resource is the RMI's Smelter Reference List, which features smelters that have undergone third-party audits and assessments. Additionally, the European Commission's published Indicative, non-exhaustive list of Conflict-Affected and High-Risk Areas (CAHRAs) under Regulation (EU) 2017/821 provides valuable information about regions where known human rights issues exist, and companies should prioritize due diligence accordingly. To conduct your own due diligence, you can review the smelters' documentation, management systems, and traceability practices. This can be done through on-site visits, questionnaires, or third-party audits, ensuring that your supply chain remains conflict-free and in line with responsible sourcing practices.

  • Step 3: Remediate Non-Compliant Smelters

If you find that any of your smelters are non-compliant with conflict minerals regulations, you must take steps to remediate them. This can include working with your suppliers to find alternative smelters or working with non-compliant smelters to improve their due diligence practices. It is essential to keep track of any remediation efforts and document the steps taken to remediate non-compliant smelters.

  • Step 4: Prepare for Smelter Audits and Assessments

Once you have identified and evaluated your smelters, the next step is to prepare for smelter audits and assessments. This involves ensuring that you have the necessary documentation and processes in place to demonstrate compliance with conflict minerals regulations. To prepare for smelter audits and assessments, you can take the following steps:

  • Develop a Due Diligence Policy: Develop a due diligence policy that outlines your company's commitment to responsible sourcing and compliance with conflict minerals regulations. This policy should include information on how you identify and evaluate your smelters and how you remediate non-compliant smelters.

  • Collect Necessary Documentation: Collect all the necessary documentation related to your smelters, including their audit reports, due diligence documentation, and traceability reports.

  • Develop an Internal Audit Process: Develop an internal audit process to ensure that your company is complying with conflict minerals regulations. This process should include regular reviews of your smelters' due diligence documentation and an assessment of any risks associated with your supply chain.

  • Train Your Employees: Train your employees on conflict minerals regulations and the importance of responsible sourcing. Ensure that they understand their roles and responsibilities in ensuring compliance with these regulations.

  • Step 5: Collaborate with Your Suppliers

Collaborating with your suppliers is an essential part of preparing for smelter audits and risk assessments. You must work with your suppliers to ensure that they understand the importance of complying with conflict minerals regulations.

To collaborate with your suppliers, you can take the following steps:

  • Provide Guidance and Support: Provide your suppliers with guidance and support on how to comply with conflict minerals regulations. This can include sharing best practices, providing training, and offering assistance in identifying and evaluating smelters.
  • Conflict Minerals Policy in Supplier Contracts: Require your suppliers to comply with conflict minerals regulations. Make compliance with these regulations a part of your supplier contracts and ensure that your suppliers understand the consequences of non-compliance.
  • Work Together to Eliminate High-Risk Smelters: Share information with your suppliers on the high-risk smelters reported by them. This can help your suppliers identify potential risks in their supply chains and take steps to address them. Follow up with the supplier on the steps taken to comply with or eliminate those high-risk smelters.

The Role of Technology in Managing Your Conflict Minerals Smelter Audit & Risk Analysis

Managing a conflict minerals smelter list can be a time-consuming and complex process. However, technology solutions can help automate and streamline this process, making it easier for companies to comply with regulations and ensure responsible sourcing practices.

One of the key benefits of technology solutions is that they can automate the collection and analysis of data related to smelters and refiners. This can save time and resources, as well as reduce the risk of errors or inconsistencies in the data.

Additionally, technology solutions can provide real-time visibility into your supply chain, allowing you to quickly identify and address any issues related to conflict minerals sourcing. This can help companies to respond to regulatory requirements more quickly and to demonstrate due diligence efforts to stakeholders.

How to choose the right technology solution

  • The level of automation and customization offered by the solution.
  • The ability to integrate with other supply chain management systems and data sources.
  • The cost and ease of implementation.

How Acquis can leverage its technology to help you streamline your conflict minerals program

With Acquis' Conflict Minerals Software, you can source, validate, and consolidate CMRT for conflict minerals reporting while receiving red flags on High-Risk smelters. Our comprehensive reporting and analytics offer real-time visibility of your conflict minerals program, allowing you to make informed decisions to optimize your approach.

By leveraging Acquis' compliance tool, you can streamline and optimize your compliance efforts, saving valuable time and resources, and demonstrating your commitment to social responsibility and sustainability. As a result, you can enhance your responsible sourcing practices, reduce risk, and promote transparency and sustainability throughout your supply chain.

If you are looking for a streamlined solution to manage your conflict mineral regulation? Acquis has you covered. Our advanced technology platform offers a comprehensive suite of tools to help you identify, track, and monitor the use of conflict minerals in your supply chain, ensuring compliance with regulations like the Dodd-Frank Act.

Speak to Our Compliance Experts

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